Category: Blog

A welcome relief for businesses and corporate promoters! The Goods and Services Tax Network (GSTN) has issued an advisory dated 3rd March 2025 bringing an important improvement to the #Biometric #AadhaarAuthentication process for GST registration.

What’s the Key Relief?

Earlier, Promoters / Partners / Directors of companies often had to travel to multiple states to complete biometric Aadhaar authentication for GST registrations.

✅ Now, only a ONE-TIME biometric authentication in the home state is required.

This change directly addresses a major operational challenge faced by many corporates operating across multiple states.

How the New Process Works

• Promoters / Directors can complete one-time biometric Aadhaar authentication in their home state.
• For registrations in other states, businesses can nominate an Alternate Primary Authorized Signatory (PAS).
• The PAS will complete the biometric authentication locally in the respective state where the GST registration is being processed.

Why This Matters

✔ Eliminates repeated interstate travel for directors
✔ Reduces compliance burden and administrative delays
✔ Improves operational efficiency for multi-state businesses

📄 The advisory issued by Goods and Services Tax Network highlights important details—particularly paragraphs 3, 8, 9, and 10, which taxpayers should carefully review.

This is definitely a progressive step toward simplifying GST registration compliance.

💬 What do you think about this change? Will this make multi-state GST registrations easier for businesses?

The #GSTAmnestyScheme was introduced with the intent to reduce litigation and provide relief to taxpayers. However, in practice, several complexities and procedural challenges continue to exist.

Instead of simplifying dispute resolution, the scheme often resembles a separate set of proceedings, involving:

• Burdensome procedural compliance
• Strict eligibility conditions
• Limited timelines
• Multiple procedural layers

As a result, taxpayers may find themselves navigating a longer and more complex compliance path, sometimes leading to circular litigation rather than true dispute resolution.

There is a strong case for the GST Council to revisit the scheme’s design and focus on:

✅ Widening the scope of eligibility
✅ Simplifying procedural requirements
✅ Reducing litigation
✅ Facilitating faster revenue realization

📄 In our article published on Taxindiaonline (TIOL), we have discussed 14 key practical challenges in the implementation of the scheme along with our suggestions to the Central Board of Indirect Taxes and Customs (CBIC) and the GST Council.

The objective is simple — make dispute settlement truly effective and practical for taxpayers.

🤝 Content supported by Akshaya Ramesh.💬 What has been your experience with the #GSTAmnestyScheme so far? Share your thoughts below.

To make E-Invoice verification simpler and more reliable, the Goods and Services Tax Network (GSTN) has released a list of authorized B2B e-Invoice verification apps.

These apps are officially approved and help businesses securely verify e-Invoices and QR codes, ensuring smoother GST compliance.

📄 Key Points to Know:

• All listed apps are authorized by GSTN
• Apps are interoperable across the GST ecosystem
• They provide a secure and reliable way to verify e-Invoices and QR codes
• Useful for businesses to validate invoice authenticity instantly

📥 Access the full list of approved apps here:
https://lnkd.in/gae_-ubu

Stay updated. Stay compliant. 🚀

The Central Board of Indirect Taxes and Customs (CBIC) has issued Instruction No. 02/2025-GST dated 7th February 2025 in relation to the waiver scheme under Section 128A.

But the big question is — is there anything significant to celebrate?
✍ IMHO, honestly… not really.

The instruction clarifies that where Department Appeals are filed only on account of interest and/or penalty, and the taxpayer fulfills the conditions under Section 128A, the proper officer may proceed to withdraw such departmental appeals.

Fair enough… but does this really cover all practical scenarios? 🤔

Key Concerns

1️⃣ No Finality Even After Availing Waiver

Even after the waiver benefit is granted, the department is not legally barred from filing appeals or rectification against the order granting waiver.

This means that despite opting for the scheme to settle the dispute and achieve closure, the taxpayer may still face further litigation.

📌 Suggestion:
Introduce a legal provision preventing the department from appealing against orders granting waiver benefits, since proceedings should ideally conclude once Section 128A relief is granted.

Otherwise, it becomes an endless cycle of disputes.

Also, the current instruction covers only departmental appeals relating to interest and/or penalty, making it inadequate in scope.

