From the Desk of Chairman


Dear Members


The Government has taken a series of measures to simplify and quicken the process of IGST refund on exports and refund of GST Input Tax Credit for exporters. This includes facility of online filing of LUT, notifying documents to be submitted for claiming ITC refund, organizing IGST refund fortnight and providing facility for manual submission of
claims for IGST refund which were held-up due to errors etc.,

I participated in the meeting on GST convened by Member (Customs), Central Board of Indirect Taxes and Customs (CBIC) on March 23, 2018 and took-up the issues concerning refund. I made the requests namely a) removal of condition of requirement of EGM filing for claiming GST refunds b) Field formations not to ask for BRC for processing ITC refund and delay in refund of IGST wherein the credit in particular month is less than IGST claim. Subsequently, I also submitted a representation to Member (Customs) reiterating these requests and also requesting for processing GST refund on the basis of self declaration from exporters in the following cases

– Table 6 A of GSTR 1 form (monthly return for outward supplies) has provisions for filing export details. Non- Transmission of this Table 6 A from GSTIN to Customs is observed in the following cases.

a) IGST paid value declared in GSTR 1 is more than that declared in GSTR 3 B form (monthly summary return) for the month due to inadvertent errors committed by exporter while filing returns

b) Exporter has given export sales under Table 3.1.(a) (meant for local sales) instead of Table 3.1.(b) (meant for exports) in GSTR 3 B

– Table 9 A of GSTR 1 form has provisions for filing errors committed (in earlier returns) in respect of invoices/shipping bills. In cases where exporter has mentioned wrong port code in earlier returns and made corrections in Table 9 A, this Table 9 A is not transmitted from GSTIN to Customs.

In the meeting with Member (Customs) , a mention was also made by the Senior officials on the various kinds of errors committed by exporters while filing GST returns and the combination of these errors make it very difficult for a standalone solution to be found for rectification of errors. The errors committed by exporters can be broadly classified into 2 categories.

• In the first category are those errors which prevent the data in respect of refunds being pushed from GSTN to CBEC. These include filing of correct GSTR 1 (GST monthly return for outward supplies) but duty payment details not filed in appropriate column in GSTR 3 B, correct details including cess not provided in Table 6 A (of GSTR 1) or the details of shipping bills are not given.
• The second category of errors are those errors because of which though the data has been received by CBEC but
because of mismatch, refunds do not get sanctioned. This contains invoice mismatch contributing to about 30% to 35% of the cases, non-filing of EGMs at ICDs and at gateway ports, wrong filing of GSTN No./ Shipping Bills. For correcting invoice mismatch, a circular has already been issued providing for an officer based interface for processing the refunds. All the Chief Commissioners have been sensitized for coordinating with the shipping lines for filing EGMs at gateway ports and at ICDs which is being monitored on a daily basis by CBEC. On ICEGATE, the exporters can see what the errors are and can take action accordingly.
• There is an issue of error in filing GSTR 3 B (GST summary monthly return) where instead of IGST paid for exports
which is to be reflected in Table 3.1 (B) of GSTR 3 B, the said amount has been mistakenly filed in Table 3.1 (A). For solving such errors, the matter is being discussed with GSTN to find a solution.

I would hence urge members to avoid errors in filing GST returns so as to avoid delay in processing of GST refunds.

It was also mentioned in the meeting that exporters have to ensure that their bank accounts get validated ( for processing GST refunds) and they should preferably give the same bank account number with Customs and GST authorities.

We have already sent a circular to members requesting details of pending GST ITC refund cases. I would urge members to provide the details in the prescribed format to enable us to take-up the issue with concerned authorities.

All Industry Rates of Duty Drawback

You are aware that the GST rates and cap values of several leather, leather products and footwear were increased in the new Drawback Rates announced w.e.f. Jan. 25, 2018. The Drawback Directorate has now called for data for revision of the Drawback Rates for the year 2018-19. CLE will be sending a detailed circular in this regard. I would urge members to provide the data in prescribed format without fail, as submission of representative and verifiable data is necessary to get Drawback Rates commensurate with the duty incidence.

With best wishes

Mukhtarul Amin