Table of Contents
INTRODUCTION: ........................................................................................................... 4
GOODS AND SERVICES TAX: A CLOSER LOOK .................................................................. 5
I.
Dual GST Model: .............................................................................................................................. 5
II.
Taxes to be subsumed: ..................................................................................................................... 6
III.
GST Rates: ....................................................................................................................................... 7
IV.
GST Thresholds: ............................................................................................................................... 7
V.
Integrated GST (IGST): ..................................................................................................................... 7
VI.
GST Input Credit (ITC) Mechanism: .................................................................................................. 8
VII.
GST Administration: .......................................................................................................................... 8
VIII. GST: IT Strategy ............................................................................................................................... 9
GST : IMPACTS ON INDUSTRY...................................................................................... 11
A. Manufaturing Industry .........................................................................................................................11
B. Service Industry ..................................................................................................................................14
GST: OPERATIONAL IMPACTS AND CONCERNS: ............................................................. 18
A. REGISTRATION: A TAX ENTITY .......................................................................................................18
B. PROCUREMENT OF GOODS & SERVICES ......................................................................................22
I.
Domestic Intrastate Procurement Goods (Raw Material)................................................................22
II.
Domestic Interstate Procurement Goods (Raw Material)................................................................25
III.
Domestic Procurement : Capital goods.............................................................................................29
IV.
Domestic Procurement Services ...................................................................................................31
V.
Import Procurement Goods (Raw Material)....................................................................................34
C. SALE OF GOODS & SERVICES ........................................................................................................38
I.
Domestic Intrastate Sale Goods (Raw Material).............................................................................38
II.
Domestic Interstate Sale Goods (Raw Material).............................................................................41
III.
Domestic Sale Services ................................................................................................................45
IV.
Export Sale Goods (Raw Material) ................................................................................................48
D. STOCK TRANSFERS.........................................................................................................................51
E. SUBCONTRACTING ..........................................................................................................................54
F. DEPOT OPERATIONS .......................................................................................................................57
I.
Depot Procurement Goods ............................................................................................................57
II.
Depot Sales Goods .......................................................................................................................58
G. LEGAL REPORTING ..........................................................................................................................61
ANNEXURE I : ACCOUNTING TREATMENT FOR BUSINES SCENARIOS....................... 63
I.
Domestic Intrastate Procurement : Goods (Raw Material).................................................................63
II.
Domestic Interstate Procurement : Goods (Raw Material).................................................................63
III.
Domestic Procurement : Capital Goods ............................................................................................64
IV.
Domestic Procurement : Services ....................................................................................................64
V.
Import Procurement : Goods (Raw Material).....................................................................................65
VI.
Domestic Intrastate Sale : Goods (Raw Material) .............................................................................66
VII.
Domestic Interstate Sale : Goods (Raw Material) .............................................................................66
VIII. Domestic Sale : Service ...................................................................................................................67
IX.
Export Sale : Goods (Raw Material) .................................................................................................67
X.
Stock Transfers................................................................................................................................68
XI.
Subcontracting .................................................................................................................................68
XII.
Depot Procurements ........................................................................................................................69
XIII. Depot Sales .....................................................................................................................................69
GLOSSARY:
Acronym
Meaning
A/C
Account
BED
CG
Capital Goods
CGST
CST
CVD
Countervailing Duty
DEPB
ECess
Education Cess
EOU
EPCG
GST
IGST
ISD
LTU
PLA
RM
Raw Material
SAD
SED
SEZ
SGST
SSI
VAT
GSTN
Note:
Structural Overview
Starting from section "GST: Operational Impacts & Concerns, each subsection takes a closer
look at each of the impacted business processes, starting with an introduction to the existing
business process followed by the process flow diagram and process overview of the existing
scenario with the current prevalent indirect taxation structure.
This is followed by the GST scenario which covers the impact that the introduction of GST will
have on the same business process, along with an example scenario and a diagrammatic
representation of the business process in the GST era (wherever possible). In addition, finally
the subsection is ended with the list of clarifications sought by business software providers in
order to be able to have complete clarity on the process flow in the GST era so as to be able to
implement the new business process and the related taxation requirements in time for the GST
changeover date.
Annexure I highlights the accounting schemas for different business processes covered, as
per the current tax system inplace.
INTRODUCTION:
The introduction of Goods and Service tax (GST) in India by April 2012 promises to be one of the biggest and
most impactful changes in the history of Indian indirect taxation. This whitepaper focuses on the proposed
GST model for India and its impact on the manufacturing and services industry.
At present the tax structure in India is federal in nature with the power to levy taxes and duties distributed
among the Union Governments and the State Governments. The Goods and Service tax (GST) being
introduced in 2012 will replace the existing indirect taxes on consumption. GST will be applicable on both
goods and services. In respect of goods, the levy will be destination based whereas in respect of service tax,
the levy will be consumption based. GST will be charged and collected at each stage of the production/
processing / trading on the value added during that stage. GST proposes set-off of tax paid on inputs / capital
goods and services.
GST can be defined as a tax on goods and services, which is levied at each point of sale or provision of
service, in which, at the time of sale of goods or providing the services, the seller or service provider may
claim the input credit of tax which he has paid while purchasing the goods or procuring the service.
The GST introduction will have impact on Tax Structure, Tax Incidence, Tax Computation, Utilization and
Reporting leading to a complete overhaul of the current indirect tax system. At the organizations end, it would
mean change to business processes to align to the new tax regime, update of the various software solutions
across all locations to meet the proposed structure, training of all personnel to use the new process and in
addition ensuring smooth transition from the old regime.
GST will have a significant impact on almost all aspects of businesses operating in the country, including the
supply chain, sourcing and distribution decisions, inventory costs and cash flows, pricing policy, accounting
and and transactions management.
Application Systems act as a backbone support for the complex business structure and enable it to function
smoothly and seamlessly. As of today almost all the businesses, small or big, uses Application Software in
some form or the other to efficiently carry out their operations. Any changes to the business operations has a
direct impact on the software infrasturcture which has to be re-aligned to accomodate such changes.
GST being the structural change by nature, will of-course call for a significant re-structuring at the supporting
application sofware infrastructure at the business organization. Hence planning and execution of such a
transitional task is of utmost impartance for the organizations management at this moment as we move
closer to GST implamentation. First and foremost step in this direction is to completely understand the depth
and impact analysis of such a change with greater levels of clarity.
The intention of this whitepaper is to take a closer look at the impact of GST on business processes from a
systems prospective and also highlight the areas where further clarity is required in order to effect a smooth
and efficient transition to the GST era.
II.
Taxes to be subsumed:
The current indirect system in India imposes multiple levies on sale and purchase of Goods and
Services within its jurisdiction. With an attempt to simplify this tax structure for the benefit of both
trade and consumers, following are the taxes, proposed to be subsumed under the dual component
structure GST.
Exclusions:
Basic Customs Duty, Octroi, Stamp Duty and Electricity duty may be kept outside the GST. Levies
like the toll tax, environment tax and road tax will be outside the GST ambit, as these are user
charges. A basket of petroleum products and natural gas likely to be charged with GST and an
additional levy by both the Central and States. No input credit would be available against on the
additional levy. A similar treatment might be provided to alcohol and tobacco.
III.
GST Rates:
The Empowered Committee has decided to adopt a two-rate structure a lower rate for necessary
items and goods of basic importance and a standard rate for goods in general. There will also be a
special rate for precious metals and a list of exempted items.
First discussion paper on GST did not specify any GST rate. Currently, the standard Cenvat, VAT,
CST and Service Tax rates are 8%, 12.5 %, 2% and 10% respectively. The Task Force on GST of
Thirteenth Finance Commission (TFC) has worked out a Revenue-Neutral Rate (RNR) of 12% (5%
CGST and 7% SGST) assuming there is a single GST rate and stamp duty & electricity duty are also
subsumed in the GST. With dual GST in place, this RNR is going to change.
The exact value of the SGST and CGST rates, including the rate for services, will be made known
duly in course of appropriate legislative actions.
IV.
