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TMI BlogMinutes of the 22nd GST Council Meeting held on 6 October 2017X X X X Extracts X X X X X X X X Extracts X X X X ..... 7 under Goods and Services Tax (GST) and Compensation paid to States for the period July - August, 2017 5. Report and Recommendations of the Committee on Exports 6. Issues for consideration for relief to small taxpayers i. Proposal for increasing the aggregate annual turnover threshold under Composition scheme from ₹ 75 lakh (₹ 50 lakh in Special Category States except Uttarakhand and Jammu Kashmir) to Rs. one crore; and not taxing the exempt supplies made by a composition dealer ii. Proposal for quarterly filing of returns along with quarterly payment of taxes by taxpayers having annual turnover up to ₹ 1.5 crore iii. Proposal for suspension of application of provisions of sub-section (4) of section 9 till 31 March, 2018 iv. Proposal for deciding the date for the operationalization of provisions of nationwide e-Way bill 7. Issues recommended by the Fitment Committee for consideration of the GST Council i. GST Rate in respect of government works contract services having high labour content ii Definition of Governmental Authority and GST on Government Grants iii Rate of tax on car leasing, sale of leased cars, sale of old and used ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... starting Tax Deduction at Source and Tax Collection at Source iii. Changes in GST rates on certain goods and exemption from IGST in certain cases iv. Issue of Annuity being given in Place of Toll Charges to Developers of Public Infrastructure-exemption thereon v. Additional relief to Small Tax Payers- Composition Scheme vi. GST on development charges collected by Gift City Company Limited for allotment of land on long term lease (of 30 years or more) to developers for development of commercial and residential spaces vii. Additional relief to Small Tax Payers - GTA to unregistered persons 14. Date of the next meeting of the GST Council 3. The Hon'ble Chairperson welcomed the Members of the Council. He stated that originally this Meeting was proposed to be held through video conferencing but as various letters and suggestions were received from States and other stake holders, a regular Meeting was being held . He commenced discussion on the agenda items. Discussion on agenda items: Agenda item I: Confirmation of the Minutes of the 21 st GST Council meeting held on 9 September, 2017 4. The Hon ble Chairperson requested the Chairman, CBEC to inf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o definition of governmental authority and transfer of budgetary grant are to be discussed independently of the issue of works contract even when these two issues have been discussed in relation to works contract also . The Council agreed to add the version proposed by the State of Gujarat. 4.5. The AS, GSTC informed that the State of Gujarat had requested to replace the first sentence of paragraph 5.22 of the Minutes with the following: CCT Gujarat stated that if a Government corporation or authority or board was allotted grants by the State government (for example grant allocated to construct a jail or police line, etc.), such transaction should not attract GST at the rate of 18% . The Council agreed to add the version proposed by the State of Gujarat. 4.6. The AS, GSTC informed that the State of Odisha had suggested to replace the version of the Hon ble Minister from Odisha recorded in paragraph 33.2 (ii) of the Minutes ( The Hon ble Minister from Odisha stated that fly ash was a very important commodity and that tax on it should be Nil ) with the following: Fly Ash caused environmental pollution. There was no consideration for fly ash. 1f it was kept in taxable category ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the State of Punjab in paragraphs 33(vi) and 34.1 (iv) of the Minutes could not be accepted. The Council agreed not to make amendments in paragraphs 33(vi) and 34.1(iv) of the Minutes. 4.10. The Hon ble Minister from Punjab drew attention to the Council s decision recorded in paragraph 7.1 of the Minutes that the issue of Form C under the Central Sales Tax (CST) Act shall be examined further in light of the court decision and requested that this issue should be examined urgently and issue necessary clarification as another judgment had been delivered by the Hon ble Mumbai High Court on this issue. Shri Udai Singh Kumawat, Joint Secretary, Department of Revenue, (DOR) informed that an amendment proposed in Section 8(3) of the CST Act was presently being examined by the Union Law Ministry and the same would be issued shortly. 5. In view of above discussion, for agenda item 1 , the Council decided to adopt the Minutes of the 21 st Meeting of the Council with the changes as recorded below: 5.1. To suitably add the following version in paragraph 5.3 of the Minutes: Dr. P.D. Vaghela, CCI , Gujarat, stated that the report of CCTs on CST may be considered by the Council which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Commercial Tax, Sikkim requested GSTN to modify the registration software application to provide field requiring the applicant to fill in licence details. He said that this was necessary to make the software compatible with the GST law as Section 22(2) of the CGST Act, 2017 prescribed that holding of licence was pre-requisite for filing registration application. He also requested the Council to authorise GSTN to carry out the needful modification. 5.7. To amend the version of the Hon ble Minister from Punjab recorded in paragraph 31.2 of the Minutes with the following: He suggested that similar goods should attract same rate and in one chapter there should not be more than three rates and that... Agenda item 2: Decisions of the GST Implementation Committee (GIC) for information of the Council 6. The Chairman, CBEC invited Shri Upender Gupta. Commissioner, (GST Policy), CBEC, to make a presentation on the decisions taken by the GST Implementation Committee (GIC) since the 21 Meeting of the Council held on 9 September, 2017. The presentation made by the Commissioner (OST Policy), CBEC is at Annexure 3 of the Minutes. 6.1. In his presentation, the Commissioner (GS ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... en given for the development of priority functionality and mostly the timelines, as given, were maintained, except for delay of about 2-3 days. He further informed that return filing was getting stabilised and about 13 lakh Returns were filed on 20 September 2017, and in one hour, more than one lakh Return had been filed. He informed that the GoM had also decided that technical team from Infosys should be deployed in each State and that Infosys had already deployed some people but in the next two weeks, this deployment would be beefed up by deploying more technical persons. He added that the GoM had also asked Infosys to deploy separate team for development of Backend Applications for Model 2 States (27 in number) for which Infosys was developing the backend facility of the tax administration. 8.1. The Hon ble Chairperson desired to have a briefing about the main IT related problems being faced by the taxpayers and how these were being addressed. Shri Prakash Kumar, Chief Executive Officer (CEO), GSTN made a presentation on this issue which is attached as Annexure 4 . 8.2. In the presentation, the CEO, GSTN, gave an update on the number of Registrations, Returns, Invoices, d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... im personnel with permanent ones who are qualified to do this job, in next two weeks; (ii) Sharing of data on the following items with Model 1 and 2 in csv (comma separated values) format: (a) Enrolment Report-Daily incremental is being shared after sharing of complete data dump ; (b) New Registration Report - Daily incremental is being shared after sharing of complete data dump; (e) Return Filer- Daily incremental is being shared after sharing of complete data dump; (d) Dealers complete Address list- Complete data dump (one time) shared for both, migrated as well as newly registered ones; (e) GSTR 3B filer-Complete data dump (one time); (iii) Sharing of data with Model 1 States -the root cause for difference in data reported and records (registration form, returns etc.) pulled by CBEC/Model I States has been found and corrective action taken; (iv) Enabling tax payers stuck at submit stage to edit the same and file GSTR-3B (2.2 lakh taxpayers); (v) Amendment of core and non-core items of Registration form rolled-out on the portal; (vi) Tran-1 Filing (Negative Credit issue) resolved for future use. Cases done in past are being dealt with separately by data fix; (vii) Suo moto Regist ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turns on the last date, if they so choose, and that overload on the System should not be a factor for inability to file Returns. He suggested that until the System stabilised, fine and penalty should be deferred. The Hon ble Minister from Odisha stated that there should be a one-time measure not to impose fine and penalty. The Hon ble Chairperson observed that if fine and penalty was deferred for the next six months, then no one would file Returns. He observed that the sanctity of dates for filing Returns should be maintained. The Hon ble Deputy Chief Minister of Bihar suggested that this issue could be decided at a later date. 8.6. The Secretary informed that late fee was waived for July, 2017 Return but no late fee waiver was announced for August Return as it could discourage filing of Returns leading to loss of revenue. He observed that the amount of late fee leviable was not very high. The Hon ble Chief Minister of Goa stated that those taxpayers who paid tax in July, 2017 but could not file their Returns due to glitches in the System should not be penalised for late filing of the Returns for the month of August, 2017. The Secretary observed that filing of GSTR-3B was necess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ories of taxpayers should not be introduced in the law. He suggested to do the staggering on the basis of existing categorisation like exemption threshold of ₹ 20 lakh per annum, composition threshold, etc. The Hon ble Minister from Karnataka stated that before taking decision on revising the dates for filing Returns, one should wait for one cycle of GST Return filing to be completed. He observed that once offline utility was fully operational in the next two weeks, the time spent by a taxpayer on the System for filing Return could come down from 40 minutes to 5-10 minutes and the throughput of the System would go up substantially. The Secretary stated that some modification in timelines for filing Returns by small taxpayers was already in the agenda of this Meeting [Agenda item 6(ii)]. 