Intimation of Composition Levy 

Rule 1(1) of draft GST Composition Rules provide that any person who has been granted registration on a provisional basis under sub-rule (1) of rule Registration.16 and who opts to pay tax under Section 10, shall electronically file an intimation in FORM GST CMP-01, duly signed, on the Common Portal, either directly or through a Facilitation Centre notified by the Commissioner, prior to the appointed day, but not later than thirty days after the said day, or such further period as may be extended by the Commissioner in this behalf.

Issue

The declaration filed prior to appointed date will not have any legal sanctity due to non-existence of statute

Suggestion

• It is suggested that filing date of declaration be only after appointed date and within 180 days.
• Also, it be clarified that time limit will apply from date of grant of certificate of registration

Source ICAI Suggestions on GST Rules Submitted to Govt of India