GST Thresholds:
A dual threshold is proposed by EC for CGST and SGST. For CGST, the basic exemption for goods
would remain at rupees 1.5 Crores and for services a similar exemption would be provided later. For
SGST, the basic exemption for goods and services would be rupees 10 Lakhs. Department of
Revenue has expressed concerns in having two different thresholds and has proposed a uniform
threshold for goods and services for both SGST and CGST. Also, a threshold of rupees 50 Lakhs
has been proposed under the composition scheme for small taxpayers. The threshold exemption
might not apply to persons engaged in inter-State business.
Further there would be a compounding/composition scheme for the small tax payers similar to the
one under VAT system. As per the First Discussion Paper, there would be a compounding cut-off at
Rs. 50 lakh of gross annual turnover and a floor rate of 0.5% across the States. The scheme would
also allow option for GST registration for persons with turnover below the compounding cut-off.
V.
VI.
VII.
GST Administration:
It proposed that, to the extent feasible, uniform procedure for collection of both Central GST and
State GST would be prescribed in the respective legislation for Central GST and State GST.
The administration of the Central GST would be with the Centre and for State GST with the States.
The taxpayer would need to submit periodical returns to both the Central GST authority and to the
concerned State GST authorities.
Each taxpayer would be allotted a PAN linked taxpayer identification number with a total of 13/15
digits. This would bring the GST PAN-linked system in line with the prevailing PAN-based system for
Income tax facilitating data exchange and taxpayer compliance. The exact design would be worked
out in consultation with the Income-Tax Department.
Keeping in mind the need of tax payers convenience, functions such as assessment, enforcement,
scrutiny and audit would be undertaken by the authority which is collecting the tax, with information
sharing between the Centre and the States.
VIII.
GST: IT Strategy
On the IT front, there has been consensus that there will be a common portal providing three core
services (registration, returns and payments). The broad services framework of the portal has been
discussed with the Sub Working group for IT.
Empowered Group on IT Infrastructure on GST has recommended setting up Goods and Services
Tax Network (GSTN), for managing the IT systems for GST implementation, including the Common
GST Portal.
GSTN will perform the following functions:
Provide common infrastructure and services to Central and State Governments
Ensure integration of the Common GST Portal with existing tax administration systems of Central
and State Governments
Build efficient and convenient interfaces with tax payers and tax administrators
Facilitate, implement and set standards for providing common GST services to the Central and State
Governments
Carry out research, study global best practices and provide training to the stakeholders.
The GSTN solution architecture for information flow is designed to ensure timely delivery of
information through the Common GST Portal, and timely delivery of funds directly through the
banking system.
The Common GST Portal is simply a pass-through device for information, while enhancing it with intelligence
to plug leakages. The taxpayer sends the return with GSTN, which keeps a copy of the return for analysis,
and forwards it in near real-time to the respective State and CBEC. The taxpayer pays the actual duty in the
bank, which uploads only the challan details into the GSTN. Actual funds never pass through the GSTN.
The Common GST Portal reconciles the returns and the challans. In addition to its pass-through role, the
portal would also play two other critical roles:
1. It would act as a tax booster, matching the input tax credits in the returns to detect tax evasion. It can
also integrate with various other systems at MCA and CBDT for verification of PAN or other
corporate information and perform data mining and pattern detection to detect tax fraud. It would
send this information as alerts/ reports to the respective tax authorities.
2. It would also compute inter-State settlement, netting IGST across States.
The Ministry of Finance, with the concurrence of the Empowered Committee of State Finance Ministers, has
set up an Empowered Group on IT Infrastructure for GST with, inter alia, the mandate of approving the
Solution architecture of the Common GST portal to be set up, Suggesting the modalities for setting up of a
GSTN and evaluating the suitability of the existing infrastructure namely NSDL & NPCL for incubating the
GSTN.
The Empowered Group on IT Infrastructure for GST in its first meeting evaluated the feasibility of incubating
the GSTN under NSDL and came to the conclusion that NSDL is well suited for this purpose. The scope of
the project and implementation strategy is being worked out with the NSDL.
Note: For further details on GSTN, please refer http://www.finmin.nic.in/GST/IT_Strategy_GST.asp .
10
A. Manufacturing Industry
Manufacturing sector in India is a highly taxed sector. Despite of low manufacturing cost of products in India,
multistage taxation i.e. customs duty on imports, central excise duty on manufacture, central sales tax (CST)
/ value added tax (VAT) on sale of goods, service tax on provision of services and levies such as entry tax,
octroi and cess by the State or local municipal corporations add to the cost of the product.
Introduction of GST will reduce the disadvantage of the complex and high taxation structure in India which is
currently increasing the cost of the products and sometimes even rendering them as uncompetitive in the
international market.
Manufacturers produce goods production might be completely in-house wherein production of raw
materials and the building of the final product is carried out by the manufacturer itself or else the process
might involve sourcing of raw materials externally or subcontracting of job works in order to carry out the final
assembling and building a product.
Goods which are manufactured in India attract the indirect tax: Central Excise Duty. This tax is collected by
the central government and the duty collections are managed by the Central Board of Excise and Customs
functioning under Ministry of Finance, Department of Revenue.
The manufacturer collects excise duty from the buyer and remits this duty to government. Goods can be
removed from their place of manufacture only while being accompanied with an excise invoice, while
contains information about the excise rate and duty applicable of the goods being moved.
11
Tax Incidence:
The manufacturer is liable to pay the excise duty to the government as soon as the excise invoice has
been issued and can avail input credit of excise duties once the goods and excise invoice has been
received in his premise.
(a) Input Credit at Excise Invoice Posting after Receipt of Goods
(b) Output Tax Payable on Excise Invoice Generation at Billing
GST impacts:
With the introduction of GST, the Central Excise duty will no longer be applicable (except on Petroleum
products and alcoholic products). The manufactured products will attract CGST and an SGST
component.
For example, in the existing tax regime, a company producing furniture will be charged with excise duty
by the Central Government at the time of dispatching the goods from their premise. However, when a
retailer sells the end products to consumers, the goods attract VAT governed by the laws of the state
where the goods are being sold.
VAT rates differ from state to state adding to the complexity and making certain product more attractive
to procure in certain states compared to others. Also the retailer will not be able to avail any input credit
against the incoming excise duty paid by him earlier on the purchase of the goods. In such a case, the
incoming excise duty will be added on to the cost of the product making it more expensive for the end
consumer.
Let us now consider the same scenario in the GST regime. GST (central and state component) will be
collected at each point of sale irrespective of the nature of transaction be it from a manufacturer to a
retailer or from a retailer to the end user.
GST will be levied on the transaction cost and in the case of sale from manufacturer to retailer, the CGST
and SGST levied will be available as input credit for the retailer while selling the goods to the end user.
This means that the retailer will be liable to pay tax only to the extent of the value added by him to the
goods value. This in turn will mean reduced burden of taxes on the end consumer due to avoiding of
double taxation on the goods.
12
The above illustration demonstrates the tax levy, collection and set off mechanism in the existing tax
regime, wherein input excise duty cant be set off against output VAT and hence the excise duty adds to
the product cost during the value change and burdens the product cost for the end consumer.
In the GST era however since each of the above transactions will attract CGST and SGST component
which will be set off against the output CGST and SGST component, the product will be taxed only on
the value addition carried out at each step of the value change.Hence, double taxation of the product will
be avoided, thereby reducing the taxation burden on the end consumer.
13
B. Service Industry
Services covers a wide gamut of activities like trading, banking & finance, infotainment, real estate,
transportation, security, management & technical consultancy among several others. The various sectors
that combine together to constitute service industry in India are:
Trade
Hotels and Restaurants
Railways
Other Transport & Storage
Communication (Post, Telecom)
Banking
Insurance
Dwellings, Real Estate
Business Services
Public Administration; Defence
Personal Services
Community Services
Other Services
There was marked acceleration in services sector growth in the past two decades, with the growth being
the fastest in communications, banking, hotels and restaurants, community services, trade and business
services.
Service Tax is a form of indirect tax imposed on specified services called "taxable services". Service tax
cannot be levied on any service which is not included in the list of taxable services. Service Tax was first
brought into force with effect from 1 July 1994. Over the past few years, service tax been expanded to
cover new services. The objective behind levying service tax is to reduce the degree of intensity of
taxation on manufacturing and trade without forcing the government to compromise on the revenue
needs.