8.9. The Hon ble Deputy Chief Minister of Delhi raised three issues. First, he suggested that GSTN should also look at the capacity of the income tax IT System for accepting the number of Returns every hour and the load of Return filing that it can withstand on the last day of the Return filing. Second, he observed that there was no service level agreement with GSTN for delivery of services ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... revenue collection of VAT and SGST for the months of July and August, 2017 and the settlement fund released to States based on July and August, 2017 Returns. He informed that compensation could not be released to Arunachal Pradesh as the State had not yet reported the revenue collection in the month of August, 2017. He stated that revenue figures for the State of Rajasthan were also being further verified as the revenue collection figure reported by the State was very low. 10.1. The Hon ble Minister from Assam stated that in order to ensure full transparency, the Department of Revenue of the Government of India should share the calculation sheet for compensation to the States. The Hon ble Minister from Rajasthan stated that compensation for his State should not have been withheld on account of variation in the figures of revenue as the law was very clear in this regard. He observed that the Department of Revenue could ask reasons for variation but there was clear and categorical protection of law for not stopping compensation. The Joint Secretary, Department of Revenue, informed that the officers from Rajasthan had informed that they would clarify the issue shortly. The Secretar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be depleted in the next 2-3 months depending upon the revenue trend. The Hon ble Chairperson stated that in the coming months, buoyancy on account of VAT revenue would not be available and the amount available in the Cess fund was a floating fund which could be used as per the requirements of compensation. The Hon ble Minister from West Bengal stated in his written comments that the downturn in revenue and reduction in the number of Returns filed for the month of August. 2017 as compared to the month of July, 2017 showed that there were serious procedural issues and shortcomings in the GSTN framework plaguing the implementation of GST, thereby adversely affecting the small and medium enterprises and this precarious situation required serious correction. 10.4. The CEA stated that there should be transparency in respect of compensation and each State should know the compensation given to other States including those States which had surplus revenue. The Secretary pointed out that the Hon ble Minister from Assam had already made a similar demand. He added that revenue of the first two months would not show a reliable trend. The Hon ble Minister from Punjab requested to share data o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a stated that the share of revenue of the Centre and the States pre-GST was 45:55. The Hon'ble Chairperson observed that compensation related issues of the States of Rajasthan, Sikkim and Jammu Kashmir should be resolved at the earliest. 11. For agenda item 4 , the Council took note of the GST collection for August and September, 2017. The Council also agreed that a chart showing revenue figure of each State and its compensation requirement (including the calculation for the same) shall be prepared on bi-monthly basis and shared with all the States while disbursing the compensation amount to the States. Agenda item 5: Report and Recommendations of the Committee on Exports 12. The Chairman, CBEC, invited Shri Sandeep M. Bhatnagar, Director General, Directorate General of Export Promotion (DGEP), CBEC and Member Secretary of the Committee on Exports to brief the Council on the report and the recommendations of the Committee. DG, DGEP, made a presentation on the report of the Committee on Exports, which is attached as Annexure 5 . He informed that the Committee and its Sub-groups met six times between 19 September, 2017 and 29 September, 2017. He further informed t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TR-1 was made available as per prescribed timelines in routine. He stated that refund of IGST paid on export of services, supplies to SEZs and refund of accumulated input tax credit on account of export of goods/services and supplies to SEZs under Bond/LUT had to be dealt with by jurisdictional Central/State GST officers. With concurrence of all stakeholders, the Committee had decided certain timelines for dealing with such refund claims. Thus, by 6 October 2017, the GSTN and the DG Systems, CBEC would finalize modalities for CBEC to receive all GSTR-1 and all GSTR-3B; by 10 October 2017, GSTN would make available on the website a new utility form RFD 01A for refund claimant which would contain a request to debit the credit ledgers for ITC refund being claimed; and by 30 October 2017, GSTN would make available facility in a new form RFD 01B for GST officers to order re-credit of the amount of refund rejected. He informed that Pr. CCA, CGA, CAG, Budget' Division in the Department of Economic Affairs, Department of Revenue and State accounting authorities were finalizing the accounting procedure and settlement of funds. He added that GIC was looking into the cross empowerment of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the credit against the refund paid to him. He added that notional credit in e-Wallet was like an advance refund, with the restriction that this could only be used to pay taxes and would be adjusted against final payment of refunds. He explained that the credit in e-Wallet could be used for payment of IGST on imports thus ensuring that there was no additional burden of working capital. As regards payment of GST on domestic purchases, he explained that thee-Wallet system would permit transfer of balances from the exporter's account to his supplier's account so that GST could be paid by the supplier on the basis of the amount transferred in his e-Wallet by the exporter. He reiterated that balance in e-Wallet would be allowed only to pay taxes. He observed that the working capital requirement in the eco-system would get reduced by the amount of the notional credit given in the e-Wallets. 12.4. DG, DGEP, further informed that another cause of increased transaction cost identified by the Committee was the requirement of bond/letter of undertaking (LUT) for all exports and bank guarantee in certain cases. He stated that the Committee's recommendation was to dispense with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oring the end use. 12.8. Initiating the discussion on the recommendations of the Committee on Exports, the Hon'ble Minister from Punjab observed that it was an excellent report and congratulated the Committee members on their work. On the issue of working capital blockage to exporters, he suggested that presently Option-1 (allowing tax payment through Advance Authorisation/EPCG/EOU schemes) could be implemented and Option-2 (e-Wallet) could be implemented by April, 2018. The Hon'ble Minister from Jammu Kashmir stated that Option-1 damaged the basic structure of GST of not giving exemptions which also applied for duty exemption schemes for North-Eastern States. He stated that the basic structure of GST should not be tampered with due to operational difficulties which was largely due to delay in the delivery by the IT vendor. He also expressed an apprehension that the vendor would take a long time to develop the system of e-Wallet. He cautioned that if a regime of exemptions was introduced, the GST architecture might collapse. The Hon'ble Minister from Karnataka stated that problems of exporters were critical and solution must be found but the proposed solutions were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... served that provisions of GST law were proposed to be tweaked due to the problems of the IT vendor. He enquired regarding the impact on revenue of 1% tax was levied on merchant exporters. He also enquired whether this proposal was discussed with the exporters. DG, DGEP explained that the issue was discussed with the various export associations and their preference was to have an upfront exemption but once they were explained the GST design, they agreed that 1% tax on supplies to merchant exporters was the best solution. Shri Khalid A. Anwar, Senior Joint Commissioner, Commercial Taxes, West Bengal, stated that the Hon'ble Minister from West Bengal had desired him to convey that exports were in a very bad shape and the Export Promotion Councils had reported that exports had come down drastically. He stated that as e-Wallet would take some time to develop, Option-1 proposing an upfront exemption should be considered. He stated that merchant exporters also enjoyed similar exemption through Form 'H' under VAT and they should not be discriminated against by charging tax at the rate of 1% on supplies made to them. The Hon'ble Deputy Chief Minister of Bihar observed that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... used only for payment of tax. He stated that in the interim, some measures could be taken to help the exporters meet their working capital requirement. The Hon'ble Minister from Jammu Kashmir suggested to give upfront subsidy to exporters. He observed that the industry in Jammu Kashmir was in crisis due to removal of area based exemption scheme and they would demand its restoration if exemption for exports was permitted. He added that no refund had been given to the industries in Jammu Kashmir for the last three months and till now he had been explaining to them that it was a systemic reform, and now they would again demand upfront exemption. He observed that e-Wallet was virtual currency and the proposed solution was sectoral in nature and so not desirable. He also expressed worry about the technology to be used for e-Wallet after the experience with the current vender. The Deputy Chief Minister of Gujarat desired to know as to how much money was blocked due to pending refunds on exports. The CEO, GSTN stated that this amount would have to be culled out from the GSTR-3B returns. The Secretary stated that GSTN might not have full data because GSTR-1 had been uploaded only ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly be 0.1 %. The Hon'ble Chief Minister of Goa cautioned that once an exporter lost his market, he would not get it back as the buyer would switch to another supply chain. He recalled that Goa was once the biggest exporter of iron ore but once it lost its market due to certain reasons, it was not able to regain it. He suggested that the old system of exemption should be retained for some time. The Hon'ble Minister from Odisha supported the suggestion of the Hon'ble Chief Minister of Goa. The Hon'ble Minister from Chhattisgarh stated that export was exempt from tax as GST was a consumption based tax. He stated that the Committee had given unanimous recommendation and the Council should accept Option-1 as an interim measure and move to Option-2 later. The Hon'ble Minister from West Bengal stated in his written comments that till e-Wallet was introduced, he favoured the time-tested model of exemption like Section 5(3) of the Central Sales Tax Act for not only merchant exporters, but also for manufacturing exporters and EOUs. He further stated that the concern was whether, even after treating the supplies of domestic suppliers to exporters as deemed exports, they wo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at this would take a minimum of six months to develop. The Hon'ble Chairperson stated that e-Wallet could be implemented by 1 April 2018 and till then the old system as proposed in Option-1 could be continued. 