GST UPDATES IN THE MONTH OF NOVEMBER 2018

Image result for GST hd picsUPDATES WITH GST

  • GSTR-3B is mandatory for all the tax payers those who have registered under GST. The Due Date for GSTR-3B has been extended from the month of July 2017 to Nov 2018 is now till 31st December 2018 for newly migrated tax payers and the due date for others is not changed.
  • Every registered dealer is required to file GSTR-1 every month. The return contains details of all outward supplies made during the month.The Due Date to file GSTR-1 has been extended for the taxpayers with Turnover above the Amount 1.5 crores in previous year or current year.
  • The Due date for the month from July 2017 to September 2018 extended till the 31st October 2018.
  • The current four bills that have been passed do not put forth a single uniform rate across all categories. Instead a multi-tier tax slab has been put forth with four different tax rates i.e., 5%, 12%, 18% and 28%. The reasoning behind this is that luxury goods cannot be taxed at the same rate as daily necessities.
  • There would also be goods that are tax-exempted and zero-rated which implies that there are six categories of products and services under the bill. An additional Cess on demerit goods such as aerated drinks, luxury cars and tobacco products would be levied. There will not be any tax on food products and petroleum products as of now. There has been no information as of yet regarding alcohol under GST.
  • Services will not be taxed over 18% and 5% tax will be levied on mass consumed products such as packaged salts and spices although food grains and other agricultural products are not going to be taxed. For most other products and services, the nearest tax slab will be applicable. Items generally used by the common man such as toothpaste, oil, soap and others will be taxed between 12% to 18% as opposed to the current rate which is over 20%.
  • GST Bill is expected to have a good impact on the general public as products of mass consumption, such as food grains, will not be taxed. Other commodities and services that are commonly used, like soaps and toothpaste will attract 12%-18% tax, which is lower than the current rate of more than 20%. Even household products such as refrigerators and washing machines will be cheaper as the rate of tax now applicable to them is 28% as opposed to the previous rate of 30%-31%.

Update GST Registration:

  • Most of the commodities and services that are subject to GST have been categorized under four tax slabs, viz. 5%, 12%, 18%, and 28%. However, GST Rates is not applicable to some goods and services, such as jute, fish, eggs, fresh meat, milk, chicken, curd, fresh fruits, butter milk, vegetables, natural honey, bread, salt, besan, Prasad, sindoor, printed books, bindi, judicial papers, newspapers. hand loom, bangles, horn cores, bone meal, bone grist, horn meal, hoof meal, Palmyra jaggery, cereal grains hulled, coloring and drawing books, etc.

Key Due Dates:

  • 31st December 2018.
  • 31st October 2018.

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decision do consult your professional /tax Adviser for their misrepresentation or interpretation of act or rules author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associate, a leading Tax & Investment planning Adviser Service provider. His Blog can be found at http://carajput.com for any query you can write to info@carajput.com. Hope the information will assist you in your professional endeavors. For query or help contact: info@carajput.com  or call at 09811322785/4- 9555555480.

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corporate and professional updates 18th oct 2018

Image result for corporate and professionalDIRECT TAX

  • Addition on account of un-explained loan – assessee discharged its initial onus to prove the identity of the investor company, its creditworthiness and genuineness of the transaction in the matter – No additions  – ITAT Delhiin case of [Raj Kumar Chawla Vs. ACIT, Central Circle-IX, New Delhi

  • Scope of Exemption u/s 10(20) – Municipal Committee – Scheme of the Rajasthan Urban Improvement Act, 1959 does not permit acceptance of the contention of the appellant assessee that Urban Improvement Trust is a Municipal Committee within the meaning of Section 10(20) Explanation (iii)  – Supreme Court Of Indiain case of [The ITO, CITVs. Urban Improvement Trust, Urban Improvement Trust Kota, Urban Improvement Trust Through Director
  • Reopening of assessment u/s 148 – rejection of objections raised by the assessee – the reopening of the assessment in the writ petitions with reference to Sections 147 to 153 is in accordance with law and there is no infirmity, as such  – Madras High Courtin case of [M/S. South Asia Fm Limited Vs.The ACIT, The DCIT

  • Addition on account of share capital/premium received – The income/losses declared by the investor companies is not a sole criterion to examine the creditworthiness of the shareholders – Psychotropics Leasing & Finance Pvt. Ltd., Vs ITO (2018 (10) TMI 855 – ITAT Delhi)
  • Exemption 10(37) – acquisition of the urban agricultural land as a compulsory acquisition – – merely because the sale price was fixed through a negotiated settlement, the character of acquisition would still remain compulsory – ITO Vs Smt. Girijakumari M (2018 (10) TMI 852 – ITAT Ahmedabad).
  • The revenue department has issued preliminary notices to about 10,000 people under the benami law seeking source of income details as it analyses data on deposits of cancelled notes after the November 2016 demonetisation.
  • Allahabad HC issues notice to CBDT on the issue of levy of interest u/s 234A despite due date extension
  • ITAT Kolkata held that TDS not deductible on Internet connectivity charges & specialized line rental. ACIT Vs SDV International Logistics Ltd. (ITAT Kolkata)
  • Calcutta High Court held that payment by tenant for removal of sub-tenants from property is capital expenditure. nited Spirits Limited Vs Commissioner of Income Tax (Calcutta High Court)
  • Search assessments. The time limit of 2 years u/s 153B for framing search assessment orders applies only to the original order and to orders passed after remand. The time limit for passing remand orders is governed by s. 153(3)/ erstwhile 153 (2A) & not by s. 153B. Limitation begins (for any purpose under the Act) from the point of time when the departmental representative receives the copy of a decision or an order of the ITATSurendra Kumar Jain vs. PCIT (Delhi High Court)
  • Calcutta High Court held that payment by tenant for removal of sub-tenants from property is capital expenditure. nited Spirits Limited Vs Commissioner of Income Tax (Calcutta High Court)