In the current tax regime, service tax is applicable on the sale of taxable services. The service provider is
liable to pay the output service tax to the government while the customer can use the input service tax
credit to pay off his output service tax liability or output excise duty payable. Service tax credit can be
used to pay off output excise duty payable and vice versa.
14
In cases of manufacturers having different units spread over various parts of the country, invoice for input
services can be received by the head office (or corporate office/ registered office), while the services are
actually rendered in the factories or premises of the service provider.
Similarly, in the case of services which are not specific for any particular factory or premises, such as
advertising, market research, management consultancy, the invoices may be received directly at the
head office. The head office will then need to distribute or transfer the service tax credit availabed to its
manufacturing locations and/or other taxable service providing units.. Such offices of the manufacturer or
service provider are designated as input service distributor (ISD) under rule 2(m).
Service provider
Value : 1000
Ser. Tax:12%
+ 120
ISD
Customer
Ser. Tax:
20
Value : 200
Ser. Tax:12%
+ 24
Ser. Tax:
100
Value : 2000
Ser. Tax:12%
+ 240
Mfg Plant
Tax Incidence:
A service provider is liable to pay service tax to the government as soon as he receives payment from
customer (in part or full) whereas the input credit is available to a service receiver as soon as he makes
payment to the vendor to the extent of amount paid.
(a) Input Credit on full payment of vendor invoice
(b) Output Tax payable on part / full receipt from Customer
This was true till the Union budget announcement of 2011- 2012 wherein a change in the service tax
rules was made. With the introduction of the amendments to the service tax regulations, from 1st April
2011, the point of taxation for service tax and availability of service tax credit will be determined in the
following manner:
15
Point of Taxation:
Rule 3 has been amended to provide that the point of taxation shall be whichever is earlier from the
following:
(a) Date of invoice or payment, whichever is earlier, if the invoice is issued within the prescribed period
of 14 days from the date of completion of the provision of service.
(b) Date of completion of the provision of service or payment, if the invoice is not issued within the
prescribed period as above.
Illustration of applicability of this rule:
S.No.
Date of
completion
of service
Date of
invoice
Payment
Receipt
Date
Point of
Taxation
10-Apr-11
20-Apr-11
30-Apr-11
20-Apr-11
10-Apr-11
26-Apr-11
30-Apr-11
10-Apr-11
10-Apr-11
20-Apr-11
15-Apr-11
15-Apr-11
26-Apr-11
April 5,
2011 (part)
and April
25, 2011
(remaining)
April 5, 2011
and April 10,
2011 for
respective
amounts
10-Apr-11
Remarks
In case of Continuous Supply of Services, the Rule 6 relating to continuous supply of service has been
aligned with the revised rule 3 and the date of completion of continuous service has been defined within
the rule. This date shall be the date of completion of the specified event stated in the contract which
obligates payment in part or whole for the contract.
For example, in the case of construction services if the payments are linked to stage-by-stage completion
of construction, the provision of service shall be deemed to be completed in part when each such stage
of construction is completed. Moreover, it has been provided that this rule will have primacy over rules 3,
4 and 8.
While the rules shall come into force from 01.04.2011, an option has been given in rule 9 to pay tax on
payment basis, as at present, till 30.06.2011.
16
CENVAT Credit:
The CENVAT credit on input services can be availed on receipt of invoice. However, the payment has to
be made within three months. If the payment is not made within three months, then the credit availed has
to be reversed/paid. However the same can be taken back as credit on making payment. In case of
service tax paid by the recipient of service on reverse charge basis, the credit can be taken on making
payment of the value of service to the service provider and service tax to the Government. This is
effective from 01.04.2011 irrespective of the fact that the service provider may continue to pay service
tax on receipt basis.
GST impacts:
The proposed Goods and Service Tax will lead to the evolutoin of an efficient and harmonized
consumption tax system in the country. Presently, there are parallel systems of indirect taxation at the
Central and State level. Successful integration of goods and service tax, would give India a world-class
tax system and will bring in improved tax collection. It will also end the long standing distortions of
differential treatments to the manufacturing and service sectors.
For example, after the introduction of GST, a retailer can set off the input credit of CGST and SGST on
procurement of services like rentals, freight, advertisement, which currently attract service tax, against
the output tax levied on the sales of goods from his premise.
Currently such services attract service tax and this input service tax credit cant be used to pay off output
tax such as VAT. Since in the current tax regime, output VAT can be only be set off by utilising the input
VAT, the input service tax becomes a cost in the system and results in increased cost for the end
products being sold to consumers. With the introduction of GST, the issue of inability to offset the input
taxes should get resolved.
17
At the same time going deeper into the operational ends of the business processes, the impact on application
systems being the backbone cant be ignored. In other words, GST will also bring in a significant change in
the application systems design and modeling, which will be required in order to sustain the existing business
processes and enable the changes brought in.
In the context, heres an attempt to highlight some of the Impact areas and concerns with respect to GST as
shared by the organizations having operations in that area. The subsequent sections look at the different
areas of impact for industries / businesses.
18
Registration Applicability:
In the GST regime, all business entities with annual aggregate turnover of goods and services exceeding
Rs.10 lakh (excluding CGST and SGST) need to mandatorily register and obtain a GST registration number.
Small dealers (including service providers) and manufacturers should be exempted from the purview of both
CGST and SGST if their annual aggregate turnover (excluding both CGST and SGST) of all goods and
services does not exceed Rs.10 lakh. Those below the threshold limit may voluntarily opt to register.
The 13th Finance commission has recommended that the threshold exemption limit should be uniform for
both CGST and SGST and across states. At present as well, theres a separate threshold for services (Rs.
10 lakh) and goods (Rs. 1.5 crore) for Service Tax and CENVAT and also the VAT thresholds vary from state
to state.
19
The last two digits in the illustration KA denote the state code for Karnataka. The GST registration number
for a person having operations in multiple states will have the same prefix of the PAN number which is
unique for the person and for each state where he has operations and needs to remit SGST, the GST
registration number will be suffixed with the respective state code.
The unit of taxation for the purposes of GST should be persons as defined under the Income Tax Act.
Consequently, for the purposes of CGST, all production units/branches of a person located anywhere in the
country will be treated as a single taxable entity eligible for CGST input credit across units/branches.
Similarly, for the purposes of SGST, all production units/branches of a person located anywhere within the
State will be treated as a single taxable entity eligible for SGST input credit across units/branches in that
State.
From application software prospective, this would also mean that there is a need to uniquely identify the
entity at the transaction level so that the reporting can be done appropriately. The system should have the
capability to distinguish the origin and destination state during each business process (like procurement,
sales, stock transfer etc) so that at the time of reporting, it is able to classify under which GST registration
number this transaction needs to be reported.
For example, in case of a sale of a goods within Karnataka, the application software used to generating
invoices and reporting purpose, must be able to determine and capture the state to which the SGST is to be
remitted and accordingly while reporting for the GST registration number corresponding to the Karnataka
state, it should report this sales of goods.
* Rates are only for illustration. Final GST rates have not yet been fixed by the government
20
Clarifications sought:
1. Has the recommendation from the 13th Finance commission of having a 12 digit alpha numeric GST
registration number which is suffixed with a 2 digit state specific code been accepted?
2. Will Small Scale Industries (SSI) exemptions continue to exist?
3. How will Large Taxpayer Units (LTU) be handled? For large units under LTU, would there be a single
registration for all the states as well as for CGST?
4. How will the treatment of procurement and sales vary if its from a non GST registered vendor or to a
non GST registered customer?
5. Will the accumulation of input credits and payables be at the Registration level? Will all reporting be
at the Registration level?
6. Will all the entities belonging to a company in a state have the same GST registration number? For
example, if a company has a plant, a depot and a retailing outlet in the same state, will the same
GST registration number be applicable for each of these entities. Will the GST credit accumulation
and the returns be required to be filed at the entity level or at the GST registration level at the state
level?