12.16. Shri Tuhin Kanta Pandey, Principal Secretary (Finance), Odisha stated that the system of e-Wallet should be legally examined as this system involved creating money to pay tax. The Hon'ble Chairperson stated that this issue could be looked at by officers who were not associated with drafting of the original Law. He stated that a new Committee of officers should review the law and propose changes in the CGST/SGST Acts and the IGST Act taking into account various feedbacks and these proposals could be brought before the Council. The Secretary stated that during the Budget session of the Parliament, changes in the Law could be introduced and for this a new Law Review Committee of officers could be constituted in which the old members of the Law Committee could be called for consultation but decisions should be taken by the new Law Review Committee. He added that the existing Law Committee could continue to look into day-to-day operational issues of the GST law ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... make available electronically to CBEC, Table 6A of GSTR-1 of exporters containing details of zero rated supplies. These refunds shall be dealt with by Customs Officers. (ii) For Refund of IGST paid on export of services, supplies to SEZs and refund of accumulated input tax credit on export of goods/services and those supplied to SEZs under Bond/LUT, the following timelines were approved: (a) The GSTN and the DG Systems, CBEC shall finalize modalities for CBEC System to receive GSTR-1 and GSTR-3B from the GSTN by 6 October 2017; (b) by 10 October 2017, the GSTN would make available on the website a new utility Form RFD 01A for refund claimant which would contain a request to debit the credit ledgers for lTC refund being claimed; (c) by 30 October 2017, the GSTN would make available facility in a new Form RFD 01B for GST officers to order re-credit of the amount of refund rejected; (d) these refunds would be dealt with by jurisdictional Central/State GST officers. (iii) To grant exemption from IGST, Cess, etc. under Section 6 of the IGST Act, 2017 read with Section 25 of the Customs Act, 1962 to import of goods for exporters availing the schemes of Advance Authorisation/Export ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... C stated that these issues were discussed during the meeting of the officers held on 5 October 2017 and the changes proposed by them were indicated in red colour in the presentation. The presentation is attached as Annexure 3 . The discussion for each agenda item is recorded below. Agenda Item 6(i): Proposal for increasing the aggregate annual turnover threshold under Composition scheme from ₹ 75 lakh (₹ 50 lakh in Special Category States except Uttarakhand and Jammu Kashmir) to ₹ 1 crore; and not taxing the exempt supplies made by a Composition dealer 15. The Commissioner (GST Policy), CBEC stated that it was proposed to increase the aggregate annual turnover threshold under Composition scheme from the existing ₹ 75 lakh to ₹ 1 crore. He stated that the limit for the Special Category States could also be discussed by the Council. The facility of availing such increased limit could be extended to both the migrated as well as the new tax-payers and would become valid from the first day of the subsequent month in which the option to migrate to the Composition scheme was exercised. He added that the increase in the turnover threshold would mak ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Chairperson stated that the new Law Review Committee could look at recommending a higher turnover threshold for the Composition scheme. 15.2. The Hon'ble Minister from Chhattisgarh stated that after three months of implementation of GST, his discussions with small taxpayers had revealed large scale dissatisfaction with procedures under GST amongst Micro, Small and Medium Enterprises (MSMEs). He stated that MSMEs and cottage industry had suffered setback after introduction of GST and that while they accounted for large scale employment, barely 5% of total revenue came from them. He stated that there was a need for balance between 5% revenue and employment scenario. In this light, he supported the proposal for increasing the threshold turnover for Composition taxpayers from ₹ 75 lakh per annum to Rs. one crore per annum and to also exclude the exempt supplies from the calculation of the turnover of the Composition dealer. The Hon'ble Chief Minister of Goa, the Hon'ble Ministers from Jammu Kashmir, Kerala, Odisha, Punjab, Haryana, Madhya Pradesh, Karnataka and Telangana, and the Senior Joint Commissioner (Commercial Taxes), West Bengal supported the proposal to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orced to maintain separate books of accounts. The Hon'ble Deputy Chief Minister of Delhi stated that exclusion of exempt turnover would lead to inspectors visiting taxpayers to verify their books of accounts to ascertain the quantum of exempt supplies. The Hon'ble Minister from Tamil Nadu also expressed an apprehension that taxpayers would find it difficult to segregate their turnover into taxable and exempt categories and that this would lead to Inspector Raj. He suggested that tax for Composition dealers could be reduced to less than one per cent. The Hon'ble Minister from Assam stated that the fear of arbitrage and return of Inspector Raj was exaggerated. He added that it was not proper to always vilify Inspectors as the Government was paying them salary and they also did good work in expanding the taxpayer base and collecting more revenue. He supported the proposal to exclude the value of exempted goods from the total turnover value for the Composition taxpayers. The Hon'ble Minister from Kerala stated that it would have been desirable to extend the limit of Composition turnover to ₹ 1.5 crore if the law so permitted, but in its absence, it would be better ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... States was provided in the Law. The Hon'ble Deputy Chief Minister of Manipur expressed to increase the turnover threshold for Composition taxpayers from ₹ 50 lakh to ₹ 75 lakh in his State. Shri Y. Mhathung Murry, Commissioner of Taxes, Nagaland, Shri Hrisheekesh Modak, Commissioner (Commercial Taxes), Manipur, Ms. Dipa Basnet, Secretary (Commercial Taxes), Sikkim and the Principal Secretary (Finance), Tripura also expressed to increase the turnover threshold for Composition taxpayers from ₹ 50 lakh to ₹ 75 lakh in their respective States. The Hon'ble Chairperson suggested that the Council may agree with the proposal to increase the aggregate annual turnover threshold for eligibility for Composition scheme from ₹ 75 lakh to Rs. one crore for normal States and for the two Special Category States, namely Jammu Kashmir and Uttarakhand. The Council agreed to the suggestion. He further suggested to increase the aggregate annual turnover threshold under Composition scheme for Special Category States other than Jammu Kashmir and Uttarakhand from ₹ 50 lakh to ₹ 75 lakh. He also suggested that the issue regarding excluding the turnover ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etary (Finance), Tripura also supported this view. The Hon'ble Minister from Mizoram pointed out that the present agenda was only in respect of increasing the turnover threshold for Composition scheme and not to relax the provision of Section 10(2)(c) of the CGST/SGST Acts, 2017, which prohibited Composition taxpayers to make inter-State outward supplies. The Hon'ble Minister from Assam stated that the North Eastern States would lose revenue if benefit of Composition scheme was extended to inter-State supply of goods as these States mostly got goods from the neighbouring bigger States like West Bengal and there was hardly any reverse supply from the North-Eastern States to the bigger neighbouring States. He stated that if such a provision was introduced in the law, there should be a provision for its review after five years once the scheme of compensation to the States for loss of revenue came to an end. 15.10. Shri Ritvik Pandey, CCT, Karnataka stated that for supplies made by a normal tax payer, under destination principle, the tax travels to the consuming State when input tax credit is utilised by the seller. For Composition tax payers, as tax was not on supplies but ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion dealers should be ₹ 5 lakh. He also suggested to collect tax on maximum retail price (MRP) in some sectors like telecommunication where taxing supply of vouchers at each stage was bringing an additional 25 to 30 lakh people with small turnover in the tax net. The Advisor (Finance), Government of Punjab pointed out that the definition of aggregate turnover in Section 2(6) of the CGST/SGST Acts included all taxable supplies but excluded CGST, SGST, etc. He stated that this exclusion did not cover the earlier tax like VAT and as a result, the aggregate turnover of Composition taxpayers in the first year would be inclusive of VAT and as a result, their de facto turnover for benefit of Composition scheme in the first year would continue to be ₹ 75 lakh (even when it is increased to Rs. one crore) in the first year. He suggested to clarify this issue. 