GST - Need for preserving data bases, documents relating to pre-GST regime

[Srikanthan S]

India has moved forward to a single indirect tax system with effect from 1^st July, 2017 which is considered to be a major milestone in the history of India.

As is usual in any fiscal statute, various compliances have been prescribed under the new GST laws; the country is progressing in this direction with great support from the GOI and the IT back-bone GSTN.

As we hear from various agencies about the amount of transitional credit availed by the registered dealers via TRAN-1 and the likelihood of scrutiny at some point in future, this Article is an attempt to draw attention to an important area: data and documents preservation to avoid possible disputes and tax demands not only with respect to TRAN-1 but also in respect of other earlier transactions.

It would be prudent to preserve the data / documents relating to the period ending with 30^th June, 2017, more importantly those supporting the transitional credit availment.

To list a few:

1. All excise data / documents including PLA balances
2. Import / Export data / documents
3. Purchase Invoices (along with excise and related documents), Sale Invoices, Service Tax related documents/Returns, Stock Transfer Invoices (Inwards / Outwards) along with related Lorry Receipts, Waybills supporting the transfers (in a few States like West Bengal require reconciliation), F Forms issued / received, H Forms issued (in respect of domestic transactions leading to Export), C Forms issued / received etc.
4. All documents / data relating to Industrial Exemptions enjoyed till 30.6.2017, refunds pending to be received from Central and State Governments, and correspondence relating thereto.
5. Original Excise / VAT / Service Tax and other Registration Certificates to be preserved carefully.
6. All assessment orders, notices and replies thereto, pending litigation related documents etc. 
7. Many a time, data relating to past pending assessments may be called for and hence preserving the data bases / ERP accesses (including master passwords) is essential so that retrieval is made easy in future.  In many large organizations, IT personnel, third party support systems and functional people may leave and appropriate handover process in respect of data bases should be ensured.

Request learned readers to add on to the above list to make it more comprehensive.

Finance, IT, Tax/Commercial and Legal teams to work towards this carefully.