21
22
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Raw Material and Tax-Code for
Excise Tax + VAT.
b) Goods are delivered at buyers premises and Goods receipt is carried. This will update the RM stock
and RG23A Part -1 register with quantity of material receipt accepted.
c) Excise Invoice is then captured in the system either with GR or explicitly, depending on the
configuration. RG23A Part -2 register will also get updated with Input Excise Credit booked for each
duty component.
d) Supplier invoice received is then captured, booking the vendor payable clearing the Cenvat Account
and booking VAT credit.
e) Vendor due payment is done to clear the account payables.
GST Scenario:
Under GST era, in case of domestic procurement of goods within the same state, the applicable indirect
taxes will be CGST and SGST. The vendor will issue an invoice charging the CGST and SGST components
as tax. The purchaser will claim credit of the CGST and SGST paid to the vendor by him.
Let us consider an example of sales of raw material used in manufacturing:
A factory in Karnataka raises an order of 100 pieces of steel rods used for manufacturing from a vendor in
the same state. The vendor receives the order and dispatches the steel rods to the factory. He then issues
an invoice for the steel rods.
Invoice details:
Steel Rods @ Rs 550 per piece = Rs 55, 000 for 100 pieces
CGST @ 8 %* = Rs 4400 / SGST @ 6%* = Rs 3300
Final invoice amount = Rs 62,700/* Rates are only for illustration. Final GST rates have not yet been fixed by the government
The purchaser will have to pay the vendor Rs 62,700/- towards the goods and taxes. He will get the following
CGST and SGST credit:
CGST credit = Rs 4400
SGST credit = Rs 3300
The vendor will have a CGST payable of Rs 4400 and SGST payable of Rs 3300 to the government.
However, he will actually pay a CGST and SGST payable only on the value addition after adjusting the
CGST and SGST credits he received on the input side.
23
Clarifications sought:
1. It needs to be clarified at what point the purchaser become eligible for the credit of CGST and SGST.
Would the purchaser be allowed to take the CGST and SGST credit once he receives the GST
invoice from the vendor (as is the case with CENVAT currently) or will it be at the time of making the
payments to the vendor (deferred tax concept which existed for service tax).
2. Proof of credit: Would commercial invoices act as proof of Input tax credit. Or would there be a
separate tax invoice like excise invoice? Will Excise Invoice continue?
3. Would the purchaser need to maintain registers for tracking the CGST and SGST credit, similar to
the RG23 registers maintained for CENVAT credit?
4. Does the purchaser need to record SGST credit accumulated from different states in different
registers since the SGST will be state specific?
5. Would the CGST and SGST collected by the vendor have to be paid to a common tax authority
present in the state or would this have to be remitted to different authorities one specific to the
state and one central authority?
6. Will there be any difference in treatment of raw material, capital goods and finished goods in the
procurement process or reporting process?
7. For capital goods, will the rule of only 50% of credit being available in the first year of purchase still
hold good for CGST and SGST?
8. Will Daily Stock Account (RG1) and RG23 Registers still be valid?
9. Will input credit be available for First Stage Dealers?
10. Evaluated Receipt Settlements: In this case invoices are not raised by the vendor. How can this be
addressed?
24
II.
25
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Raw Material and Tax-Code for
Excise Tax + CST.
b) Goods are delivered at buyers premises and Goods receipt is carried out. This will update the RM
stock and RG23A Part -1 register with quantity of material receipt accepted.
c) Excise Invoice is then captured in the system either with GR or explicitly, depending on the
configuration. RG23A Part -2 register will also get updated with Input Excise Credit booked for each
duty component.
d) Supplier invoice received is then captured, booking the vendor payable clearing the Cenvat Account.
e) Vendor due payment is done to clear the account payables.
GST Scenario:
In case of inter-state domestic procurement of goods the IGST model for taxation will be applicable.
As per the IGST model, the center will levy IGST on all inter-State transactions of taxable goods and
services. IGST will be computed as CGST plus the SGST component of the destination state.
26
Central agency will act as clearing house mechanism and be responsible for monitoring and
verifying credit movements and accordingly inform respective Government authorities to transfer
funds.
The purchaser will have to pay the vendor Rs 62,700/- towards the goods and taxes. He will get the
following IGST credit in Karnataka:
IGST credit = Rs 7700
The purchaser can use this IGST to set off his output tax liability in Karnataka.
The vendor will have a IGST payable of Rs 7700 to the Center. However, he will actually pay a IGST
payable only on the value addition after adjusting the IGST, CGST and SGST credits he received on
the input side.
27
Clarifications sought:
1. Would the IGST rate differ from state to state based on the destination state regulations or would
there be a common IGST rate defined for goods / services which will be applicable in case of any
inter-state transactions?
2. What is the information required to be submitted by any organization to ensure that IGST credit
can be taken and at what frequency?
3. When would the purchaser in the importing state be availing the input credit on the IGST paid?
4. Will the procedure related to road permits/ way bills be discontinued?
5. Would C forms / F forms no longer be applicable?
6. Would there be an introduction of a centralized tool which will allow for tracking of IGST credit
transfer between states? Would there be a provision for end-users to track the status of credit
transfer in case of inter-state transactions through such a tool? Would the document submission
for this tool be in the form of a e-file?
7.
In case of a inter-state transaction, would the vendor selling out of state need to maintain a
separate register for such transactions? Would the inter-state transactions need to be reported
separately by the vendors and would there be any difference in the IGST payment to the tax
authority from the normal SGST payment?
8. Would separate reporting / book keeping for inter-state transactions (New register)be required?
9. Can SGST Input credit be used to utilize IGST payable?
10. Destination plant/customer takes full credit of IGST. If he does not have output IGST, can this be
utilized against SGST payable?
11. If all states do not move to the GST regime, how will inter state sales/transfer between GST and
Non GST states be managed?
28
III.
29
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Capital and Tax-Code for Excise Tax
(CG).
b) Goods are delivered at buyers premises and Goods receipt is carried out. This will update the CG
stock and RG23C Part -1 register with quantity of material receipt accepted.
c) Excise Invoice is then captured in the system either with GR . RG23C Part -2 register will also get
updated with x% Input Excise Credit booked for each duty component. Whereas the balance x%
Credit will be posted to Cenvat on Hold A/c and will not be available for set-off in the current financial
yr.
d) Supplier invoice received is then captured, booking the vendor payable and clearing the Cenvat
Account.
e) Vendor due payment is done to clear the account payables.
f)
Subsequent Credit can be availed in the next financial year. This will transfer the x% credit on hold to
input credit A/c.
GST Scenario:
Under GST era, in case of domestic procurement of capital goods, the applicable indirect taxes will be CGST
and SGST, in case of intrastate procurement and IGST, in case of interstate procurement. The CENVAT
credit rules in case of capital goods state that the purchaser can avail only upto 50% of the input credit during
the first year of purchase of the capital good. The remaining credit can only be availed in the next year
onwards.
The 13th Finance commission however recommends that there should be no difference between the
treatment of raw material and capital goods in terms of the input credit in the GST regime.
Clarifications Sought:
1. Will input credit arising out of capital goods be treated the same as the input credit from raw material,
i.e., the entire input credit can be used for setoff during the first year of purchase itself?
2. Will there be no need to maintain separate registers for raw material and capital goods stock and
credit account like the existing RG23A/ RG23C Part 1 and RG23A/ RG23C Part 2 registers?
30
IV.
31
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Service Material and Tax-Code for Service Tax.
b) Services are rendered at buyers premises and Service Receipt is carried out . This will book the
service expense with the amount of service accepted.
c) Service Invoice is then received for the service s rendered and will be captured in the system,
debiting the Service tax applicable to an interim a/c and SR/IR Clg a/c . Vendor payable are also
credited for payment.
d) Vendor due payment is done to clear the account payables.
e) After the service payment only service tax paid will be transferred from interim a/c to service tax final
a/c and made available as input credit. ST credit will not be transferred unless full payment is done to
the service provider
GST Scenario:
In the GST regime, the applicable taxes on the procurement of services will be CGST and SGST instead of
the prevalent Service tax. In the case of inter-state procurement of services, IGST (CGST + SGST) will be
applicable and in case of imports of services, CGST and SGST will be applicable.
The vendor will issue an invoice charging the CGST and SGST components as tax and the purchaser will
claim credit of the CGST and SGST paid to the vendor by him.