15.13. The Hon'ble Deputy Chief Minister of Bihar stated that entities in the MSME (Micro Small and Medium Enterprises) sector availing the Composition scheme also made supplies to registered entities and there should be a provision that the registered buyers should be able to take input tax credit of the purchases ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hon'ble Minister from Assam supported this proposal and stated that people had developed a negative impression of GST because of mention of separate rates for CGST and SGST. The Hon'ble Minister from Jammu Kashmir stated that the requirement of declaring MRP and the GST were two different systems and it would not be possible to reconcile GST with MRP. He stated that MRP belonged to the pre-GST regime and that the margin of distributors etc. was taken into account while fixing the MRP. He observed that GST applied at every level of the retail chain and the perception problem was because a tax of, say 18%, was being charged on MRP. He suggested that the system of MRP should be abolished in the GST regime. He added that another concern of the taxpayers was the fear of retrospective inquiry regarding their turnover in the pre-GST period and suggested that the Council should clarify that retrospective tax inquiry relating to returns filed during -the pre-GST period shall not be initiated by the Central or State tax administration merely on the basis of returns filed during the GST period. The Hon'ble Chairperson supported this suggestion. The Council agreed to this sugges ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be discontinued. The Hon'ble Chairperson stated that data of tax on restaurants could be evaluated before having a relook at the rate of tax on restaurants. The Hon'ble Minister from Karnataka stated that perception about GST was important and for a restaurant having air conditioned and non-air-conditioned portion, tax should be charged at the rate of 18% if the bill was raised from the air-conditioned part of the restaurant and 12% if the bill was raised from the non-air-conditioned part of the restaurant. He stated that this change would generate a lot of good will for GST amongst the consumers. The Hon'ble Minister from Goa stated that this meeting should send a message that the Council cared for the common people. The Hon'ble Ministers from Tamil Nadu and Odisha supported the proposal made by the Hon'ble Ministers from Kerala and Goa. The Hon'ble Chairperson suggested that the proposed Group of Ministers tasked to look into the Composition issue~ could also examine the rate of tax on restaurants. He stated that a uniform rate of tax of 12% with input tax credit could cause revenue loss because aerated drinks attracted tax at the rate of 43% and this coul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ven to small taxpayers to file monthly return; (ii) lTC on purchases from such taxpayers may be permitted monthly; (iii) GSTR-3B may continue to be filed by all taxpayers for the month of December, 2017 as announced earlier; (iv) Cycle for July, 2017 returns may be completed by all taxpayers (including those taxpayers having an annual turnover of up to ₹ 1.5 crore in the previous year) as announced earlier; (v) Dates for August and September, 2017 Return filing may be announced after seeing experience from July cycle; (vi) Quarterly returns for small taxpayers may start from quarter starting October, 2017; (vii) Last date for filing of GSTR-4 for the first quarter may be 15 November, 2017; (viii) Last date for filing of GSTR-6 for July, August and September, 2017 may also be 15 November, 2017. He stated that this would help GSTN and all other partners to make necessary changes in software. He added that GSTN had informed that FORM GSTR-4 and GSTR-6 would be available by 03 November, 2017 and 23 October, 2017 respectively. 16.2. The Hon'ble Minister from Chhattisgarh supported this proposal and suggested to further enhance the value of turnover of taxpayers eligible to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ly return with monthly payment of tax and taxpayers with turnover above ₹ 5 crore should file monthly return. The Hon'ble Chairperson observed that, as stated by the Hon'ble Minister from Jammu Kashmir, it would not be advisable to make too many categories of taxpayers for compliance. 16.3. The Hon'ble Chief Minister of Puducherry stated that the small taxpayers were finding the return filing to be highly cumbersome and they were forced to employ a person permanently to submit return. He supported the proposal of filing quarterly return by small taxpayers but suggested that payment of tax should be done on monthly basis so that the small taxpayer did not keep the tax collected from the buyer with himself for three months. The Hon'ble Minister from Telangana supported the proposal. The Hon'ble Minister from Madhya Pradesh supported the proposal of fi ling quarterly return for taxpayers with turnover up to ₹ 1.5 crore per annum and suggested that this could be implemented from 1 October, 2017. The Senior Joint Commissioner (Commercial Taxes), West Bengal supported the proposal of filing quarterly return for taxpayers with turnover up to Rs.l.5 cro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... software would take between 8 to 1 0 weeks to implement. The Secretary observed that the changes might not be major and only change of dates were to be made in the software. The Chairman, GSTN, suggested that staggered dates for different categories of taxpayers should be prescribed for filing ofGSTR-1, GSTR-2 and GSTR-3. The Secretary stated that the Law Committee could examine this suggestion. The Council agreed to this suggestion. Agenda item 6(iii): Proposal for suspension of application of provisions of sub-section (4) of section 9 till 31 March, 2018 17. The Commissioner (GST Policy), CBEC stated that this agenda item proposed suspension of application of provisions of sub-section ( 4) of Section 9 till 31 March, 2018. He added that in the meeting of the officers held on 5 October 2017, it was felt that this would also be required for section 5(4) of the IGST Act. He explained that the provision had virtually eliminated the exemption limit provided to the small taxpayers and increased compliance for larger taxpayers. He added that establishments making small quantity of taxable supplies but substantial quantity of exempt supplies (e.g. educational and religious insti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ransaction. He supported the proposal to suspend this provision as a temporary measure. The Hon'ble Minister from Telangana also supported a temporary suspension of reverse charge mechanism. 17 .2. The Advisor (Finance), Government of Punjab, stated that reverse charge mechanism had certainty of levy for goods but its applicability was uncertain in many cases in the services sector. He gave an example of an unregistered person providing free software to a registered recipient on the condition that the recipient would not share it with anyone else. This amounted to agreeing to not doing something which was also a supply of service by the unregistered person to the registered person making the latter liable to tax under reverse charge mechanism. He stated that because of such uncertainties, large taxpayers were shy of making purchases from smaller taxpayers. The Senior Joint Commissioner (Commercial Taxes), West Bengal recalled that originally, the reverse charge mechanism under Section 9(4) of the CGST/SGST Acts, 2017 was meant only for Composition taxpayers buying from unregistered persons but the Council took a considered decision to apply it to all taxable persons. He p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... em as this could lead to different types of problems and would become like check posts. The Hon'ble Minister from Kerala stated that e-Way bill system was very important and delay in its implementation was very unfortunate. He stated that as software had already been developed by NIC in Karnataka and its implementation was held up due to procurement of hardware, those States could start implementation that already had the requisite hardware. The Hon'ble Chief Minister of Puducherry stated that e-Way bill should be implemented at the earliest possible. The Commissioner (Commercial Taxes), Manipur also stated that the e-Way bill should be implemented at an early date. The Hon'ble Minister from Madhya Pradesh stated that e-Way bill should be implemented after the software was developed. The Hon'ble Minister from Punjab suggested that the e-Way bill should be implemented from 1 April, 2018 on goods which are prone to evasion. The Senior Joint Commissioner (Commercial Taxes), West Bengal, stated that e-Way bill system should not be introduced until the existing glitches in the System relating to registration, return and payment were successfully addressed. The Hon'bl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... EO, GSTN stated that the hardware for the e-Way bill system was expected by the end of October, 2017 and the earliest that they could implement e-Way bill system was from 1 December, 2017. He suggested to introduce the e-Way bill system from 1 January, 2018 after a month of beta testing. The Hon'ble Minister from Karnataka suggested to roll out e-Way bill system from one State, and then scale it up to 4-5 States by 1 November, 2017. 18.4. The Hon'ble Chairperson suggested that e-Way bill system could be rolled out from 1 January, 2018 in a staggered manner in State after State and could be implemented across the country from 1 April, 2018. The Council agreed to this suggestion. 19. For agenda item 6, the Council took the following decisions: (i) To increase the aggregate annual turnover threshold for eligibility under the Composition scheme from ₹ 75 lakh to Rs. one crore for normal States and for two Special Category States, namely Jammu Kashmir and Uttarakhand; (ii) To increase the aggregate annual turnover threshold for eligibility under the Composition scheme from ₹ 50 lakh to ₹ 75 1akh for Special Category States other than Jammu Kashm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mine the possibility of prescribing staggered dates for filing GSTR-1 , GSTR-2 and GSTR-3 for different categories of taxpayers; (vii) To suspend the application of reverse charge mechanism under Section 9(4) of the CGST/SGST Acts, 2017 and Section 5(4) of the IGST Act, 2017 till 31 March, 2018 for all categories of registered persons including Composition taxpayers and during this period, the scheme shall be reviewed by the new Law Review Committee constituted to review the changes required in the Jaw; (viii) To roll out e-Way bill system from 1 January, 2018 in a staggered manner in State after State and to implement it across the country from 1 April, 2018; (ix) To make similar changes in SGST Act and UTGST Act, wherever required. Agenda item 7: Issues recommended by the Fitment Committee for consideration of the GST Council Agenda item 7(i): GST Rate in respect of government works contract services having high labour content 20. Introducing this agenda item, Shri Amitabh Kumar, Joint Secretary (TRU-ll), CBEC, stated that some States had requested to levy tax at the rate of 5% on those works contracts which had predominantly labour component and the mater ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... able to Government Entity. 20.1. Initiating the discussion, the Hon'ble Minister from Madhya Pradesh suggested that high labour content should be defined where the material component was less than 33%. The Hon'ble Minister from Jammu Kashmir stated that if material component was kept at 25% and even if these attracted tax at the rate of 28%, there would be no outgo of refund but increasing the material component to 33% would lead to a situation of refund. The Secretary stated that this issue had been carefully considered by the Fitment Committee and the Council should go by its recommendation. 