INDIRECT TAX

  • SC upholds the time limitation for claiming ITC i.e. 90 days from the date of purchase or before the end of the FY whichever is later – ALD Automotive Pvt. Ltd. Vs ACT & Ors. (2018 (10) TMI 814 – Supreme Court).
  • Correction of errors in the TRAN-1 declarations – migration to GST Regime – transitional provisions – There is no scope for directing the respondents to allow the petitioner to correct the TRAN-1 declaration already made – Jay Chemical Industries Ltd. Vs Union of India (2018 (10) TMI 876 – Gujarat High Court).
  • Supreme Court of India in Section 19 (11) of TNVAT Act,2006-Cases failure to claim ITC with in the time prescribed has since been disposed off. The SC has dismissed all the Civil Appeals of the dealers.
  • Delhi High Court allows manual filing of GSTR-3B. IndusInd Media & Anr. Vs. Union of India & Ors. W.P. (c) No. 8691/2018.
  • The Gujarat High Court has issued the notice to Centre and GST Council on a petition challenging the provisions of Central Goods and Services Tax (CGST) Act, seeking interest for delayed IGST Refund.
  • AAR Punjab held that GST Payable on complementary IPL tickets & ITC can be claimed. In re KPH Dream Cricket Pvt. Ltd. (GST AAR Punjab)
  • Punjab and Haryana HC held that No GST on license Fee for sale of liquor for human consumption.DivyaSinglaVs Union of India (Punjab and Haryana HC

FAQ ON GST

  • Query:Other than appellate remedy, is there any other recourse available to the taxpayer against a summary assessment order?
  • Answer:A taxable person against whom a summary assessment order has been passed canapply for its withdrawal to the jurisdictional Additional/Joint Commissioner within thirty days of the date of receipt of the order. If the said officer finds the order erroneous, he can withdraw it and direct the proper officer to carry out determination of tax liability in terms of section 51 of MGL. The Additional/Joint Commissioner can follow a similar course of action on his own motion if the finds the summary assessment order to be erroneous (section 48 of MGL).
  • Query: Under what circumstances can a special audit be instituted?

  • Answer:A special audit can be instituted in limited circumstances where during scrutiny, investigation, etc. it comes to the notice that a case is complex or the revenue stake is high. This power is given in section 50 of MGL.

MCA UPDATES

  • The Ministry of Corporate Affairs (MCA) has ordered a probe by the Serious Fraud Investigation Office(SFIO) into allegations of suspected audit and financial fraud running into Rs 7,500 crore by the city-based Ramky Infrastructure Limited after the Registrar of Companies, Ranchi, flagged the issue.
  • Leading foreign bank to drag Kwality to NCLT over Rs 12 billion default.

SEBI UPDATES

  • SEBI is planning to relax rules for listing of startups in India, which include giving promoters the flexibility to categorise themselves as ordinary shareholders and exempting them from the mandatory three-year lock-in period – ET.
  • SEBI clarified with respect to amendments to regulation 40 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, which stated that transfers of listed securities would not be processed after 5 December 2018, unless such securities are held in a dematerialized form with a depository.

RBI UPDATES

  • Govt and RBI are not in favour of extending the deadline to store payments data mirroring by payments firms as an alternative to only storing data locally, The central bank has mandated that all payment firms, including MasterCard, Visa, American Express and Paypal, should store their India related data locally.
  • The Reserve Bank of India on Tuesday laid out guidelines that would allow for seamless payments between different mobile wallets, in a move that could further boost the use of digital payments in the country.
  • RBI will not relax the October 15 deadline for global financial technology (fintech) companies to comply with its data localisation norms in the public interest.
  • RBI sold the highest amount of dollars in five years to curb the slide in the rupee. In the five months April-August, RBI sold almost $34 billion in spot and forward markets $18.6 billion in spot and $15 billion in forwards.

OTHER UPDATES

  • NBFCs are likely to be impacted significantly if the liquidity situation, triggered by IL&FS default, continues to remain tight as its subsidiaries are facing liquidity crisis and has defaulted on debt repayment. The default by IL&FS has also impacted other NBFCs and also mutual fund players.
  • Bank of Baroda invites proposals from Chartered Accountant Firms/Groups for conducting financial and tax due diligence of Bank of Baroda, Dena Bank and Vijaya Bank for the proposed amalgamation.
  • Private sector lender ICICI Bank Tuesday said the RBI has approved Sandeep Bakshi’s appointment as Managing Director and CEO of the bank for three years. After the resignation of Chanda Kochhar, who was facing inquiry, earlier this month, the bank’s board had elevated Chief Operating Officer (COO) Bakshi as the new managing director and CEO for three years until October 3, 2023, subject to regulatory and other approvals.
  • Prime Minister Narendra Modi has urged oil suppliers to review payment terms to give temporary relief to the rupee, which has fallen sharply in recent months.
  • Central Vigilance Commission has completed a first-of-its-kind analysis of the top 100 banking frauds, including those in the jewellery and aviation sectors, and shared its findings with the RBI, the ED and the CBI The analysis focused on the methods used, amount involved, type of lending (consortium or individual), anomalies observed and loopholes that led to the frauds, along with recommendations to plug the gaps in the system
  • ICAI has given an opportunity to students to change the Centre or Group or Medium as filled by them in examination form from 15.10.2018 to 24.10.2018 fee Rs. 1000.