Let us consider an example of a domestic intrastate provision of services:
A company in Karnataka requests for auditing services from a Chartered Accountancy firm. The audit is a
onetime service which the accountancy firm will be providing to the company. The firm provides the service
and raises an invoice for the same
Invoice details:
Auditing Service @ Rs 5000 per hour = Rs 50, 000 for 10 hours
CGST @ 8 %* = Rs 4000
SGST @ 6%* = Rs 3000
Final invoice amount = Rs 57,000/* Rates are only for illustration. Final GST rates have not yet been fixed by the government
The purchaser will have to pay the vendor Rs 57,000/- towards the provision of the service. He will get the
following CGST and SGST credit:
CGST credit = Rs 4000
SGST credit = Rs 3000
The vendor will have a CGST payable of Rs 4000 and SGST payable of Rs 3000 to the government. He can
however adjust the input tax credit of CGST and SGST against his output tax liability.
32
Clarifications Sought:
Determination of origin and destination state in case of provision of Service:
1. In case of a scenario where the service provider and recipient are from the same state but service
provider engages 3rd party from a state. Will this be deemed as an inter-state transaction? How
would the credit distribution happen?
2. Consider the following scenarios extending to the example mentioned above:
3. If the company is in Karnataka and the Chartered Accountancy firm is also Karnataka, however the
CA firm hires external consultants from Maharashtra to complete the service. In such a case, will this
transaction be an inter-state transaction?
4. If the company is headquartered in Karnataka and the Chartered Accountancy firm is in Andhra
Pradesh, however the CA firm hires external consultants from Maharashtra to complete the service.
Which of the two states, Andhra Pradesh or Maharashtra, will be considered as the origin state?
5. In case of agreement contracts for services, will the SGST be from the state where the agreement
was executed or from the state where the services will be provided, in case the two states are
different?
6. Consider the following scenarios extending to the example mentioned above:
7. If the company is headquartered in Karnataka and the Chartered Accountancy firm is also Karnataka,
but the service is required to be provided in the companys office in Kerala. Considering that the
payment is being made from the headquarters in Karnataka, will this be considered as an inter-state
or intra-state transaction?
8. If the company is headquartered in Karnataka and the Chartered Accountancy firm is in Maharashtra,
but the service is provided by the firms external consultants situated in Kerala to the companys
office in Kerala. Considering that the payment is being made from the headquarters in Karnataka,
which of these states will be origin state and which will be the destination-state?
33
V.
34
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Raw Material and Tax-Code for
Excise Tax.
b) Custom Duty needs to be paid on Goods Arrival before the goods receipt at the premises.
Commercial Invoice is captured in system for such customs duty payment to authorities, debiting the
CD and CVD Clg a/c against custom Duty payable A/c . Such payable gets cleared when the
payment is done by the buyer.
c) Goods are delivered at buyers premises and Goods receipt is carried out. This will update the RM
stock and RG23A Part -1 register with quantity of material receipt accepted. The customs duty paid
will be inventorized.
d) Excise Invoice is then captured in the system either with GR. RG23A Part -2 register will also get
updated with Input CVD Credit booked.
e) Supplier invoice received is then captured, booking the vendor payable and clearing the Cenvat
Account.
f)
GST Scenario:
All goods imported into India have to pass through the procedure of Customs clearance as they cross Indian
border. The goods are examined, appraised, assessed, evaluated and then allowed to be taken out of charge
of the Customs for use by the importer at the port of entry.
In the GST regime, both CGST and SGST will be levied on import of goods and services into the country.
The incidence of tax will follow the destination principle and the tax revenue in case of SGST will accrue to
the State where the imported goods and services are consumed. Full and complete set-off will be available
on the GST paid on import on goods and services.
The importer will need to pay the CGST and SGST components as tax and he will be able to avail input
credit on the entire CGST and SGST paid.
Let us consider an example of import of microchips from Korea to India:
An importer in Karnataka raises an order of 100 pieces of microchips from a foreign vendor in Korea. The
foreign vendor receives the order and dispatches the microchips to India via ship. The port of entry into India
is Bombay in Maharashtra state. The foreign vendor issues an invoice of the following amount:
Invoice details:
Microchips @ USD 20 per piece = USD 2000 for 100 pieces
Final invoice amount = USD 2000/At the port of entry, the following duties are charged by Indian government as imports duty:
CGST @ 8 % of goods value = Rs 8000 (exchange rate at Rs 50 per USD)
35
The purchaser will have to pay the vendor USD 2000 towards the payment of the goods and Rs 14,000 as
imports duty to the Indian government. He will get the following CGST and SGST credit:
CGST credit = Rs 8000
SGST credit = Rs 6000
The importer will get the credit of Rs 6000 as input credit in the state of Karnataka since the SGST is
collected by Karnataka which is the state where the goods are finally consumed and not in Maharashtra
where the goods are received into India.
Clarifications sought:
1. Would the basic duty of customs (BCD) still remain? Would the Education Cess and Secondary and
Higher Education Cess applicable in case of imports still exist separately on the CGST and SGST or
would these be included in the CGST and SGST?
2. What will happen to the imports processes such as DEPB, EPCG? Will there be provision of advance
licenses like the ones existing for exempting CVD and SAD?
3. Import of Services: Will Reverse charge continue for Imports?
36
4. Would the appropriate state for collecting SGST on imports be the state where the goods are cleared
or the state where the goods are consigned for ultimate use or trading?
5. Would there be a case where SGST would be applicable based on the state of the port and then
IGST will be applicable in the transfer between the state of the port and the final destination state?
6. What will be the reporting requirements specific for imports process?
7. Will the importer need to maintain a separate register/ books for imports?
8. What will be the proof for taking credit for CGST and SGST? Will there be a GST invoice issued by
the customs department or will there be any other document issued in case of imports with reference
to which the credit of CGST and SGST can be taken?
37
38
Process Overview:
a) Create Sales order with Non- exempt Customer for Excisable Raw Material and Tax-Code for Excise
Tax + VAT.
b) Goods are delivered from buyers premises and Goods Issue is carried out. This will update the RM
stock and RG23A Part -1 register with quantity of material Issued.
c) Customer invoice is then created, booking the Sales Revenue , Customer receivable and VAT and
Excise Payable. Excise Invoice can be posted in background or explicitly. RG23A Part -2 register will
also get updated with Excise Credit (immediate utilization).
d) Customer Receivable gets cleared on receipt of payment from customer.
GST Scenario:
In case of domestic sales of goods within the same state, the applicable indirect taxes will be CGST and
SGST. The vendor will issue an invoice charging the CGST and SGST components as tax. The vendor will
be liable to pay the CGST and SGST collected. The SGST must be remitted to the same state as the origin
and destination state are the same.
Let us consider an example of sales of raw material used in manufacturing:
A vendor in Karnataka receives an order of 100 pieces of steel rods used for manufacturing from a factory in
the same state. The vendor receives the order and dispatches the steel rods to the factory. He then issues
an invoice for the steel rods.
Invoice details:
Steel Rods @ Rs 550 per piece = Rs 55, 000 for 100 pieces
CGST @ 8 %* = Rs 4400
SGST @ 6%* = Rs 3300
Final invoice amount = Rs 62,700/* Rates are only for illustration. Final GST rates have not yet been fixed by the government
The vendor will have a CGST payable of Rs 4400 and SGST payable of Rs 3300 to the government.
However, he will actually pay a CGST and SGST payable only on the value addition after adjusting the
CGST and SGST credits he received on the input side. Assuming he had bought raw material (steel) to make
the steel rods and had the following input credit:
CGST credit = Rs 1000
SGST credit = Rs 750
Hence after carrying out the input credit setoff, he would pay the government:
CGST payable = Rs 4400 Rs 1000 = Rs 3300
SGST payable = Rs 3300 Rs 750 = Rs 2550
39
Clarifications Sought:
1. Would the CGST and SGST payable be due for payment once the invoice has been generated?
2. Would the tax payment be monthly?
3. Would there be a need to maintain a PLA register for payment of excessive payable amounts in case
of insufficient input credits available for set-off?
4. Will TR6C challan still be required? If not, what would be the new mode of payment?
5. Document Numbering- Would there be multiple document numbers required for CGST and SGST or
would it be a single document number?