20.2. After discussion, the Council agreed that the rate of tax in case of works contract services involving predominantly earth works (that is, constituting more than 75% of the value of the works contract) supplied to the Central Government, State Governments, Iocal authority or a governmental authority shall be reduced to 5%. In view of decision in respect of agenda item 7(ii), this reduced rate on works contract service would also apply to Government Entity. Agenda item 7(ii): Definition of Governmental Authority and GST on Government Grants 21. Introducing this a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rate) dated 28.06.2017, and that the corresponding Service Tax exemption (Notification No. 25/2012-ST, Sl. No. 60 dated 20.06.2012) covered services provided by Central Government, State Government, Union territory, local authority as well as governmental authority. He informed that the Law Committee had recommended to modify the Entry at Sl. No. 5 of Notification No. 12/2017-CT (Rate) dated 28.06.2017. and corresponding IGST, UTGST and SGST notifications accordingly. 21.2. He stated that an incidental amendment connected with reduction in GST rate on specified works contract services was required to be carried out in paragraph 2 of notification No. 11/2017-CT dated 28.06.2017 and corresponding IGST, UTGST and SGST notifications. He explained that the said paragraph provides that In case of supply of service specified in column (3) of the entry at item (i) against serial no. 3 of the Table above involving transfer of property in land or undivided share of land, as the case may be, the value of supply of service and goods portion in such supply shall be equivalent to the total amount charged for such supply less the value of land or undivided share of land, as the case may be, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... per the proposal received from the Government of Gujarat, the State Government had set up various Boards/Corporations/Societies/ Institutes to implement various schemes of the Government and to carry out functions on its behalf, such as Gujarat Medical Services Corporation Limited (GMSCL), Gujarat Rural Industries Marketing Corporation (GRIMCO), Gujarat Municipal Finance Board (GMFB) etc. Government provided budgetary grants to these entities which in tum carried out allotted functions using these grants and it could be argued that the transfer was not solely a transfer of money as Government was expecting the entity to perform certain activities on its behalf, particularly keeping in view the fact that business was defined in very broad terms in Section 2(17) of the CGST/SGST Acts. He stated that the recommendations of the Law Committee could be accepted with certain modifications as highlighted in bold letters below: (a) Grants given by Central Government, State Government or a local authority to a Government Entity may be exempt under GST. Government Entity may be defined as an authority or a board or any other body including a society, trust, corporation which is, - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ding IGST, UTGST and SGST notifications as under: For the purposes of this notification, the expression Governmental Authority means an Authority or a Board or any other body (i) set up by an Act of Parliament or a State Legislature or (ii) established by any Government, with 90% or more participation by way of equity or control, to carry out any function entrusted to a municipality under Article 243 W of the Constitution or to a Panchayat under Article 243 G of the Constitution . (ii) The same definition to be also included in the notification No.11/2017-CT dated 28.06.2017 and corresponding IGST, UTGST and SGST notifications which, as amended by notification No. 20/2017-CT dated 22.08.2017, prescribes GST rate of 12% on certain works contract services provided to Governmental Authority. (iii) Entry at Sl. No.5 of notification No. 12/2017-CT (Rate) dated 28.06.2017 may be amended along the lines of entry at Sl. No. 4 to include services provided by Central Government, State Government, Union Territory and local authority in addition to those provided by governmental authority. Corresponding IGST, UTGST and SGST notifications may also be amended. (iv) Provision in p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etary (TRU-ll), CBEC, suggested the following formulation for exemption: 'Supply of service or goods by a Government Entity to Central Government, State Government, Union territory, local authority or any person specified by Central Government, State Government, Union Territory or local authority against consideration received from Central Government, State Government, Union Territory, or local authority, in the form of grants.' The Hon'ble Minister from Karnataka stated that his State had set up SPVs which might not be covered under exemption. The Joint Secretary (TRU-ll), CBEC, explained that this would be covered under the definition of 'Government Entity'. The Hon'ble Minister from Jharkhand stated that where a works contract had been entered in April, 2017 (i.e. before GST) but the bill was raised in October, 2017 (i.e. after GST), the contractor was not in a position to pay tax at the new rate of 12% when his profit was only around 9%. The Secretary stated that such contracts would need to be renegotiated taking into account the new tax liability and that a Committee of officers could be constituted for the same. The Hon'ble Minister from Punjab su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cars where the incidence of cess was 1 %-3%. He, therefore, suggested the alternative that the rate of GST for old leases could be 65% of the applicable GST rate and Compensation Cess. He stated that this approach would make the additional tax incidence on smaller cars (below 1200 cc and less than 4 metre) lower as compared to bigger cars (greater than 1500 cc). He stated that as per this proposal, leasing for small cars (LPG/CNG/Petrol) would attract tax at the rate of 18.85% as against the present 29% and the combined pre-GST incidence of VAT and Service Tax at the rate of 17% ( 14.5% + 2.5%). He added that leasing of diesel cars (below 1500 cc) would attract tax at the rate of 20.15% as against the present 31% and cars with engine capacity of more than 1500 cc would attract tax at the rate of 31.2% as against the present 48%. He stated that it was also proposed that the vehicles covered by such leases (i.e. leases of vehicles purchased and leased prior to I July, 2017 and registered as commercial vehicles prior to that date or within 15 days of leasing), when disposed of/sold shall also be taxed at 65% of the applicable GST plus Cess rate. 22. I. He further stated that the F ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this agenda item. The Hon'ble Minister from Karnataka stated that there would be double benefit under VAT for those who had earlier taken credit of VAT, as they would also be given the benefit of reduced tax rate. The Secretary stated that it would not be practical to separate the tax rate for the Centre and the States. The Hon'ble Minister from Karnataka suggested that Central Excise credit could be extended for such lease agreement. The Joint Secretary (TRU-ll), CBEC, stated that the time period for availing the credit of Central Excise Duty had lapsed. After further discussion, the Council approved the proposal made at paragraph 22.2 above. Agenda item 7(iv): GST on renting of motor cab and transport of passengers by motor cab services 23. Introducing this agenda item, the Joint Secretary (TRU-1), CBEC, stated that presently under Notification No.ll /2017-Central Tax(Rate) dated 28 June, 2017, the rate of tax for transport of passengers by motor cab, where the cost of fuel was included in the consideration charged for the services from the recipient, was 5% without input tax credit (lTC) of goods and services and 12% with full lTC. Similarly, for renting of mot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3.3. After discussion, the Council agreed to the following proposals: (i) To apply rate of tax of 5% without input tax credit and 12% with input tax credit as presently applied for transport of passengers by motor cab or for renting of motor cab to service provided by using any other motor vehicle designed to carry passengers; (ii) To allow input tax credit for input service in the same line of business i.e. from another service provider of transporting passengers in any motor vehicle or renting a motor vehicle, at the rate of tax of 5%; (iii) To allow input tax credit for renting any motor vehicle or transport of passengers by motor vehicles to a person who supplied either of the service - renting of any motor vehicle or transport of passengers by motor vehicles. Agenda item 7(v): Reduction in rate of tax on some Job Work Services 24. Introducing this agenda item, the Joint Secretary (TRU-ll), CBEC, stated that representations had been received from various quarters to reduce the rate of tax on job work in certain services or to rationalise the rates of tax for different types of job work in the same sector like printing industry. 24.1. He stated that there wa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re also received from job workers in packing of processed milk into packets to reduce the rate of tax on job work from 18% to Nil. He further stated that representations had also been received from job workers in clay bricks manufacturing to reduce the tax rate from 18% to 5%. 