KEY DUE DATES

October 2018 Due Dates:

  • 31st October- TCS Return for Jul to Sep 2018- Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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corporate and professional updates 12th oct 2018

Image result for corporate and professional updatesDIRECT TAX

  • CBDT lays down the functionality for processing of Returns having Refund Claims which were not processed within the time allowed u/s 143(1) due to some technical or other reasons.
  • Bombay High court held that reassessment for non-disclosure of bank A/C which was disclosed during original assessment is invalid. Akshar Developers Vs Assistant Commissioner of Income-tax (Bombay High Court)

Indirect Tax:

  • CBEC has amend the Central Goods and Services Tax Rules, 2017. These rules may be called the Central Goods and Services Tax (Eleventh Amendment) Rules, 2018 which shall be deemed to have come into force with effect from the 23rd October, 2017. Vide notification no 53/2018, dated 9th October 2018.
  • CBIC amends Rule 96, refund of integrated tax paid on goods or services exported out of India: Notification No. 53/2018 – Central Tax dated 9th October 2018.
  • CBEC has clarified that both the state and central authorities handling the goods and services tax have enforcement powers over all assessees in a state, triggering fears that the industry may get caught in a crossfire between the two.
  • National anti-profiteering authority (NAA) orders to Companies or dealers may have to cut prices of each stock keeping unit (SKU) of their products to pass on the benefits of any lower GST rate. in a case related to a Maggi noodles (Nestle’s) dealer.
  • CBIC clarifies that both the State and Central Authorities handling the GST have Enforcement Powers over All Assessee in a State. Both the Central Tax and State Tax Authorities are allowed to Initiate Intelligence-Based Enforcement Action on the entire taxpayer base, irrespective of the administrative assignment of the taxpayers to any authority.
  • The National Academy of Customs, Indirect Taxes and Narcotics (NACIN) is conducting an examination for confirmation of enrollment of Goods and Services Tax Practitioners (GSTPs) enrolled on the GST Network under sub-rule (2) of Rule 83 and covered by clause (b) of  sub-rule (1) of Rule 83 of Central Goods and Service Tax Rules, 2017. Such GSTPs are required to pass the examination before 31 December, 2018. The examination will be held on 31.10.2018 from 1100 hrs to 1330 hrs at designated examination centers across India. In this matter kindly refer Press Release dated 17 September 2018.The registration for this exam by the eligible GSTPs has already started on 25 September, 2018.

FAQ on GST Audit:

  • Query:What is the legal recourse available in respect of a person who is liable to pay tax but has failed to obtain registration?
  • Answer:Section 63 of CGST/SGST Act provides that in such a case, the proper officer can assess the tax liability and pass an order to his best judgment for the relevant tax periods. However, such an order must be passed within a period of five years from the due date for furnishing the annual return for the financial year to which non-payment of tax relates.

SEBI UPDATES

  • SEBI has allowed eligible foreign entities including stock exchanges to hold 15 per cent stake in depository participants in India. Earlier, foreign players were allowed to hold 15 per cent in domestic stock exchanges but none of them have scaled up their holdings to that mark so far as India’s exchange space is considered heavily regulated

OTHER UPDATES

  • CCI amends its regulations to make it easier for corporations to Secure Approvals for Mergers and Acquisitions (M&A). It allows companies to Voluntarily Divest Assets for M&A Approvals.
  • ICAI releases Exposure Draft on Accounting Standard (AS) 40:  Investment Property, which is slightly different from the Indian Accounting Standards (Ind-AS) of the Ministry of Corporate Affairs (MCA).The stakeholders can submit their comments on or before 10th November 2018
  • ICAI has made it mandatory for its members to get a unique document identification number, or UDIN, a move to identify and weed out fake chartered accountants. From January 1, 2019, all paperwork for clients will need to show UDIN of the CA.
  • As per Govt. Sources, IL&FS will be New Audit Watchdog NFRA’s First Test Case. Set up recently, NFRA has the powers to launch a Sue Moto Investigation on Suspected Accounting Irregularities. It is also empowered to penalize Chartered Accountants and Audit Firms
  • With an aim to deepen the Commodity Derivatives Market, SEBI allows trading in this segment by Foreign Entities with exposure to the Indian Physical Commodity Market.