2️⃣ No Protection from Department Appeals or Rectification

For cases relating to FY 2019-20, there is a real possibility that:

• Taxpayers may apply for amnesty and pay the tax liability, while
• The department may still file an appeal before the limitation period expires (around Feb 2025, depending on order date).

This creates uncertainty — even after opting for the amnesty scheme, taxpayers may still face departmental appeals.

📌 Suggestion:
The Central Board of Indirect Taxes and Customs should issue internal instructions to avoid departmental appeals in cases where taxpayers have opted for the amnesty scheme.

Without this, the objective of dispute settlement remains incomplete.

3️⃣ No Waiver Option for Future Uncertainty

Another practical issue arises where:

• Currently no demand exists, because the department has dropped proceedings, but
• The department may appeal against the drop order, and
• The tax liability may later be confirmed by an appellate authority.

In such situations, taxpayers lose the opportunity to opt for the amnesty scheme, because:

• There is no demand at present, and
• The law does not explicitly allow future access to the scheme if the demand arises later.

📌 Suggestion:
Amend Section 128A to allow cases where NIL demand orders are later enhanced in appeal to also qualify for the amnesty scheme.

Final Thought

While the instruction attempts to address certain procedural aspects, it falls short of providing true dispute finality.

Without stronger safeguards, taxpayers opting for the scheme may still face future appeals, rectifications, and prolonged litigation.

💬 What are your thoughts on this instruction?
Do you think the amnesty scheme achieves its intended objective of dispute resolution?

Share your views below 👇

The much-awaited advisory from the Goods and Services Tax Network (GSTN) has been released regarding the difference in values between Table 8A and Table 8C of GSTR-9 Annual Return for FY 2023-24.

For FY 2023-24, Table 8A is auto-populated based on GSTR-2B instead of GSTR-2A, which has created significant reconciliation challenges for taxpayers.

However, instead of offering a complete solution, the advisory appears to create further complexities in reporting. At best, it confirms that GSTN is aware of the challenges in this form, though the suggested approach may still result in differences that could trigger future disputes.

In the attached document, we have also highlighted additional issues and mismatches that may arise while strictly following the advisory instructions.

Practical View on the Advisory

In my view, although the advisory suggestions may lead to differences in the form and potential notices in the future, adopting any alternate approach may place taxpayers in an even more uncertain position.

Therefore, following the advisory may still be the safer approach, as it provides a reasonable explanation for why differences are reported in the return.

It often appears that this form, in a self-assessment tax regime, is structured more for future litigation triggers rather than simple annual reporting.

A complete solution may only be possible if the entire structure of GSTR-9 is redesigned to properly capture all ITC reporting scenarios.

Recommended Best Practice

Any difference between Table 6J and Table 8D of GSTR-9 may potentially result in future notices and tax disputes.

Hence, the following best practice is advisable:

• Differences between Table 6J and Table 8D should be properly explained in Table 13 of GSTR-9C.
• A detailed reconciliation statement with reasons should be prepared and uploaded as an attachment in GSTR-9C.
• Where GSTR-9C is not applicable, taxpayers should:

• Raise a grievance ticket on the GST portal, and
• Submit a formal letter to the jurisdictional officer with acknowledgement.

Important Note

This approach may not completely avoid litigation, but it helps create documentary evidence and justification to defend the differences during future assessments or audits.

Maintaining proper documentation today can significantly help in handling future GST litigation effectively.💬 Views expressed are personal. Comments and professional perspectives are welcome.

The Goods and Services Tax Network (GSTN) has issued an important advisory regarding the GST Amnesty Scheme for waiver of interest and penalty under Section 128A.

According to the advisory, Form GST SPL-01 and Form GST SPL-02, which are required to apply for the amnesty scheme, are currently under development on the GST portal and are expected to be made available tentatively from the first week of January 2025.

This update has drawn attention across the tax community because the legal provisions of the scheme are already in force, while the portal functionality required to apply for it is still pending.

Timeline of the GST Amnesty Scheme under Section 128A

The development of the scheme has progressed through several stages:

• 22 June 2024 – Recommendation made during the GST Council meeting (53rd GST Council Meeting)
• October 2024 – Official notifications issued
• 1 November 2024 – Provisions of the scheme came into effect
• January 2025 (tentative) – GST portal expected to enable Forms SPL-01 and SPL-02

This timeline highlights a practical challenge: while the scheme is legally effective, taxpayers currently cannot apply online until the required forms are activated on the portal.