6. VAT Numbering: What would be the new numbering rules for Intra State and inter state transactions?
40
II.
41
Process Overview:
a) Create Sales order with Non- exempt Customer for Excisable Raw Material.
b) Goods are delivered from buyers premises and Goods Issue is carried out. This will update the RM
stock and RG23A Part -1 register with quantity of material Issued.
c) Customer invoice is then created, booking the Sales Revenue , Customer receivable and VAT and
Excise Payable. Excise Invoice can be posted in background or explicitly. RG23A Part -2 register will
also get updated with Excise Credit (immediate utilization).
d) Customer Receivable gets cleared on receipt of payment from customer.
GST Scenario:
In case of inter-state domestic sales of goods the IGST model for taxation will be applicable. As per the IGST
model, the center will levy IGST on all inter-State transactions of taxable goods and services. IGST will be
computed as CGST plus the SGST component of the destination state.
The IGST model will work in the following way:
The Centre will levy an IGST (rated at the combined Central GST plus State GST rates) on all interstate transactions of goods and/or services with appropriate provisions to be made for consignment
or stock transfer of goods.
Inter-state vendor would levy the IGST (CGST + SGST) on inter-state transactions involving sale of
goods
The exporting vendor will have to pay IGST on value addition after adjusting available input tax credit
of IGST, CGST, and SGST.
Exporting State will transfer to the Central Government the amount of SGST credit utilized by the
inter-state vendor to discharge output IGST liability in that State.
Importing purchaser will claim the input tax credit of the IGST in his own state by adjusting this credit
against his output liability.
Central Government would accordingly transfer the amount of IGST used in payment of SGST to the
account of importing State; and
Central agency will act as clearing house mechanism and be responsible for monitoring and verifying
credit movements and accordingly inform respective Government authorities to transfer funds.
Let us consider an example of sales of raw material used in manufacturing:
A vendor in Madhya Pradesh receives an order of 100 pieces of steel rods used for manufacturing from a
factory in Karnataka. The vendor receives the order and dispatches the steel rods to the factory. He then
issues an invoice for the steel rods.
42
Invoice details:
Steel Rods @ Rs 550 per piece = Rs 55, 000 for 100 pieces
IGST = CGST + SGST = Rs 7700
(CGST @ 8 %* = Rs 4400 and SGST @ 6%* = Rs 3300)
Final invoice amount = Rs 62,700/* Rates are only for illustration. Final GST rates have not yet been fixed by the government
The vendor will have a IGST payable of Rs 7700 to the Center. However, he will actually pay IGST payable
only on the value addition after adjusting the IGST, CGST and SGST credits he received on the input side.
Assuming he had bought raw material (steel) to made the steel rods and had the following input credit:
CGST credit = Rs 1000, SGST credit = Rs 750
Hence after carrying out the input credit setoff, he would pay the government:
IGST payable = Rs 7700 Rs 1750 = Rs 5950
The SGST payable equivalent will be transferred to the destination state, i.e., Karnataka by the Center /
clearing house.
Clarifications Sought:
1. Would there be an introduction of a centralized tool which will allow for tracking of IGST credit
transfer between states? Would there be a provision for end-users to track the status of credit
transfer in case of inter-state transactions through such a tool?
2. Would the document submission for this tool be in the form of a e-file?
43
3. In case of a inter-state transaction, would the vendor selling out of state need to maintain a separate
register for such transactions? Would the inter-state transactions need to be reported separately by
the vendors and would there be any difference in the IGST payment to the tax authority from the
normal SGST payment?
4. Can SGST Input credit be used to utilize IGST payable?
5. Would separate reporting / book keeping for inter-state transactions (New register)be required?
6. Destination customer takes full credit of IGST. If he does not have output IGST, can this be utilized
against SGST payable?
7. If all states do not move to the GST regime, how will inter state sales between GST and Non GST
states be managed?
8. Will Sales return also have IGST as applicable?
44
III.
45
Process Overview:
a) Create Sales order for Service Material and Tax-Code for Service Tax.
b) Services are rendered at buyers premises and Service acceptance is carried out.
c) Service Invoice is then raised for the service s rendered. This books the Service revenue and Service
tax payable.
d) Customer Receivable gets cleared on receipt of payment from customer.
GST Scenario:
In the GST regime, the applicable taxes on the sale of services will be CGST and SGST instead of the
prevalent Service tax. In the case of inter-state sale of services, IGST (CGST + SGST) will be applicable and
in case of exports of services, GST will be zero-rated.
The vendor will issue an invoice charging the CGST and SGST components as tax and the purchaser will
claim credit of the CGST and SGST paid to the vendor by him.
Let us consider an example of a domestic intrastate sale of services:
A Chartered Accountancy firm in Karnataka receives a request for auditing services from a company. The
audit is a onetime service which the accountancy firm will be providing to the company. The firm provides
the service and raises an invoice for the same.
Invoice details:
Auditing Service @ Rs 5000 per hour = Rs 50, 000 for 10 hours
CGST @ 8 %* = Rs 4000
SGST @ 6%* = Rs 3000
Final invoice amount = Rs 57,000/* Rates are only for illustration. Final GST rates have not yet been fixed by the government
The vendor will have a CGST payable of Rs 4000 and SGST payable of Rs 3000 to the government. He can
however adjust the input tax credit of CGST and SGST against his output tax liability.
Clarifications Sought:
Point of Taxation:
1. Point of Taxation is defined as the point at which the service tax payable liability is to be created. At
present, the point of taxation for service tax is defined as the following:
2. Date of invoice or payment, whichever is earlier, if the invoice is issued within the prescribed
period of 14 days from the date of completion of the provision of service.
46
3. Date of completion of the provision of service or payment, if the invoice is not issued within
the prescribed period as above.
4. In the GST regime, what will be the point of taxation during the sales of services?
5. Will the point of taxation for goods and services differ?
6. Will it be mandatory for service providers to record the date of provision of service for audit purpose?
Will there be a need for a separate register to track the provision of service?
7. What will be the reporting requirements for sale of service?
47
IV.
Export Sale of Goods / Materials refers to the process of sale of goods by a business organization
(Manufacturing entity, Depot etc.), wherein buying organization reside in different Country. Any such
transactional movement of excisable goods is levied with Excise tax.
However Manufacturing plants are entitled not to pay any basic excise duty on export sales, as long as
the goods are accompanied by required documentation (ARE forms linked to Excise Bonds issued by
Excise Authorities) as per the central excise legislation. An excise bond covers a fixed amount of excise
duty. The excise duty of the goods exported under bond cannot exceed the bond value.
If the Excise Bond cannot be obtained, the any excise duty liable when removing goods from your
premises for export must be paid. However, manufactured can claim a rebate for the excise duty once
you have completed the export if you fill out an ARE-1 to go with the export. In order to qualify for a
rebate on the excise duty, all exports must be accompanied by the appropriate paperwork, including an
ARE-1 document, and you must complete the export within the export period.
A sale of goods, in India, to a company that qualifies as an export-oriented unit or is located in one of the
following:
Export processing zone
Electronic hardware technology park
Software technology park
is termed as Deemed Export. Such companies export most of their goods; and so any goods that you
sell them are liable to be used in the production of goods for export, hence the term "deemed export."
Under the terms of the deemed exports scheme, these companies can obtain licenses that exempt them
from payment of basic excise duty on certain input materials. In order to qualify for an exemption from
excise duty, all deemed exports must be accompanied by the appropriate paperwork, including an ARE-3
document, and you must complete the deemed export within the re-warehousing period.
Lets take the scenario of Exports under Excise Bond, wherein Excise duties to the extent of Bond are
not payable to the authorities for an export sale.
48
Process Overview:
a) An Excise Bond is obtained from the Excise Authorities and Entered into the System for the purpose
of tracking and monitoring of the Export sales under the same.
b) Create a Sales Order with excisable material and with customer abroad (Ship to party outside the
country).
c) Good Delivery is carried out, with appropriate treatment to stock. ARE -1 document is then created
with the details of goods being delivered and corresponding reference to the Bond created in step (a)
is given.