KEY DUE DATES

October 2018 Due Dates:

  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018
  • - Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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CORPORATE AND PROFESSIONAL UPDATES 11TH OCT 2018

Image result for corporate and professional updatesDirect Tax:

  • ITAT Mumbai held that Income of Indian plastic institute from technical lectures, seminars and workshop is exempt.  M/s. Indian Plastics Institute VsThe Assistant Director of Income Tax Officer (ITAT Mumbai)
  • Calcutta High Court held that payment by tenant for removal of sub-tenants from property is capital expenditure. nited Spirits Limited Vs Commissioner of Income Tax (Calcutta High Court)
  • CBDT further extends due dt for filing of IT Returns & audit reports from 15th Oct,2018 to 31st Oct, 2018 for all assessees liable to file ITRs for AY 2018-19 by 30.09.2018, after considering representations from stakeholders. Liability to pay interest u/s234A of IT Act will remain same.
  • CBDT has set up a committee to draw up the Incentive programme to reward and recognise honest taxpayers to encourage a culture of compliance like A cup of tea with the state governor, priority check-in at the airport, passports on priority, dedicated toll lanes, airport lounge access etc.
  • Every company to which sec 115JB of income tax act, 1961 applies, is required to file Form 29B certifying that book profits have been computed in accordance with the provisions of the Income Tax Act. Further, the Form 29B should be electronically filed along with the return of income before the due date.
  • Undue delay in granting the refund – The petitioner cannot claim any further interest or compensation over and above the statutory interest prescribed u/s 244A – having regard to long delay, the CIT shall pay cost of ₹ 1,00,000/= to the petitioner –NIMA Specific Family Trust Vs ACIT (2018 (10) TMI 441 – Gujarat HC).

INDIRECT TAX

  • AAR stated that No ITC admissible on GST paid on freight for transportation of petro goods to the export warehouse located in another state.
  • GSTN has introduced the new RFD-01A form for Refund by Supplier of deemed export. In these article we will see the detailed analysis related to the Refund form, Rules and how to file the nil and not a nil refund form online.
  • Govt has imposed an anti-dumping duty of up to USD 719 per tonne for five years on import of nylon filament yarn from the European Union (EU) and Vietnam following recommendations by the commerce ministry’s investigation arm DGTR.
  • Jurisdiction of Central and State tax administrations under GST – Both the Central and State tax administrations shall have the power to take intelligence-based enforcement action in respect of the entire value chain – O. F. No. CBEC/20/43/01/2017-GST(PT), dt.05.10.2018.
  • Levy of GST – printing services – The supply of Aadhaar Cards are classifiable under heading 9989 of GST Tariff and attracts GST @ 12% – AAR, Hyd-Tel. in  KL Hi-Tech Secure Print Ltd. (2018 (10) TMI 445).

FAQ on GST Audit:

  • Query:Who is the person responsible to make assessment of taxes payable under the Act?
  • Answer:Every person registered under the Act shall himself assess the tax payable by him for a tax period and after such assessment he shall file the return required under section 39

MCA UPDATES

  • MCA notified Form RC-1 vide Companies (Authorised to Register) Second Amendment Rules, 2018, dated 5th July 2018 would be available for filing purposes w.e.f 9th October 2018. Web-service RUN and SPICe form are also likely to be revised due to the impact of introduction of URC-1 form.
  • MCA notified URC-1 vide Companies (Authorised to Register) Second Amendment Rules, 2018, dated 5th July 2018 would be available for filing purposes w.e.f 9th October 2018.

SEBI UPDATER

  • SEBI has put in place revised norms for recovering of investors’ money, wherein a registered insolvency professional will be appointed as administrator to undertake sale of assets.

RBI UPDATES

  • foreign RBI investors with new relationship terms for a commitment of staying invested a minimum three years in local debt from them. In exchange, it has offered unbridled access to local derivatives market and its own liquidity facilities.
  • RBI is expected to increase policy rates by 25 basis points in the first quarter of the next year, primarily led by inflationary pressures and depreciation of the rupee, says a Goldman Sachs report.
  • The Reserve Bank of India Sovereign Gold Bond Scheme 2018-19, Operational Guidelines. Vide notification no RBI/2018-19/58, dated 8th October 2018.

OTHER UPDATES

  • ICAI has released an exposure draft on ICAI Code of Ethics, 2018. The Last date for comments on this Draft is November, 7, 2018.
  • Central government will issue Sovereign Gold Bonds 2018-19 for public subscription from October 15-19 and will be issued every month from October 2018 to February 2019.” bonds would earn an interest of 2.5% per annum, payable every six months on the nominal value.
  • International Monetary Fund (IMF) retained economic growth projection for India at 7.3% for 2018-19.  IMF wants the RBI to tighten monetary conditions. For the next year 2019-20, the IMF lowered India’s growth projections to 7.4%.
  • ICAI releases List of Valid Nominations for election to the 24th Council and 23rd Regional Councils. There are 19 Valid Nominations for CC and 46 Valid Nominations for RC from Northern India.
  • UIDAI has said that the Supreme Court order restricting use of Aadhaar will have no bearing on enrolment and update services being carried out at banks, post offices and government premises. The move comes as service providers may still use offline verification tools that leverage the unique ID without authentication.