24.3. He informed that the issue of having the same rate of tax on job work services in relation to any goods as that on the (same) goods concerned, was discussed but was not found acceptable because this would lead to large scale classification disputes in job work services and potential differential in rate of tax on job work services for intermediate goods and final goods thus leading to problem of lobbying. He stated that the following rates were proposed by the Fitment Committee: (i) To prescribe a rate of 5% on job work services in relation to food and food products falling under Chapters1 to 22 of the HS Code; (ii) To prescribe a rate of 5% on job work services in relation to products falling under Chapter 23 of the HS code except for dog and cat food put up for retail sale (Chapter Heading 2309 1000); (iii) To reduce the rate of tax on job work services in relation to manufacturing of umbr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der Chapters 48 and 49, which attract GST at the rate of 5% or Nil may be prescribed at 5%. (Heading 9988); (b) GST rate on services by way of printing on job work basis or on goods belonging to others in relation to printing of all goods falling under Chapter 48 and 49, which attract GST at the rate of 12% may be prescribed at 12% (Heading 9988); (c) GST rate on services by way of printing on job work basis or on goods belonging to others in relation to printing of goods falling under Chapter 48 and 49, other than those covered by (a) and (b) above, may continue at 18% (Heading 9988); (d) GST rate on services by way of printing in relation to printing of all goods falling under Chapter 48 and 49, which attract GST at the rate of 5% or Nil, where only content is supplied by the publisher and the physical inputs including paper used for printing belong to the printer may be prescribed at 12% [(Heading 9989), item (i) may be amended accordingly]. [It would not result in ITC overflow as most of the paper, paperboard attracts GST at the rate of 12%. It would also not result in any tax disadvantage to the printer because a recipient of such supply having in-house printing would ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 24.6. The Joint Secretary, (TRU-ll), CBEC, further stated that the hand-made carpet industry of Uttar Pradesh had represented that in pre-GST period, there was no Central Excise Duty on carpets but post-GST, there was 12% rate of tax on carpets and 5% on job work relating to manufacturing of carpets. The industry had pointed out that there were 23 processes involved in making of carpets, namely, spinning, weaving, washing and finishing activities, which were done by job workers and they were mostly poor, unorganized, illiterate and home based and it would not be possible for them to comply with GST law. Therefore, hand-made carpet exporters would not be able to claim refund of GST paid on inputs and services which would lead to increased cost and make Indian products globally uncompetitive. He pointed out that the entire textile sector had been exempt from Excise Duty when input tax credit was not availed and under GST, all textiles, whether hand-made or machine-made, were charged to tax at the rate of 5% or 12%. The job works services in relation to textile items attracted 5% tax while it was exempted under Service Tax regime and this 5% GST on jobwork was being agitated by the h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iesel was not available and that the case was similar to that of transportation of natural gas through pipeline as no input tax credit of tax paid on the same could be availed because natural gas was outside the purview of GST. 25.3. He stated that in view of above, there was justification to reduce the rate of tax on transportation of natural gas through pipeline from 18% to 12% with input tax credit and to give an option to tax the same at the rate of 5% without input tax credit. He further pointed out that input tax credit on pipeline was not admissible under GST law as it amounted to immovable property under Section 17 of the CGST/SGST Acts, 2017. In view of the above, he proposed the following: (i) GST be levied at the rate of 12% on works contract services and associated services in respect of E P (Exploration and Production Companies) in respect of offshore works in the area beyond 12 nautical miles; (ii) GST be levied at the rate of 12% with lTC OR 5% without ITC for transportation of natural gas through pipeline. 25.4. The CCT, Karnataka suggested that the option of 5% rate of tax might not be given. The Secretary stated that as there was no GST on output, to p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... int Secretary (TRU-1), CBEC, stated that the Council, in its 21st Meeting held on 9 September, 2017 had recommended that in respect of 5% rate of tax on cereals, pulses and flours, etc. put up in unit containers and bearing a registered brand name, the following amendments may be made to the existing Notifications, so as to provide that: (i) A brand registered as on 15.05.2017 shall be deemed to be a registered brand for the purposes of levy of 5% GST, irrespective of whether or not such brand is subsequently deregistered; (ii) A brand registered as on 15.05.2017 under the Copyright Act, 1957 shall also be treated as a registered brand for the purposes of levy of 5% GST; (iii) A brand registered as on 15.05.2017 under any Jaw for the time being in force in any other country shall also be deemed to be a registered brand for the purposes of levy of 5% GST; and (iv) A mark or name in respect of which actionable claim is available shall be deemed to be a registered brand name for the purposes of levy of 5% GST. 27.1. He stated that accordingly, Notifications No. 27/20 17-Central Tax (Rate), 28/2017- Central Tax (Rate), 27/2017-Integrated Tax (Rate), 28/2017-Integrated Tax (Rate), 27 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 27.5. He stated that in view of this, the aforesaid notifications were being placed before the Council for ratification. The Council agreed to the proposal and ratified the notifications. 27.6. The Joint Secretary (TRU-1 ), CBEC further stated that it is possible that the person having actionable claim or enforceable right on a brand name and the person undertaking packing of such goods in unit containers are two different persons and in such cases, it would be necessary to provide that the affidavit (as mentioned in paragraph 27.3 above) is filed by the person having actionable claim or enforceable right on such brand name and he shall state the following in the affidavit: (a) He is voluntarily foregoing his actionable claim or enforceable right on such brand name, and (b) He has authorised the person (undertaking packing of such goods in unit containers bearing said brand name) to print on such unit containers in indelible ink, both in English and the local language, that in respect of such brand name, he (the person owning the brand name) is voluntarily foregoing the actionable claim or enforceable right on such brand name. 27.7. He requested the Council to approve the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... able to keep tax at the rate of 5% because there would be tax on inputs like ghee, transport, rent, etc. which could be used for paying tax at the rate of 5%. The Council agreed to the recommendation of the Fitment Committee to tax the food preparations put up in unit containers and intended for free distribution to economically weaker sections of the society under a programme duly approved by the Central Government or any State Government at the rate of 5% subject to the condition as mentioned in the paragraph 28.1. 28.3. All goods falling under heading 6802 (other than those of marble and granite or those which attract 12% GST)(SI. No. 2): The Fitment Committee had recommended that tax on all goods falling under Heading 6802 (except those of marble and granite or those which attract 12% GST) should be reduced from 28% to 18%. However, Statues, statuettes, pedestals; high or low reliefs, crosses, figures of animals, bowls, vases, cups, cachou boxes, writing sets, ashtrays, paper weights, artificial fruit and foliage, etc.; other ornamental goods essentially of stone, falling under 6802, should continue to attract 12% GST. 28.4. The Hon'ble Minister from West Bengal state ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to pay tax on the whole quantity of SKO supplied to LAB manufacturer, then refineries would have to reverse a large portion of such credit as the majority of their final products were outside GST. Keeping in view this recommendation, the Council approved the proposal to issue a clarification stating that in such cases, GST will be payable only on the net quantity of superior kerosene oil (SKO) retained for the manufacture of Linear Alkyl Benzene (LAB). 28.7. Staple pin (SI. No. 10): Shri P.K. Mohanty, Consultant (GST), CBEC, suggested to rationalise tax on all items falling under Chapter Heading 8305 and to subject them to a uniform rate of tax of 18%. The Council agreed to this suggestion. 28.8. Parts of (a) fixed speed diesel engine of power not exceeding 15 HP, and (b) submersible pumps: The Hon'ble Deputy Chief Minister of Gujarat stated that a view needed to be taken regarding the rate of tax on these items. The Secretary stated that these items were covered under Agenda item 13(iii) circulated in the morning and could be discussed when that agenda item came up for discussion. 28.9. Real zari (not listed): The CCT, Gujarat suggested to reduce the rate of tax on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Governmental Authority 29.2. To amend the definition of Governmental authority in notification 12/2017-CT and corresponding IGST, UTGST and SGST notifications as under: For the purposes of this notification, the expression Governmental Authority means an Authority or a Board or any other body (i) set up by an Act of Parliament or a State Legislature or (ii) established by any Government, with 90% or more participation by way of equity or control, to carry out any function entrusted to a municipality under Article 243 W of the Constitution or to a Panchayat under Article 243 G of the Constitution. 29.3. The definition of Governmental Authority at paragraph 29.2 above to be also included in the notification No.1/2017-CT dated 28.06.2017 and corresponding IGST, UTGST and SGST notifications which, as amended by notification No. 20/2017-CT dated 22.08.2017, prescribes GST rate of 12% on certain works contract services provided to Governmental Authority. 29.4. Entry at Sl. No. 5 of notification No. 12/2017-CT (Rate) dated 28.06.2017 to be amended along the lines of entry at Sl. No. 4 to include services provided by Central Government, State Government, Union Territory an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... harge mechanism on sale of used /seized vehicles, scrap etc by Government Departments 29.9. Leasing of vehicles purchased and leased prior to 1 July 2017, to be taxed at 65% of the applicable GST plus Cess rate. This reduced rate shall be applicable for a period of 3 years with effect from 1 July 2017. 29.10. The vehicles covered by the above leases (i.e. leases of vehicles purchased and leased prior to I July 20 17), when disposed of/sold shall also be taxed at 65% of the applicable GST plus Cess rate. This reduced rate shall be applicable for a period of 3 years with effect from 1 July 2017. 29.11. Sale/supply of vehicles by a registered person, who had procured the vehicle prior to I July 2017 and has not availed input tax credit of Central Excise duty, VAT or any other taxes paid on such vehicles, to be taxed at 65% of the applicable GST plus Cess rate. This reduced rate shall be applicable for a period of3 years with effect from 1 July 2017; 29.12. Sale by way of auction etc. of used vehicles, seized and confiscated goods, scrap etc. by Central Government, State Government, Union Territory or a local authority, to any person, shall be subjected to GST under reverse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Chapter 48 and 49, other than those covered by paragraphs 29.21 and 29.22 above shall continue at 18% (Heading 9988). 29. 