49
d) Once ARE-1 document is posted corresponding Bond value get reduced by the export value.
e) An Excise invoice is also created and posted with type Under Bond with the details on goods
exported and the duties involved. Exports under bond are not subject to excise duty and thus do not
attract any excise taxes. Even though the excise duty is zero, when you print the excise invoice, the
system calculates the duty for the purposes of printing.
f)
Commercial Invoice / Billing document is then posted booking the Account receivables.
g) Receivables get cleared once the payment is received from the customer.
GST Scenario:
In the GST regime, all goods and services exported out of India will be zero-rated, i.e., no tax would apply on
exports, and the input credit relatable to such export supplies would be allowed to be used against other
domestic liabilities or refunded.
Treatment of SEZs:
The discussion paper stated that supply of goods and provision of services, to processing zones in a Special
Economic Zone (SEZ) would be zero rated. However, sales of goods and provision of services by a SEZ to
Domestic Tariff Area will be liable to GST.
The 13th Finance commission however recommends that there should be no such exemptions in SEZs.
Clarification Sought:
1. How will the SEZs currently having exemptions from central excise, CST, service tax and VAT be
treated in terms of GST applicability? What will be the status of all the exemption schemes available
for exports?
2. Would there no longer be exemptions for SEZs and EOUs? Will there be a refund process applicable
in these scenarios?
3. In case of taxes paid on exports will be refunded, what will be the refund mechanism? Will there be a
report which needs to be filed specifically for export transactions?
4. What will happen to the credit availed on GST paid on inputs for deemed export supplies?
5. Would ARE1 and ARE3 continue?
6. Would IGST be applicable for deemed exports?
7. Since exports will be zero-rated, will the concept of bond cease to exist in the GST regime?
50
D. STOCK TRANSFERS
Whenever there is movement of excisable goods excise duty needs to be paid to the kitty of the Government.
To facilitate the payment of Excise Tax, calculation and determination of Excise Tax needs to be carried out.
Stock transfers from one Manufacturing Location (Plant 1) to another (Plant 2) involve movement of goods
and is subject to excise tax payment. The same is passed to the receiving plant and can be utilized as input
credit.
51
Process Overview:
a) Create Stock Transfer order with respect to transfer of Excisable Raw Material, from Plant 1 to Plant
2.
b) Goods Issue is carried out at Plant 1 debiting the stock at Plant 1 and crediting the same at Plant 2
stock. Part-1 register is also updated with the quantity of stock transferred.
c) Excise Invoice is then issued for the Stock transfer posting the Cenvat payable RG23A Part -2
register will also get updated with Excise tax applicable.
d) Excise taxes are duly paid clearing the Cenvat Payable A/c.
e) Goods are then received at Plant- 2, with no accounting doc posted. Part -1 register gets updated
with Qty received.
f)
Incoming Excise Invoice gets captured, Part 2 register also gets updated with Input credit booked.
GST Scenario:
In case of domestic transfer of goods within the same state, the applicable indirect taxes will be CGST and
SGST. The transferring plant will issue an invoice charging the CGST and SGST components as tax. The
transferring plant will be liable to pay the CGST and SGST collected. The receiving plant will receive the
input credit for the CGST and SGST paid.
In case of inter-state transfer of goods, the IGST model for taxation will be applicable. IGST will be computed
as CGST plus the SGST component of the destination state.
Let us consider an example of transfer of raw material used in manufacturing from a plant A in Karnataka to
plant B also in Karnataka:
Plant A in Karnataka receives an stock transfer order of 100 pieces of steel rods used for manufacturing from
plant B in the same state.
GST Computation:
Assessable value of Steel Rods @ Rs 550 per piece** = Rs 55, 000 for 100 pieces
CGST @ 8 %* = Rs 4400
SGST @ 6%* = Rs 3300
* Rates are only for illustration. Final GST rates have not yet been fixed by the government
** Our assumption is that in case of Stock Transfer, CGST and SGST will be computed on the assessable
value of the goods however this needs to be confirmed.
The transferring plant will have a CGST payable of Rs 4400 and SGST payable of Rs 3300 to the
government. However, he will actually pay a CGST and SGST payable only on the value addition after
adjusting the CGST and SGST credits he received on the input side.
The receiving plant will receive an input CGST credit of Rs 4400 and SGST credit of Rs 3300.
52
Clarifications Sought:
1. In case of stock transfer, on what base would the tax be computed on? Would it be on the
assessable value?
2. Will an invoice need to be generated from the transferring plant in case of stock transfer? Will there
be a fixed format for this invoice? (like excise invoice, would there be a GST invoice?)
3. Document Numbering- Would there be multiple document numbers required for CGST and SGST or
would it be a single document number? Would invoice numbering be valid even for stock transfers?
4. Destination plant/customer takes full credit of IGST. If he does not have output IGST, can this be
utilized against SGST payable?
5. If all states do not move to the GST regime, how will inter state sales/transfer between GST and Non
GST states be managed?
6. Will Stock returns or Sales return also have IGST as applicable?
53
E. SUBCONTRACTING
Subcontracting refers to the process wherein Raw materials or components are sent out to a subcontractor
for processing and receiving them back. There are two main parties involved in the process an Mfg Plant and
a Subcontractor. Since this process involves the movement of goods from manufacturing premises, it
attracts the excise tax provisions under Cenvat rules.
However, Under Excise law, when you send materials to a subcontractor for processing, Excise duty
payment is not required, even though the materials have left the premises. However, if the materials have not
been returned back within a given length of time specified by the law (180 days), Excise Credit posted at the
time of purchase of such goods have to be reversed . A Re-Credit can be taken if the material is returned
later against the pending-challan.
54
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Raw Material and Tax-Code . Excise
tax applicable will be a condition type at the order.
b) Subcontracting Goods are then transferred from RM stock to Subcontracting stock, with reference to
PO created at step a..
c) Excise Invoice is then created and posted with reference to Transfer posting doc created at step b.
RG23A register will be updated with the Duties and qty of RM transferred to subcontractor.
d) ON receiving the goods from Subcontractor, Excise invoice is then captured w.r.t Subcontracting PO.
This will generate the Excise invoice no.
e) Goods Receipt is then carried out w.r.t the subcontracting PO and excise invoice no. is saved along
with material doc. This will also update the RM stock with the Material received. RG23A Part 1 is also
updated.
f)
Excise Invoice captured at step (d) is then posted with the duties involved. Part II register gets
updated with the Duties and the credit is available.
GST Scenario:
The discussion paper on GST does not explicitly describe how the subcontracting process will be impacted in
the GST era. Our assumption is that the existing subcontracting process, wherein a 57F4 challan is sent
along with the goods to the subcontractor and then the goods are reconciled against the challan upon
receipt, will no longer continue.
In the GST era, since CGST and SGST will be applicable for each transfer/ sale of goods, we assume that
the same will be applicable on subcontracting of goods. However this needs to be confirmed with the
authorities.
55
Clarifications Sought:
1. Will the 57F4 challan for subcontracting still be required to be sent along with the subcontracted
goods?
2. Will there be any specific report required for tracking of subcontracted goods?
3. Will the outgoing process from factory to subcontractor be treated as sales from factory with SGST
and CGST applicable?
4. Will the incoming process from subcontractor to factory be treated as procurement from vendor with
SGST and CGST applicable?
56
F. DEPOT OPERATIONS
I.
Process Overview:
a) Create Purchase order with Non- exempt Vendor for Excisable Raw Material and Tax-Code for
Excise Tax.
b) Goods are delivered at buyers Depot and Goods receipt is carried out.
57
c) Excise Invoice is then captured in the system updating RG23D register with Input Excise Credit
booked for each duty component.
d) Supplier invoice received is then captured, booking the vendor payable and clearing the Cenvat
Account.
e) Vendor due payment is done to clear the account payables.
II.
58
Process Overview:
a) Create Sales order with Non- exempt Customer for Excisable Raw Material.
b) Goods are delivered from buyers premises and Goods Issue is carried out. This will update the FG
stock and RG23A Part -1 register with quantity of material Issued.
c) Assign Excise Invoices to the O/b Delivery. RG23D Part -2 register will also get updated with Excise
Credit.
d) Customer invoice is then created, booking the Sales Revenue , Customer receivable and VAT and
Excise Payable.
e) Customer Receivable gets cleared on receipt of payment from customer
GST Scenario:
The discussion paper on GST does not explicitly describe how the depot operations will be impacted in the
GST era. However, since in the GST era, CGST and SGST will be applicable for each transfer/ sale of
goods, we assume that the same will be applicable on case of transfer or sale to depots. However this needs
to be confirmed with the authorities.