KEY DUE DATES

October 2018 Due Dates:

  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018
  • - Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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corporate and professional updates 9th oct 2018

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Direct tax

  • 244: The Dept should bring some order and discipline to the aspect of granting refunds. All pending refund applications should be processed in the order in which they are received. It is the bounden duty of the Revenue to grant refunds generated on account of orders of higher forums and disburse the amount expeditiously. In the absence of a clear policy, the Courts may impose interest on the quantum of refund at such rates determined by the Court. SICOM Ltd vs. DCIT (Bombay High Court)
  • 80-IC: An assessee who avails of deduction for a period of 5 years @ 100% of profits and gains is entitled to deduction on ‘substantial expansion’ for remaining 5 Assessment Years @ 25% (or 30% where the assessee is a company) and not @ 100% (Mahabir Industries v. PCIT 256 TM 201 (SC) distinguished) CIT vs. Classic Binding Industries (Supreme Court)

INDIRECT TAX

  • Foreign embassies to comply CGST notifications to claim compensation cess refund.Representations have been received by the Board regarding the entitlement of UN and specified international organizations, foreign diplomatic mission or consular posts, diplomatic agents and consular offices post therein to refund of Compensation Cess.
  • CBDT has extended the due date for filling of return of income and reports of audit pertaining to assessment year 2018-19 from 15thOctober 2018 to 31st October 2018. Vide notification no 225/358/2018/ITAT.II, dated 8th October 2018

FAQ on GST Audit:

  • Query:Can a consolidated ‘revised invoice’ be issued to every recipient for supplies made during the period before registration is granted?
  • Answer:As Per Proviso to Rule 6 (2) of Tax Invoice, Credit and Debit note Rules, it is mandatory to issue separate tax invoices in the following cases:
    • Supplies to registered persons;
    • Inter-state supplies to unregistered persons where the taxable value of the supplyexceeds Rs. 250,000.

A consolidated invoice can be issued to an unregistered recipient (State- wiseconsolidation) not covered above.

MCA UPDATES

  • MCA has decided to relax the additional fees payable to companies having registered office in the State of Kerala on e-forms AOC-4, AOC (CFS) AOC-4 XBRL and e- Form MGT-7 upto 31.12.2019, wherever additional fee is applicable.
  • URC-1 notified vide Companies (Authorised to Register) Second Amendment Rules, 2018, dated 5th July 2018 would be available for filing purposes w.e.f 9th October 2018. Web-service RUNand SPICe form are also likely to be revised due to the impact of introduction of URC-1 form. Stakeholders are advised to check the latest version before filing.

RBI UPDATES

  • RBI lowered its retail inflation projection for the second half of the current fiscal to 3.9-4.5 per cent mainly because of an unusually benign trend in food prices. Food inflation has remained unusually benign, which imparts a downward bias to its trajectory.
  • RBI proposed new norms for foreign portfolio investors (FPIs) to attract long-term and stable FPI investments into debt markets while allowing them operational flexibility. RBI, in consultation with the government and Sebi, has proposed the voluntary retention route to encourage FPIs willing to make long-term investments in debt.

OTHER UPDATES

  • ICAI submitted representation suggesting non-deduction of TDS under MVAT Act after implementation of GST:Certain Govt Departments  like PWD & other Municipal Corporations and Local Self Govt bodies continue to deduct TDS as per the provisions of Section 31 of MVAT Act.

KEY DUE DATES

October 2018 Due Dates:

  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018
  • - Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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CORPORATE AND PROFESSIONAL UPDATES 8TH OCT 2018

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Direct Tax:

  • Bombay High court held that reassessment for non-disclosure of bank A/C which was disclosed during original assessment is invalid. Akshar Developers Vs Assistant Commissioner of Income-tax (Bombay High Court)
  • Demand of Interest U/S Section 234 A illegal once due date has been extended : Income Tax Department cannot demand interest U/S Section 234 A, once due date of ITR has been extended, Kerala High Court admits writ petition.
  • Income Tax Dept has notified norms for applicability of concessional long-term capital gain tax. This will benefit investments made in IPOs and follow-on public offerings (FPOs). The new norms will come into effect from April 1, 2019, and will apply in relation to assessment year 2019-20 and subsequent assessment years.

INDIRECT TAX.   

  • Form GSTR-9C released. Due date of filing GSTR -9C yet to be notified.

  • Extension of Due date for GSTR-3B only for newly migrated taxpayers for months July 2017 to Nov 2018 till 31st December 2018. The due dates remain unchanged for rest of the taxpayers.
  • Extension of Due date for GSTR-1 in case of taxpayers with turnover above Rs 1.5 crores in previous FY or Current FY
    • Regular taxpayers : for months from July 2017 to September 2018 extended till the 31st October 2018.
    • Newly migrated taxpayers : for months from July 2017 to November 2018 extended till the 31st December 2018.

  • Extension of Due date for GSTR-1 in case of taxpayers with turnover upto Rs 1.5 crores in previous FY or Current FY

a.Regular taxpayers :

Quarter                                    New Due date

July – September 2017            31st October 2018

October – December 2017      31st October 2018

January – March 2018             31st October 2018

April – June 2018                    31st October 2018

July – September 2018            31st October 2018

October – December 2018      31st January 2019

January – March 2019             30th April 2019

  • Newly migrated taxpayers : For all quarters from July 2017 to September 2018 extended till 31st December 2018.

  • For flood-affected regions of Kodagu, Mahe and Kerala : Above table of dates remain the same except for quarter July 2018 to September 2018 extended till 15th November 2018.

  • Due date of TRAN-1 and TRAN-2 is extended for certain taxpayers who could not complete filing due to tech glitch, to 31st March 2019 and 30th April 2019 respectively.

  • CBIC released formats of GSTR -9 & GSTR -9A.

  • GST council waives the late fees for the following :

  • Taxpayers whose GSTR -3B for the month of October 2017 was submitted but not filed on the common portal.