24. Rate of tax on services by way of printing in relation to printing of all goods falling under Chapters 48 and 49, which attract tax at the rate of 5% or Nil, where only content is supplied by the publisher and the physical inputs including paper used for printing belong to the printer shall be reduced from 18% to 12% (Heading 9989). 29.25. Rate of tax on services by way of printing of all goods falling under chapter 48 and 49 which attract tax at the rate of 12%, where only content is supplied by the publisher and the physical inputs including paper used for printing belong to the printer shall be reduced from 18% to 12%. 29.26. Rate of tax on services by way of printing of all goods falling under chapter 48 and 49 which attract tax at the rate of 18% or above, where only content is supplied by the publisher and the physical inputs including paper used for printing belong to the printer, shall continue to be at 18%. 29.27. To issue a clarification that the supply of books, pamphlets, brochures, envelopes, cartons, boxes etc. printed with logo, de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 5(3) of the IGST Act. (viii) Amendment in GST notifications in respect of 5% GST rates on cereals, pulses and flours, etc. put up in unit container and bearing a brand name 29.31. To ratify the notifications no.27/2017-Central Tax (Rate), 28/2017-Central Tax (Rate), 27/2017-Integrated Tax (Rate), 28/2017-Integrated Tax (Rate), 27/2017-Union Territory Tax (Rate), 28/2017 -Union Territory Tax (Rate) including the drafting changes made therein while implementing the decision of the Council taken during its 21 st Meeting held on 9 September 20 17 relating to rate of tax on cereals, pulses and flours etc. put up in unit container and bearing a registered brand name. 29.32. Where the person having actionable claim or enforceable right on a brand name and the person undertaking packing of such goods in unit containers are two different persons, it shall be necessary for the person having actionable claim or enforceable right on such brand name to file an affidavit (as mentioned in paragraph 27.3 above) stating the following: (a) He is voluntarily foregoing his actionable claim or enforceable right on such brand name, and (b) He has authorised the person (undertaking packing of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o provide that in case of B2C supplies, the cumulative value of goods or services or both liable to tax at a particular rate and total tax thereon on all such goods or services or both can be shown as a single entry instead of indicating rate of tax against each item. He stated that another proposal made by the Law Committee on the basis of representation from trade and industry was that a supplier may issue a single tax invoice cum- bill of supply where the supplies to an unregistered recipient include both taxable as well as exempt goods or services. He stated that another recommendation of the Law Committee was that keeping in view the large number of invoices issued by banking and insurance companies, sub-rule (2) of Rule 54 of CGST Rules, 2017 could be amended to provide for issuance of a consolidated invoice or another document for supply of services in a particular month. He stated that another proposal was to amend instructions for filing return in FORM GSTR-4 so as to provide that serial No.4 A of Table 4 shall not be furnished for July 2017 to December 2017. 31.1. The Hon'ble Minister from West Bengal in his written comments supported the proposal to allow issuan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5.09.2017 and Notification No.08/2017- Integrated Tax dated 14.09.2017. He stated that in view of the request from the State of Jammu Kashmir, the Law Committee recommended to add the following additional items in the abovementioned notifications: (i) Handmade shawls, stoles and scarves (may be added to Sl.no. 9 of the table in the notification, along with addition of Chapter 61 ); (ii) Chain stitch; (iii) Crewel, namda, gabba; (iv) Wicker willow products; (v) Toran; (vi) Articles made of shola. 32.1. The CCT, Gujarat stated that some more items, namely Terracotta figurines of the Gora Dev (tribal horse God); Plaques, inset with mirrors; Handmade blocks for fabric printing should also be added to the list. The Secretary stated that these additional items should first be discussed in the Fitment Committee. The Council approved the proposal made under this Agenda item. Agenda item 8(iv): Clarification regarding the due dates for the generation of FORM GSTR-2A and FORM GSTR-1A for the month of July, 2017 33. The Commissioner (GST Policy), CBEC stated that under Notification No.30/20 17 dated 11 September, 2017, dates for filing FORM GSTR-1, FORM GSTR-2 and FORM GSTR-3 fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s to an unregistered recipient include both taxable as well as exempt goods or services. 34.4. To amend sub-rule (2) of Rule 54 of CGST Rules, 2017 to provide that banking and insurance companies to issue a consolidated invoice or another document for supply of services in a particular month. 34.5. To amend instructions for filing return in FORM GSTR-4 so as to provide that serial No.4A of Table 4 shall not be furnished for July 2017 to December 2017. (iii) Inclusion of additional items in Notifications No. 32/2017-Central Tax and No. 8/2017-Integrated Tax 34.6. To add the following additional items in the Notifications No. 32/20 17-Central Tax dated 15.09.2017 and No. 08/2017-lntegrated Tax dated 14.09.2017: (i) Handmade shawls, stoles and scarves (to be added to Sl. No. 9 of the table in the notification, along with addition of Chapter 61 ); (ii) Chain stitch; (iii) Crewel, namda, gabba; (iv) Wicker willow products; (v) Toran; (vi) Articles made of shola. iv. Clarification regarding the due dates for the generation of FORM GSTR-2A and FORM GSTR-lA for the month of July, 2017 34.7. A circular to be issued by the Central Government and the State Governments ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e IGST Act. 35.1. The CCT, Karnataka stated that the Council could also take a decision that till the division of taxpayers was effected between the Central administration and the State administrations, an officer of the Central and the State Government was authorised to process any refund claim filed by an applicant under his jurisdiction. The Secretary stated that division of taxpayers was likely to be done soon. The CCT, Karnataka stated that a lot of ground work was still required to be done and data such as turnover details of migrated taxpayers, removing from it the data of turnover of taxpayers with centralised registration, etc. would take time and for such period, a taxpayer should be given the freedom to approach any tax administration for claiming refund. The Secretary stated that this could be permitted subject to a declaration being given by the applicant that the same refund claim has not been claimed from the other administration having jurisdiction over the applicant. The Council agreed to this suggestion. 36. For agenda item 9 , the Council approved the following: (i) To issue notifications by the Central Government and the State Governments, cross empowe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... GST Act, CGST Rules [Notification Nos. I to 37 for Central Tax and Notifications Nos. 1 to 30 for Central Tax (Rate)]; IGST Act [Notification Nos. I to 8 for Integrated Tax and Notification Nos. 1 to 31 for Integrated Tax (Rate)]; UT GST Act [Notification Nos. I to 3 for Union Territory Tax and Notification Nos. I to 30 for Union Territory Tax (Rate)]; GST (Compensation to States) Act [Notification No. 1 for Compensation Cess Notification and Notification Nos. 1 to 5 for Compensation Cess (Rate)] and Order No. 3 dated 21.09.2017 of the Central Government for their ratification. The Council ratified these notifications and Order No. 3 dated 21.09.2017 as mentioned above on deemed basis. 38. For agenda item 10, the Council ratified Notification Nos. 1 to 37 for Central Tax and Notifications Nos. 1 to 30 for Central Tax (Rate); Notification Nos. 1 to 8 for Integrated Tax and Notification Nos. 1 to 31 for Integrated Tax (Rate); Notification Nos. 1 to 3 for Union Territory Tax and Notification Nos. 1 to 30 for Union Territory Tax (Rate); Notification No. 1 for Compensation Cess Notification and Notification Nos. 1 to 5 for Compensation Cess (Rate) and Order No. 3 dated 21.09.2017 iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Kashmir suggested that the decisions of GIC should be placed before the Council for confirmation. The Secretary stated that the decisions of the GIC should come before the Council in its Meeting for information only as these would have been implemented by issuance of necessary notification, circular, etc. with the approval of the Hon'ble Union Finance Minister and the Chairperson of the Council. The Council approved this proposal. 40. For agenda item 11 , the Council approved to modify the procedure of GIC for important and urgent procedural issues. In cases involving important and urgent procedural issues, approval accorded by the GIC shall be implemented with the approval of the Hon'ble Union Finance Minister and the Chairperson of the GST Council and it shall be circulated to the States for information and the decisions taken by the GIC would be put up for information of the Council in its next Meeting. However, procedure as originally approved by the Council in its 17 th Meeting held on 18 June 2017 shall apply for normal GIC matters. Further, as decided by the Council in its 21 st Meeting held on 9 September 2017, recommendations of the GIC, involving substant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 5(4) of the GST (Compensation to States) Act, 2017 44. Introducing this agenda item, the Joint Secretary, Department of Revenue stated that in the 21 51 meeting of the Council held on 9 September, 2017, some States had mentioned that some Acts listed in the draft notification to be issued under Section 5(4) and 5(6) of the Goods and Services Tax (Compensation to States) Act 2017 had not been repealed entirely and also some Acts which were missing had to be added. He informed that the States were accordingly requested to send a formal request for suitably revising the said draft notification and that a total of 12 States viz., Andhra Pradesh, Delhi, Goa, Himachal Pradesh, Maharashtra, Odisha, Rajasthan, Telangana, Tripura, Uttar Pradesh, Uttarakhand and West Bengal sent requests for changes in their list of Acts under which taxes had been subsumed. He further mentioned that the proposed agenda was prepared as per Sections 173 and 174 of the SGST Acts of the concerned States and on the basis of inputs received from the States and was placed before the Council for approval. He further mentioned that a corrigendum to the agenda had been circulated wherein the United Provinces ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... III which was earlier not found acceptable by the Fitment Committee shall be reconsidered by it on the basis