Purpose of the GST Amnesty Scheme under Section 128A

The GST Amnesty Scheme aims to provide relief to taxpayers by allowing waiver of interest and penalties for certain tax demands issued under **Central Goods and Services Tax Act, 2017 Section 73.

The scheme primarily benefits taxpayers who:

• Have pending tax demands for earlier financial years
• Wish to settle the principal tax liability
• Want relief from accumulated interest and penalties

Once the scheme is fully operational on the portal, eligible taxpayers will be able to apply using Form GST SPL-01 and Form GST SPL-02.

Forms Required for the Amnesty Scheme

Form GST SPL-01

This form will be used by taxpayers to apply for the waiver of interest and penalty under the scheme.

Form GST SPL-02

This form will be used by the tax authorities to process and communicate decisions related to the application submitted under SPL-01.

These forms will become available on the GST common portal once development is completed.

Concerns Raised by Tax Professionals

While the scheme itself is welcomed, the delay in enabling the required forms on the portal has raised several concerns among taxpayers and professionals.

Many experts believe that when lawmakers themselves require time to operationalize the scheme, taxpayers should also be provided adequate protection during the interim period.

Two major concerns have been highlighted.

Suggestion 1: Temporary Suspension of Recovery Proceedings

Professionals have suggested that authorities should issue a clear direction that:

• No recovery proceedings should be initiated for orders issued under Section 73 for the relevant three financial years
• Such protection should remain in place until 31 March 2025, allowing taxpayers to utilize the amnesty scheme once the portal functionality becomes available.

This would prevent unnecessary recovery actions while the scheme is still being technically implemented.

Suggestion 2: Extension of Time Limit for Appeals and Rectifications

Another key suggestion is to provide a blanket extension of time limits for appeals and rectification applications related to these orders.

Experts propose that the period from 22 June 2024 to 31 March 2025 should be excluded when calculating the limitation period, similar to the extensions granted during the COVID-19 pandemic.

Such a step could help ensure that taxpayers do not lose their legal rights simply because the portal functionality was delayed.

What Taxpayers Should Do Now

Until the forms are officially enabled on the portal, taxpayers should take the following steps:

✔ Review pending GST demand orders issued under Section 73
✔ Identify potential cases eligible for interest and penalty waiver under Section 128A
✔ Ensure that principal tax liabilities are properly reconciled
✔ Monitor updates from the Goods and Services Tax Network and the Central Board of Indirect Taxes and Customs

Staying prepared will allow taxpayers to quickly apply for the scheme once Forms SPL-01 and SPL-02 become available.

Conclusion

The GST Amnesty Scheme under Section 128A represents a significant opportunity for taxpayers to settle past GST disputes with waiver of interest and penalties. However, the delay in activating Forms GST SPL-01 and SPL-02 on the GST portal has created practical challenges.

As the tax community awaits the portal rollout expected in January 2025, there is growing demand for clear administrative instructions to prevent recovery proceedings and extend appeal timelines.Until further clarifications are issued, taxpayers should stay updated, review their pending demands, and be ready to take action once the scheme becomes operational online.

The Central Board of Indirect Taxes and Customs (CBIC) has issued Circular No. 246 dated 30.01.2025, clarifying the applicability of late fees in cases where GSTR-9 is filed without GSTR-9C.

🔎 Key Clarification

Where GSTR-9C is applicable (AATO exceeding ₹5 crores), the annual return compliance under Section 44 of the CGST Act is considered complete only when both GSTR-9 and GSTR-9C are filed.

Therefore:

• Filing only GSTR-9 without GSTR-9C is treated as failure to furnish the Annual Return under Section 44.
• Consequently, late fees will continue to accrue until GSTR-9C is filed.

⚖ Professional View

While this interpretation may be subject to legal challenge, the current position taken by the Revenue authorities was largely anticipated from the time these provisions were introduced.

📌 Practical Recommendation

In the best interest of taxpayers, it may be advisable to utilize the one-time opportunity and complete the filing on or before 31st March 2025, instead of entering into prolonged litigation.