  • Taxpayers whose GSTR -4 was filed for the period of October to December 2017 within due date but late fees were mistakenly charged.

  • Input service distributors who paid late fees for GSTR-6 for any tax period between 1st Jan 2018 to 23rd Jan 2018.

FAQ on GST Audit:

  • Query:If a taxable person fails to  file  the return  required  under  law  (under  section  39 ( monthly/ quarterly), or  45  ( final return), what legal recourse is available to the tax officer?
  • Answer:The proper officer has to first issue a notice to the defaulting taxable person under section 46 of CGST/SGST Act requiring him to furnish the return within a period of fifteen days. If the taxable person fails to file return within the given time, the proper officer shall proceed to assess the tax liability of the return defaulter to the best of his judgment taking into account all the relevant material available with him. (Section 62).

MCA UPDATES

  • Constitution of National Financial Reporting Authority:In exercise of the powers conferred under Companies Act, 2013 the Central Government hereby appoints the 1stOctober, 2018 said Act shall come into force.
  • MCA has issued circular regarding Relaxation of additional fees and extension of last date of in filing of forms MGT-7 (Annual Return) and Aoc-4 (Financial statement) under the Companies Act, 2013- State of Kerala. Vide circular no 09/2018, dated 5th October 2018.

RBI UPDATES

  • Reserve Bank of India (RBI) Wednesday relaxed policy on borrowing from overseas to allow state-owned fuel retailers to raise up to USD 10 billion external debt for working capital needs.
  • Banks move to alert ED on exporters whose payments have been delayed:In the past few days, banks have shared with the Enforcement Directorate the names of thousands of exporters who have not received payments against shipment of goods

KEY DUE DATES

October 2018 Due Dates:

  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018 -Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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CORPORATE AND PROFESSIONAL UPDATES 5TH OCT 2018

Image result for corporate and professional updatesDirect Tax:

  • ITAT Mumbai held that set-off of long-term capital loss on sale of unquoted equity shares against gain on sale of property. Chandra N. Hingorani Vs ITO (ITAT Mumbai)
  • Calcutta High Court held that payment by tenant for removal of sub-tenants from property is capital expenditure. nited Spirits Limited Vs Commissioner of Income Tax (Calcutta High Court)
  • The ITAT Delhi in ITO vs. Gisil Designs Pvt. Ltd has held that the AO was negligent in filing the remand report before the CIT(A). The same attitude has continued at the stage of filing appeal to the ITAT as condonation of delay was filed for 92 days. The excuse that the appeal was not filed due to the AO being busy with time barring assessment is not acceptable. The AO deliberately overlooked the impugned order and did not file appeal before the Tribunal within the period of limitation. Even the authorization by Pr. CIT to file the appeal has been granted after the period of limitation. Hence sufficient cause is not shown – [2018-ITRV-ITAT-DEL-027]
  • The ITAT Delhi in ITO vs. Virat Credit & Holdings Pvt.Ltd has held that the grant of approval by the CIT with the words “Yes. I am satisfied” proves that the sanction is merely mechanical and he has not applied independent mind while according sanction as there is not an iota of material on record as to what documents he had perused and what were the reasons for his being satisfied to accord the sanction to initiate the reopening of assessment u/s 148 of the Act – [2018-ITRV-ITAT-DEL-031]
  • The Delhi High Court in Pr. CIT vs. N. C. Cables Ltd has held that mere appending of the word “approved” by the CIT while granting approval u/s 151 to the reopening u/s 147 is not enough. While the CIT is not required to record elaborate reasons, he has to record satisfaction after application of mind. The approval is a safeguard and has to be meaningful and not merely ritualistic or formal – [2017-ITRV-HC-DEL-181]

INTERNATIONAL TRANSATIONS / TRANSFER PRICING

  • The Karnataka High Court in PCIT vs. Softbrands India P. Ltd has explained the entire law on when transfer pricing disputes constitute “substantial questions of law” for challenge in the High Court explained. Transfer Pricing Adjustments on the basis of the comparables are a matter of estimate of broad and fair guess-work of the Authorities based on relevant material. The exercise of fact finding or ‘Arm’s Length Price’ determination or ‘Transfer Pricing Adjustments’ should become final with a quietus at the hands of the final fact finding body, i.e. the Tribunal. The ITAT’s findings of fact cannot be challenged in the High Court unless it is shown that the findings are ex-facie perverse and unsustainable and exhibit total non-application of mind by the Tribunal to the relevant facts of the case and evidence before it – [2018-ITRV-HC-KAR-025]
  • The ITAT Ahmedabad in ACIT vs. Veer Gems has explained the important law on meaning of expression “associated enterprise” u/s 92A. The mere fact that an enterprise has de facto participation in the capital, management or control over the other enterprise does not make the two enterprises “associated enterprises” so as to subject their transactions to the rigors of transfer pricing law – [2017-ITRV-ITAT-AHD-179]
  • The ITAT Ahmedabad in Quick Flight Limited vs. ITO has held that in case where payments have been made to deductees on the strength of the beneficial provisions of s. 115A(1)(b) of the Act or as per DTAA rates r.w.s. 90(2) of the Act, the provisions of s. 206AA cannot be invoked by the AO insisting to deduct tax @ 20% for non-availability of PAN – [2017-ITRV-ITAT-AHD-180
  • Delhi High Court has issued notice in a plea seeking a direction to the CBDT to extend the date of filing of ITR and Tax Audit Report for AY 2018-2019 by assessees who are required to file the same by Sept 30, 2018

INDIRECT TAX

  • Finance ministry expects the GST collections to cross Rs 1 trillion in November and December on account of festive season demand and the anti-evasion measures initiated by the revenue department. GST) revenue rose to Rs 944.42 billion in Sept.
  • ICAI is clarified that an Internal Auditor of an entity cannot undertake GST Audit of the same entity.