of the principles approved by the Council in the Approach Paper (iv) List of Acts from the Central and State Governments as per Section 5(4) of the GST (Compensation to States) Act, 2017 45.4. The draft notification in the agenda note containing the list of Acts subsumed for different States as per Section 5(4) of the GST (Compensation to States) Act, 2017 along with the addition of clause (e) of sub-section (1) of Section 131 of Odisha Municipal Act, 1950 relating to Advertisement Tax and the United Provinces Sales of Motor Spirit Diesel and Alcohol Taxation Act, 1939 of Uttar Pradesh. Agenda item 13: Any other agenda item with the permission of the Chairperson 46. After taking the approval of the Hon'ble Chairperson, some additional agenda items along with detailed agenda notes were circulated in hard copy and by email to the Members before the commencement of the Council Meeting. These are discussed in the subsequent paragraphs. Agenda item 13(i): Exemption from obtaining registration for persons making interState supply of services whose aggregate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stated that the .Council could decide regarding the date from which deduction/collection of tax should start in terms of section 51/52 of the CGST/SGST Acts. He further informed that in the Officers' meeting of 5 October 2017, it was suggested that the deduction/collection of tax could start from 1 April 2018. The Council agreed to this suggestion. Agenda item 13(iii): Changes in GST rates on certain goods and exemption from IGST in certain cases 49. Introducing this agenda item, the Joint Secretary (TRU-1), CBEC stated that the Fitment Committee had met on 5 October 2017 and examined the proposals for change in the rate of tax on certain goods and exemption from IGST on imports of bona fide gifts up to a value limit of ₹ 3000 through post or air and made recommendations to the Council. The record of discussion in respect of the issues raised in the Council is recorded as below: A. Changes in GST rates on certain goods: Serial No.1: IGST exemption on import of gold by nominated agencies (para 4.41 of the FTP) 50. The Secretary informed that the Ministry of Commerce had recommended for exemption from IGST on import of gold by nominated agencies. He ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed out that even the industry had only demanded reduction in rate to 12%. He added that this rate reduction would also address the dichotomy being faced between the integrated units and the power looms. After discussion, the Council agreed to reduce the rate of tax on manmade filament yam, spun yam and sewing thread from 18% to 12%. Serial No.3: All types of Scrap (Plastic scrap; Paper scrap; Rubber scrap and Hard Rubber scrap; Glass scrap; Precious metal scrap and Wood scrap) 52. The Joint Secretary (TRU-1) stated that the Fitment Committee had recommended the rate of tax on various types of scrap which presently attracted tax rates of 18%, 12% and 28% to 5% for Plastic scrap, Paper scrap (Waste paper), Rubber scrap and Glass scrap. The Hon'ble Minister from Kerala stated that the municipalities were paying ₹ 10,000 to ₹ 20,000 per load for removing e-waste such as computers, etc. generated in schools, colleges, etc. and that this should also not be taxed. The Joint Secretary (TRU-1), CBEC, stated that municipal waste, sewage sludge and clinical waste were already exempt from tax and that the Council could take a view regarding rate of tax fore-waste. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e as in the case of branded cereals, pulses and flours etc.) 56. The Joint Secretary (TRU-1), CBEC, stated that the rate of tax on unbranded Ayurvedic, Unani, Siddha, Homeopathy medicines and unbranded namkeens goods was proposed to be reduced from 12% to 5%. The Hon'ble Minister from Kerala stated that classic Ayurvedic preparations should be promoted and there should be no distinction between branded and unbranded ayurvedic medicines. He stated that the products of Kottakal Ayurved Shala, Coimbatore Ayurved Shala, etc. should also be charged to tax at the rate of 5%. The Hon'ble Chairperson stated that if no distinction was made between branded and unbranded Ayurvedic products, products of Dabur/ Patanjali, etc. would also attract reduced rate oftax of 5%. The Finance Secretary, Odisha stated that there was a very large market for over the counter Ayurvedic products and tax rate of 5% only on unbranded Ayurvedic medicines was reasonable. The Council agreed to the proposal. The Joint Secretary (TRU-1), CBEC, stated that tax on unbranded namkeen was proposed to be reduced from 12% to 5%. The Council agreed to the proposal to reduce the rate of tax from 12% to 5% on unb ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt Secretary (TRU-l), CBEC stated that it was proposed to exempt from IGST import of bona fide gifts up to a value limit of ₹ 3000 imported through post or air. The Hon'ble Minister from Kerala stated that earlier the value limit was ₹ 20,000 and that this value limit should be maintained. The Secretary stated that such a high value limit had led to widespread misuse of this scheme leading to loss of revenue. He proposed that the value limit could be increased to ₹ 5,000. The Hon'ble Minister from Jharkhand stated that the value limit should be ₹ 1,000. The Hon'ble Minister from Goa stated that a large number of Non-Resident Indians were sending gifts and value threshold of ₹ 20,000 should be considered even at the risk of some misuse. He stated that genuine transactions should not be punished and that the limit of ₹ 5,000 was very low. The Hon'ble Minister from Kerala enquired as to what was the total amount of tax collected on imported gifts. The Joint Secretary (TRU-I), CBEC stated that field level data was not available as such imports were not yet computerised. He further added that a value limit of ₹ 20,000 would be ve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... He stated that even interest on deposits made in banks is considered as service (though exempted) and therefore a person receiving interest would be ineligible for Composition Scheme. He stated that it was proposed to issue an Order under Section 172 of the CGST/SGST Act (providing for removal of difficulty) to exclude such services from Section 10 as per the following: (i) Section 10(2)(a) of the CGST/SGST Acts to be read so as to exclude the services by way of extending deposits, loans or advances in so far as the consideration is represented by way of interest or discount; (ii) Section 10( 1) of CGST/SGST Acts to be read so as to exclude the interest earned from deposits, loans or advances from the aggregate turnover. He added that in the absence of such an exemption, Composition Scheme would be completely unavailable to manufacturers and dealers who were earning interest from deposits, etc. It was suggested that such dispensation could be provided for all exempt services and need not be restricted to interest or discount only. The Council agreed to the proposal. It was also decided by the Council to issue a removal of difficulty order under Section 172 of the CGST/SGST/UTGST A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t. He stated that the proposal before the Council was to exempt from tax upfront, amount (called as premium, salami, development charges or by any other name) payable in respect of service, by way of granting of long term lease (30 years or more) of industrial plots or plots for development of infrastructure for financial business, provided by the State Government Industrial Development Corporations/Undertakings or any other entity having 50% or more ownership of Central Government, State Government, Union Territory to industrial units or developers in any industrial or financial business area. The Council agreed to this proposal. Agenda item 13(vii): Additional relief to Small Tax Payers - GTA to unregistered persons 64. Introducing this Agenda item, the Joint Secretary (TRU-ll), CBEC, stated that services provided by a GTA attracted tax at the rate of 5% without input tax credit under Reverse Charge Mechanism or 12% with input tax credit under forward charge. He stated that for specified categories of persons, tax on services provided by a GTA operating under 5% GST rate scheme was payable by the recipient of the service under Reverse Charge Mechanism. However, when a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... section 51 and 52 of the CGST/SGST Acts respectively shall start from 1 April 2018. (iii) Changes in GST rates on certain goods and exemption from IGST in certain cases 65.3. The rates of tax proposed under the agenda note with the following modification: (i) rate of tax one-waste (Sl. No.3) shall also be 5%; (ii) IGST on import of bona fide gifts of a value up to ₹ 5,000 per parcel shall be exempt instead of the originally proposed value of ₹ 3,000 per parcel. (iv) Issue of Annuity being given in place of Toll Charges to Developers of Public Infrastructure - exemption thereon 65.4. To exempt from tax, service by way of access to a road or bridge on payment of annuity. (v) Additional relief to Small Tax Payers -Composition Scheme 65.5. To issue an Order under Section 172 of the CGST/SGST/UTGST Acts to the effect that if a person supplies goods and/or services referred to in clause (b) of paragraph 6 of Schedule II of the said Acts and also supplies any exempt services including services by way of extending deposits, loans or advances in so far as the consideration is represented by way of interest or discount, the said person shall not b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect to one single authority and that the single authority should either be the State or the Centre which should administer all the three laws i.e. CGST, SGST and IGST in respect of such taxpayer. He observed that such an arrangement was in consonance with the larger objective of the new tax regime. He did not support the proposal to place restriction on cross-empowerment under the IGST Act in case where place of supply was under dispute. He stated that GIC had requested Tamil Nadu to prepare a draft note on the matter for detailed discussion in the Council and that a detailed note had been prepared and sent to the Council Secretariat for circulation amongst the Members. On the subject of manual refund till GSTN provided an online facility, he supported the proposal but suggested that a standard operating procedure should be put in place before actual implementation of this recommendation. On the subject of increasing the annual turnover threshold under Composition Scheme from ₹ 75 lakh to Rs. one crore; to treat exempt supplies of the aggregate turnover under the Composition Scheme as Nil rated; to allow filing of returns quarterly in respect of taxpayers having turnover up t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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