Completing the filing within the specified time can help avoid further late fees exposure and compliance complications.

Stay compliant and act within the timeline. ✅

The Goods and Services Tax Network (GSTN) has released a detailed advisory and FAQs for Form DRC-03A, providing taxpayers with clarity on how to properly link voluntary tax payments made through DRC-03 with outstanding demands on the GST portal.

This update is particularly important for taxpayers who previously paid tax through Form DRC-03 but noticed that the payment did not automatically close the liability in the electronic liability register. The newly introduced **DRC-03A functionality resolves this issue by enabling proper adjustment of such payments against specific demand orders.

Understanding how DRC-03A works in GST compliance is crucial for avoiding recovery proceedings and ensuring eligibility for relief schemes such as the GST Amnesty Scheme.

Purpose of Form DRC-03A in GST

Form DRC-03A has been introduced to address a practical issue faced by many taxpayers.

In several cases, taxpayers paid GST demand amounts using Form DRC-03 instead of the system’s dedicated demand payment function. Because of this, the GST portal did not automatically map those payments to the corresponding demand order, leaving the liability technically open in the system.

Form DRC-03A solves this problem by linking the earlier DRC-03 payment directly with the demand order, thereby ensuring that the liability is properly settled in the electronic liability register.

Why Form DRC-03A is Important for Taxpayers

The introduction of DRC-03A on the GST portal serves multiple compliance purposes.

1. Settlement of Tax Liability

Taxpayers can now link voluntary payments made through DRC-03 with specific GST demand orders, allowing the liability to be properly closed in the system.

2. Avoid Recovery Proceedings

If liabilities remain unadjusted in the system, authorities may initiate recovery proceedings under GST law. Filing **DRC-03A ensures that the payment is recognized and the demand is marked as settled.

3. Requirement for Amnesty Scheme Benefits

For taxpayers planning to apply under the GST Amnesty Scheme, filing DRC-03A becomes an essential step if the tax amount was previously paid through DRC-03.

Without properly linking the payment to the demand, the system may not recognize the liability as settled, which could affect eligibility for the scheme.

Step-by-Step Process to File Form DRC-03A

The **Goods and Services Tax Network has provided a simplified filing process on the GST portal.

Step 1: Access the Form on the GST Portal

Log in to the GST portal and navigate to the section where Form DRC-03A is available.

Step 2: Enter DRC-03 ARN

Provide the Acknowledgement Reference Number (ARN) of the DRC-03 payment previously made.

Step 3: Enter Demand Order Details

Enter the relevant demand order number against which the payment needs to be adjusted.

Step 4: Auto-Population of Details

The system will automatically fetch details from the DRC-03 payment and the demand order, enabling quick verification.

Step 5: Submit for Adjustment

Once confirmed, submit the form. The system will link the payment to the demand order, and the electronic liability ledger will update accordingly.

Eligibility for Filing DRC-03A

Not all DRC-03 payments are eligible for adjustment using Form DRC-03A.

The form applies only if the original DRC-03 payment was made under the following categories:

• Voluntary payment
• Others

Taxpayers should review their DRC-03 filing details before proceeding with DRC-03A.

Support and Resources for Taxpayers

To help taxpayers understand and use the new feature effectively, the **Goods and Services Tax Network has released several resources.

These include:

• Official GSTN advisory explaining the feature
• Detailed guidance document
• Frequently Asked Questions (FAQs) for common queries

In case of technical issues while filing DRC-03A, taxpayers can raise a support ticket through the GST Grievance Redressal Portal under the category “DRC-03A-Filing.”

Conclusion

The introduction of Form DRC-03A on the GST portal is a crucial development in the GST demand and recovery management system. By enabling taxpayers to link DRC-03 payments with specific demand orders, the form ensures proper liability adjustment and prevents unnecessary recovery actions.

Taxpayers who have previously made voluntary payments through DRC-03 should review their records and file DRC-03A where applicable to ensure that their liabilities are correctly settled in the GST system.Taking timely action will help businesses maintain accurate compliance records and benefit from available GST relief schemes.

