Improve GSTN Portal: AGFTC & ITBA to Finance Minister Nirmala Sitharaman

The All Gujarat Federation of Tax Consultants (AGFTC) and the Income Tax Bar Association, Ahmedabad (ITBA) — two of Gujarat’s most prominent tax professional bodies — have submitted a comprehensive 25-point representation to Union Finance Minister Smt. Nirmala Sitharaman, seeking sweeping changes in Goods and Services Tax (GST) policy, procedures, and technology infrastructure.

The memorandum, divided into Law/Policy-related and GSTN Portal-related suggestions, calls for measures aimed at reducing compliance burdens, streamlining dispute resolution, and promoting fairness for small taxpayers.

Key Law and Policy Recommendations

1. One-Time Amnesty Scheme under Section 74
   Urging relief for legacy GST disputes, the bodies propose an amnesty scheme to settle cases arising from initial years of GST rollout, citing system glitches, procedural lapses, and unintentional errors that led to prolonged litigation.
2. Condonation of Appeal Delays Beyond One Month
   Recommendation to amend Section 107(4) of the CGST Act to give Commissioner (Appeals) wider discretion to condone delays, aligning GST law with provisions under the Income Tax Act.
3. Operationalize GST Appellate Tribunal
   Stressing that the long-pending GSTAT is crucial for clearing the growing backlog of appeals, they highlight working capital blockages due to pre-deposits and prolonged wait for appellate relief.
4. Increase Service Provider Registration Threshold
   Proposal to raise the GST registration limit for service providers from ₹20 lakh to ₹40 lakh, matching the threshold for goods suppliers.
5. Activate GST Compliance Rating (Section 149)
   Implementation of compliance scores for registered taxpayers to encourage transparency and voluntary compliance.
6. Rationalization of GST Rates
   Simplification of the current multi-slab structure to reduce classification disputes, address inverted duty structures, and lower compliance complexity.
7. Waiver of Interest on ITC Reversal in Certain Cases
   Amendment sought to waive interest where ITC reversal occurs due to non-payment to suppliers within 180 days, but the supplier has already paid tax to the government.
8. Rationalize Minimum Penalty of ₹10,000 under Section 73
   Suggestion to link penalty to 10% of tax payable without a fixed minimum, to avoid disproportionate penalties for small demands.
9. GST on Realization Basis for MSMEs
   Allow micro and small taxpayers to pay GST upon actual receipt of payment instead of invoice date, easing cash flow stress.
10. Retrospective Effect for Rule 88B(1) Proviso
    Proviso regarding interest calculation should be applicable from July 1, 2017, to avoid hardship where tax was deposited on time but return filing was delayed.
11. Refund of GST on Capital Goods for LUT Exporters
    Amendment to allow exporters to claim GST refunds on capital goods purchased under the Letter of Undertaking route.
12. IMS Exemption for Small Businesses
    Relief from mandatory use of Invoice Management System for micro and small taxpayers to reduce compliance costs.

Key GST Portal and Technology Recommendations

1. Increase File Upload Limit to 5MB
   For all GST registration documents to improve document clarity and ease of submission.
2. Annual Download of GSTR-2A/2B, E-Way Bills, and E-Invoices
   Enable consolidated yearly data downloads to reduce reconciliation effort.
3. Unified Pop-Up Notification for Departmental Notices
   A central dashboard alert system to avoid missed communications.
4. Extended “My Applications” Search Period
   Increase history visibility from 3 months to 12 months for better record access.
5. Refiling of Refund Claims Post Rejection
   Allow taxpayers to correct and resubmit claims in the same category without being forced into appeals.
6. Auto-Population of HSN Data in GSTR-9
   Reduce manual entry errors by pulling data directly from GSTR-1.
7. Extend IRN Cancellation Time from 1 to 2 Days
   To prevent unnecessary issuance of credit notes.
8. Integrate DIGIPIN Addressing
   Adopt India Post’s digital address codes for precise taxpayer location mapping.
9. Operationalize First Return Provisions
   Introduce a dedicated form and clear rules for filing the first GST return after registration.

Appeal for Early Action

AGFTC and ITBA have emphasized that these changes will reduce litigation, improve compliance, and ease the doing of business, especially for micro, small, and medium enterprises (MSMEs). They have urged the Ministry to act swiftly under the leadership of Prime Minister Narendra Modi and Finance Minister Nirmala Sitharaman to strengthen GST’s efficiency and taxpayer trust.

Copies of the representation have also been marked to the Revenue Secretary, Gujarat Finance Minister, CBIC Chairman, Chief Commissioners of Central and State Tax, and GSTN CEO.

Read More: No Parallel GST Probes, Defines ‘Initiation of Proceedings’ Under Section 6(2)(b): Supreme Court

Mariya Paliwala

Mariya is the Senior Editor at Juris Hour. She has 5+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started as a freelance tax reporter in the leading online legal news companies like LiveLaw & Taxscan.