FAQ on GST Audit:

  • Query:What would be the action by the proper officer upon conclusion of the audit?
  • Answer:The proper officer shall, on conclusion of audit, within 30 days inform the taxable person about his findings, reasons for findings and the taxable person’s rights and obligations in respect of such findings.

MCA UPDATES

  • Standard Operating Procedure by MCA for Grievance Redressal Mechanism: Complaint on MCA website through link http://www.mca.gov.in/mcafoportal/usercompaintDetails.doshould be raised by the Stakholders/professionals.
  • Form 1 and Form 2 (along with Form 17 & Form 18) which are pending processing as on 1st October 2018 shall be marked under resubmission.  All forms shall be resubmitted by using new service RUN-LLP for name reservation or FiLLiP for incorporation only.  All names which have been approved and against which incorporation form is not filed, shall be allowed to be used to file form FiLLiP for incorporation.  All names which have been approved and against which change of name Form 5 is not filed, shall be allowed to be used to file in revised Form 5 only.

RBI UPDATES

  • The Reserve Bank of India has issued notification regarding External Commercial Borrowings (ECB) Policy. Vide notification no RBI/2018-2019/54, dated 3rdOctober 2018.

OTHER UPDATES

  • NFRA IS CHALLENGED IN THE COURT: ICAI, in Hon’ble High Court, after hearing the counsels the high court passed the order to stay any disciplinary action against any member, next date of hearing is 16.01.2019
  • Govt is mulling permitting 100% FDI in insurance broking to give a boost to the sector. The FDI policy, at present, allows 49% foreign investment in the insurance broking, insurance cos, third party administrators, surveyors and loss assessors

KEY DUE DATES

October 2018 Due Dates:

  • 5th October- DIR 3 KYC of Directors
  • 7th October- TDS Deposit – Sep 2018 Month
  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018
  • - Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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CORPORATE AND PROFESSIONAL UPDATES 4TH OCT 2018

Image result for corporate and professional updatesDirect Tax:

  • ITAT Cuttack held that remuneration to partners cannot be disallowed merely because share of partners not fixed or deed not provides for manner of qualification of such remuneration. Panda Fuels Vs ITO (ITAT Cuttack)
  • Recovery of dues – attachment of property – Period of limitation – The incompetent authority, therefore, cannot prejudice legal rights of petitioner flowing from statutory provisions or eclipse the same in any manner. Notice is, therefore, beyond period of three years and, therefore, hit by Rule 68B( 1)  – Bombay High Courtin case of [M/SRambilas Gulabdas (HUF) , Vs. Tax Recovery Officer, Range-7, CIT (Vidarbha) Nagpur M/S Rambilas Gulabdas(HUF) , Vs. Tax Recovery Officer, Range-7, CIT (Vidarbha) Nagpur]
  • TDS u/s 194H – credit card commission expenses – payments to banks on account of utilization of credit card facilities would be in the nature of bank charge and not in the nature of commission within the meaning of sec. l94H  – ITAT Bangalore  in case of [Velankani Information Systems Ltd. Vs. The DCIT, Circle 7 (1) (2) ,Bangalore And Vice-Versa]
  • Diversion of income by overriding title at source – This is where we feel the tax avoidance effort has been made by the parties and we cannot uphold the same in the overall analysis of the facts and legal position applicable to the facts of the present case  – Karnataka High Courtin case of The Pr. CIT Vs. M/S. Chamundi Winery AndDistillery]
  • Rejection of books of accounts – GP estimation – Fall in gross profit ratio could be due to various reasons, and cannot be the sole and only ground to reject the book results in entirety and frame best judgment assessment – Delhi High Court  in case of [The Pr. CIT-9 Vs. IBILT Technologies Ltd.]
  • Rajasthan High Court gave directions to CBDT for further extension of Income Tax Return filing date and Tax Audit Return filing date to 31st October-2018 and waiver of interest u/S 234A of the Income Tax Act.

Indirect Tax:

  • CBEC has issued circular regarding Modification to the Guidelines for Deductions and Deposits of TDS by the DDO under GST as clarified in Circular No. 65/39/2018-DOR dated14.09.2018. Videcircular no 67/41/2018.
  • CGST/Tamil Nadu GST: Where petitioner could not avail input tax credit in view of lack of clarity in new transitional provisions under GST Act, it was directed to place all material facts in accordance with Circular No. 39/13/2018-GST, dated 3-4-2018 before Jurisdictional Officer, who would forward same to Nodal Officer.

FAQ on GST Audit:

  • Query:Can documents which had earlier been filed with some wrong information be revised under this Scheme?
  • Answer:Reason being, Scheme clearly specifies that only overdue documents due for filing upto 30.06.2017 should be filed under this Scheme and therefore revision of previously filed annual filing e-forms shall not be taken on record.

