Application in respect of tax or duty credit carried forward under any existing law or on goods held in stock on the appointed day

Rule 1 of draft GST Transitional Provision Rules requires voluminous details like the amount of tax or duty availed or utilized by way of input tax credit under each of the existing laws till the appointed day, the amount of duty or tax yet to be availed or utilized by way of input tax credit under each of the existing laws till the appointed day; etc. And an application to be filed by the taxable person

Issues

This would be a humongous task for existing manufacturers/Dealers/service providers to upload such data on the GST portal. Also, the requirement to file an application defeats the concept of seamlessness of credit. It may be inferred that ‘application’ may lead to ‘approval’ by tax administration which might not purport the concept of ease-of-doing-business.

Suggestion

It is suggested that the requirement of ‘application’ be replaced with ‘intimation’ and the elaborate information required to be filed on GSTN be simplified to support the assessees during transition.

Source ICAI Suggestions on GST Rules Submitted to Govt of India