The Goods and Services Tax (GST) portal has introduced a new and important compliance feature – Form DRC-03A. This form plays a critical role in adjusting tax liabilities against payments already made through DRC-03.

For taxpayers who have voluntarily paid tax through DRC-03, the availability of DRC-03A on the GST portal is a major step toward ensuring proper liability adjustment and avoiding unnecessary recovery actions.

Understanding how DRC-03A works in GST compliance is essential for businesses, accountants, and tax professionals.

What is Form DRC-03 under GST?

Before understanding DRC-03A, it is important to know about DRC-03.

Form DRC-03 is used by taxpayers to make voluntary payment of GST, including:

• Tax liability
• Interest
• Penalty

Such payments may arise during:

• GST audit
• GST investigation
• Departmental notices
• Self-detected tax liability

Many taxpayers use DRC-03 to voluntarily settle tax dues before formal recovery proceedings begin.

What is Form DRC-03A?

Form DRC-03A is introduced to link or offset the payment made through DRC-03 against an existing tax liability on the GST portal.

In simple terms:

• DRC-03 = Payment of tax liability
• DRC-03A = Adjustment of that payment against the correct demand or liability

This ensures that the payment made through DRC-03 is properly reflected and adjusted in the taxpayer’s liability register.

Why DRC-03A is Important

The introduction of DRC-03A on the GST portal is crucial for several reasons.

1. Avoid Recovery Proceedings

If tax payments made through DRC-03 are not properly adjusted against liabilities, the system may still show pending tax dues.

Using DRC-03A ensures that the payment is correctly mapped, helping taxpayers avoid recovery proceedings and unnecessary notices from tax authorities.

2. Required for Amnesty Scheme Benefits

DRC-03A also plays an important role in GST Amnesty Schemes.

In many cases, taxpayers are required to:

1. Pay the tax using DRC-03, and
2. Offset that payment using DRC-03A

Only after completing this process can taxpayers claim benefits under the GST Amnesty scheme, such as waiver or reduction of penalties and interest.

3. Proper Liability Adjustment

DRC-03A ensures that the tax paid voluntarily is correctly reflected in the GST system, helping maintain accurate records in:

• Electronic Liability Register
• Demand and Recovery records
• GST compliance history

Who Should Use Form DRC-03A?

The form is particularly relevant for:

• Businesses that made voluntary GST payments through DRC-03
• Taxpayers who settled tax dues during GST audits or investigations
• Entities applying for GST Amnesty Scheme benefits
• Taxpayers looking to avoid recovery actions or outstanding demand notices

Action Required from Taxpayers

Now that DRC-03A is live on the GST portal, taxpayers should take immediate action if they have previously paid tax through DRC-03.

Recommended steps:

✔ Review past DRC-03 payments
✔ Check pending liabilities on the GST portal
✔ Use DRC-03A to offset payments against liabilities
✔ Ensure proper compliance before responding to notices or applying for amnesty benefits

Timely action can help businesses avoid future disputes, recovery proceedings, and compliance complications.

Conclusion

The launch of Form DRC-03A on the GST portal is a significant development in GST compliance and demand management. It allows taxpayers to properly adjust voluntary tax payments made through DRC-03, ensuring accurate reflection of liabilities and preventing unnecessary recovery actions.

Businesses and tax professionals should review their GST records immediately and utilize DRC-03A where applicable to maintain clean compliance and benefit from available schemes.Act now to ensure your GST liability records remain accurate and up to date.

The Goods and Services Tax Network (GSTN) has introduced Phase III changes in HSN reporting for GSTR-1 and GSTR-1A, applicable from the January 2025 return filing period.

🔎 Key Changes Introduced

• HSN codes must now be selected from a drop-down list – manual entry will no longer be allowed.
• Table 12 has been split into two sections:

• B2B supplies
• B2C supplies
  • This enables separate and more accurate reporting of HSN-wise summary.

⚙ Additional Validations

• New validation checks are introduced for taxable value and tax amounts.
• Initially, these validations will run in warning mode, allowing taxpayers to proceed with filing while highlighting possible mismatches.
• Over time, these validations are expected to improve accuracy and standardize HSN reporting in GST returns.

📄 Read the full advisory:
https://lnkd.in/g9SsN9V2

Stay updated. Stay compliant. ✅