MCA UPDATES

  • MCA plans to put in place a stricter disclosure framework for independent directors, including providing details about their resignation from companies, as part of continuing efforts to bolster corporate governance standards.
  • Form DIR-12 is likely to be revised on MCA21 Company Forms Download page w.e.f 4th OCT, 2018.Stakeholders are advised to check the latest version before filing.
  • As part of process re-engineering of LLP incorporation forms, Form 1,
    Form 2, Form 2A, Form 17, Form 18 and Form 5, web-service/revised forms
    (RUN-LLP, FiLLiP, Addendum to FiLLiP, Form 17, Form 18 and Form 5) shall be available on portalw.e.f 2nd October 2018.

OTHER UPDATES

  • SBI has lowered the ATM cash withdrawal limit to Rs 20,000 a day, from Rs 40,000. The lower limit will be effective from October 31. “In view of the increase in the number of complaints received by banks around fraudulent transactions at ATMs.

KEY DUE DATES

October 2018 Due Dates:

  • 5th October- DIR 3 KYC of Directors
  • 7th October- TDS Deposit – Sep 2018 Month
  • 14th October- ADT 1 for Appointment of Auditor
  • 15th October- TCS Return for Jul to Sep 2018 – Tax Audit & ITR for FY 2017-18
  • 18th October- GSTR 4 for Composition Dealer for Jul 2017 to Sep 2018
  • 20th October- GSTR 3B – Sep 2018 Month
  • 30th October- AOC 4 for FY 2017-18
  • 31st October- GSTR 1 for July 2017 to Sep 2018
  • 31st Oct- TDS Return for Jul to Sep 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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CORPORATE AND PROFESSIONAL UPDATES 2ND OCT 2018

Image result for corporate and professional updates

Direct Tax:

  • ITAT Indore held that profit from sale of land with well thought business project is business income.Smt. Anita Singh Vs ACIT (ITAT Indore)
  • ITAT Chandigarh held that 100% deduction under section 80IC allowable on substantial expansion of eligible unit.  Friends Alloys VsAsstt. CIT (ITAT Chandigarh)
  • Gujarat High court held that tax cannot be levied on gain from sale of agricultural land based on intention of buyer to use the land for business purpose.  Principal CIT Vs Heenaben Bhadresh Mehta (Gujarat High Court)
  • ITAT Jaipur held that interest on income tax refund not eligible for deduction under section 80IE. M/s. OMIL JSC (JV) Kameng Kota. Vs Dy. CIT (ITAT Jaipur)

INDIRECT TAX

  • GST Offline utility of Form GSTR-10 (Final Return) is now available in the download section of GST portal. The excel based offline utility is designed to help taxpayers to prepare their Form GSTR-10 offline.
  • CBIC extends Mandatory RFID sealing due date to 01.11.2018. References have been received regarding Circular 19/2018-Customs dated 18th June 2018 seeking a postponement in the date for mandatory RFID sealing in case of movement of goods under warehousing bond.
  • GST Council set up a committee of seven state finance ministers to examine the legality and recommend the methodology for levying an ‘additional tax’ to raise revenue for floods-ravaged Kerala.

FAQ on GST Audit:

  • Query: What is the legal recourse available in respect of a person who is liable to pay tax but has failed to obtain registration?
  • Answer:Section 47 of MGL provides that in such a case, the proper officer can assess the tax liability and pass an order to his best judgment for the relevant tax periods. However, such an order must be passed within a period of five years from the due date of filing of the annual return for the financial year to which non-payment of tax relates.

RBI UPDATES

  • RBI issued draft directions for the prohibition of abuse in the fixed income markets, stating, among other things, that market participants, either acting independently or in collusion, shall not undertake any action with the intention to manipulate the process of calculation of a benchmark rate or reference rate.
  • The Reserve Bank of India has issued notification regarding Co-origination of loans by Banks and NBFCs for lending to priority sector.

MCA UPDATES

  • MCA has A High Level Committee on CSR (HLC-2018) to review the existing framework and guide and formulate the roadmap for a coherent policy on Corporate Social Responsibility ( CSR).

KEY DUE DATES 

  • GSTR-3B (SEP 2018)-OCT 20th, 2018
  • GSTR-5 (SEP 2018)-OCT 20th, 2018
  • GSTR-4 (JULY-SEP, 2018)-OCT 18th, 2018
  • GSTR-5A (SEP 2018)-OCT 20th, 2018
  • Quarterly return for registered persons with aggregate turnover up to Rs. 1.50 Crores- GSTR-1 (JULY- SEP, 2018)-OCT 31ST, 2018.
  • Quarterly return for registered persons with aggregate turnover more than Rs. 1.50 Crores- GSTR-1-(SEP 2018)-OCT 31ST 2018

Disclaimer:

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances; Before making any decisions do consult your Professional / tax advisor. For misrepresentation or interpretation of act or rules Author does not take any responsibility. Neither the author nor the firm accepts any liability for the loss or damage of any kind arising out of information in this document or for any action taken in reliance there on. The author is a Chartered Accountant and the Chief Gardener & Founder Director of Rajput Jain & Associates , a leading Tax & Investment Planning Advisory Service Provider. His blog can be found at http://carajput.com/blog/For any query you can write to info@carajput.com. Hope the information will assist you in your Professional endeavors. For query or help, contact:   info@carajput.com or call at 09811322785/4 9555 5555 480)

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