59
Clarifications Sought:
1. Will the depot concept (being tax neutral) still exist post-GST since GST will be applicable at each
step of consumption and will not differ based on manufacturing or trading activity?
2. In case the depot concept will not continue, will a warehouse/ depot be treated in the same manner
as a factory?
3. Can credit be passed on to depot and utilized henceforth?
4. Will there be a need to maintain a register similar to the RG23D register which tracks the stock in the
depot?
5. Will there be a need to link the depot excise invoices to the mother excise invoices received from
factories?
6. In case of price escalations at the factory, would the process of A certificate issue to depot still hold
good?
7. In case of inter-state stock transfer from factory to depot, would IGST be applicable instead of
SGST?
60
G. LEGAL REPORTING
Tax Reporting is an integral part of the business operations with respect to leagl compliance. As of today
following are few of the Legal Reports (Tax Returns) required to be submitted to the Tax Authorities or
kept for by organizations for audit purposes, as mentioned below:
ER1 return (vide Notification No.71/ 2003-Central Excise (N.T.) )
ST3 for service tax
RG23 Register Reports (RG23A/C Part 1 and Part 2, PLA, RG23D, RG1)
Proforma Register under Rule 9(5) of Cenvat Credit Rules 2004
VAT Returns (state-specific)
Depot Stock Register
Exports related reports:
Proforma of Running Bond Account
Statement regarding Export of Excisable Goods
Bond Summary Report
Deemed Export License Summary
Ageing Analysis for ARE documents
Clarifications Sought:
1. Since these reports are applicable under the Cenvat Credit Rules, would these reports still be
applicable in the GST regime?
2. Which reports will be legally required by the tax authorities in the GST regime? Will there be different
reports for the central tax authority and for the states?
3. Will there be different state specific formats for State reports?
4. Will there be a need to report different business processes such as inter-state transactions attracting
IGST, import transaction, exports transactions etc, separately?
61
Clarifications Sought:
1. Who will be eligible to file GST returns online?
2. Will there be a common Return for central GST and state GST or will there be separate returns for
each state?
3. Will all different business processes need to be reported separately while filing the return?(e.g. would
imports and exports have to be reported differently from domestic procurement and sales?)
4. Will there be separate filing required for business processes attracting IGST, SGST?
5. At what level will the filing be done? Will it be at the central registration number for an enterprise
having cross-state operations or would it be at each state level registration?
6. Will an acknowledgement be generated once the Return is successfully filed?
7. Will e-payment also be possible for the payable CGST, SGST to the government?
62
II.
Debit
Credit
1000
1000
204
204
204
120
1000
1324
1324
1324
Debit
Credit
1048
1048
204
204
204
1048
1252
1252
1252
63
III.
IV.
Debit
Credit
1000
1000
102
102
204
204
1000
60
60
1324
1324
1324
162
162
Debit
Credit
10000
10000
10000
1200
24
11224
11224
11224
64
V.
1200
24
1200
24
Debit
Credit
300
130
430
430
430
1300
1000
300
130
130
1000
1000
1000
1000
65
VI.
A Sales Order is raised for Material A for Qty = 1 PC, at the rate of Rs.1000 per Pc,
with applicable BED @ of 16%, SED @ 4% and ECess @ 2%., VAT @ 10%.
Accounting scheme:
Sr.No. Particulars
Goods Issue
1.
FG Stock A/c
2.
COGS A/c
Excise Invoice
1.
Cenvat Clearing A/c
4.
Cenvat Payable A/c
Customer Invoice / Billing
1.
Cenvat Clearing A/c
4.
VAT Payable A/c
5.
Sales Rev A/c
6.
Customer A/c
Customer Receipt
1.
Customer A/c
2.
Bank A/c
VII.
Debit
Credit
1000
1000
204
204
204
120
1000
1324
1324
1324
Debit
Credit
1000
1000
204
204
204
48
1000
1252
1252
1252
66
VIII.
Accounting scheme:
Sr.No.
Service
1.
2.
3.
Receipt
1.
2.
IX.
Particulars
Invoice
Customer A/c
Service Tax Payable A/c
Sales Revenue A/c
Customer A/c
Bank A/c
Debit
Credit
1122
122
1000
1122
1122
Accounting scheme:
Sr.No. Particulars
Invoicing
1.
Customer A/c
2.
CENVAT A/c
3.
Sales Revenue A/c
Receipt
1.
Customer A/c
2.
Bank A/c
Debit
Credit
1000
0
1000
1000
1000
67
X.
Stock Transfers
Example: STO (treated as sale) is raised for Material for Qty = 1 PC, at the rate of Rs.1000 per
Pc, with applicable BED @ of 16%, SED @ 4% and ECess @ 2%.
Accounting scheme:
Sr.No. Particulars
Goods Issue @ plant 1
1.
Plant 2 RM Stock A/c
2.
Plant 1 RM Stock A/c
Excise Invoice Issue
1.
Cenvat Clearing A/c(BED+SED+Cess)
2.
Cenvat Payable A/c
Excise Payment
1.
Cenvat Payable
5.
Bank A/c
Excise Capture at Plant - 2
1.
RG 23A Plant 2 A/c
4.
Cenvat Clearing A/c(BED+SED+Cess)
XI.
Debit
Credit
1000
1000
204
204
204
204
204
204
Subcontracting
Example: A Sub-Con PO is raised on Vendor for Material for Qty = 1 PC, at the rate of Rs.1000
per Pc, with applicable BED @ of 16%, SED @ 4% and ECess @ 2%.
Accounting scheme:
Sr.No. Particulars
Transfer Posting
1.
Subcontracting Stock A/c
2.
RM Stock A/c
Excise Invoice Create and Post
1.
Cenvat Clearing A/c
2.
Cenvat Payable A/c
Goods Receipt
1.
RM Stock A/c
2.
GR/IR Clg A/c
Capture and Post Subcontractors Excise Invoice
1.
Cenvat RG23A A/c
2.
Cenvat Clg A/c
Subcontractors Invoice Verification
1.
GR/IR Clg A/c
2
Cenvat Clg A/c
3
Vendor Payable
Debit
Credit
1000
1000
204
204
1000
1000
204
204
1000
204
1204
68
XII.
Depot Procurements
Example: A PO is raised on Vendor for Material for Qty = 1 PC, at the rate of Rs.1000 per Pc, with
applicable BED @ of 16%, SED @ 4% and ECess @ 2%.
Accounting scheme:
Sr.No.
Particulars
Goods Receipt
1.
RM Stock A/c
2.
GR/IR Clearing A/c
Excise Invoice Capture
1.
RG23 D BED A/c
2.
RG23D SED A/c
3.
RG23D ECess A/c
4.
Cenvat Clearing BED A/c
5.
Cenvat Clearing SED A/c
6.
Cenvat Clearing ECess A/c
Supplier Invoice Verification
1.
Cenvat Clearing BED A/c
2.
Cenvat Clearing SED A/c
3.
Cenvat Clearing ECess A/c
4.
GR/IR Clearing A/c
5.
Supplier Payable A/c
Supplier Payment
1.
Supplier Payable A/c
2.
Bank A/c
XIII.
Debit
Credit
1000
1000
160
40
4
160
40
4
160
40
4
1000
1204
1204
1204
Depot Sales
Example: A Sales Order is raised for Material A for Qty = 1 PC, at the rate of Rs.1000 per Pc, with
applicable BED @ of 16%, SED @ 4% and ECess @ 2%., VAT @ 10%.
Accounting scheme:
Sr.No. Particulars
Goods Issue
1.
FG Stock A/c
2.
COGS A/c
Customer Invoice / Billing
1.
Cenvat Clearing A/c
4.
VAT Payable A/c
5.
Sales Rev A/c
6.
Customer A/c
Customer Receipt
1.
Customer A/c
2.
Bank A/c
Debit
Credit
1000
1000
204
120
1000
1324
1324
1324
69
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