The combining of all annual returns into one is a welcome step both for the trade

as well as departmental officers as it would help to simplify business processes and

harmonise service tax and central excise returns in the ensuing GST regime,
hitherto filed separately by the assessees.
1. It is suggested that necessary steps may be taken to ensure this return is filed
by all assessees beyond 1.5 crores turnover, (who will only likely to be
governed by the Centre as per the present scheme of things as decided by the
GST council) since the purpose of returns is to identify and develop risk
parameters from the information filed in the returns submitted by the
assessees.
2. In the same vein, it may be ensured that the gap between active and nonactive assessees which results in difference in the number of returns received
by the department should be investigated like in Income Tax.
3. In case of any discrepancies in the returns, the trade should have a provision
in filing a revised return within one month of filing the common annual
return. It is also expected that the assessees reconcile their monthly service
tax returns and central excise returns with the trial balance / balance sheets
product wise, service wise and submit the common annual return and there
should be a declaration to that effect from the assessee.
4. All the important third party information provided by the assessee in their
other statutory returns like VAT, Income Tax, Company Law, SEBI, Bankers,
etc., must be captured in the presently suggested combined annual return and
there should be a mechanism in place to cross verify with the other returns.
5. However, it is also opined that completely relying upon the information
provided by the assessees in the new return also would defeat the very
purpose of compliance verification mechanism of detailed scrutiny and
internal audit and therefore, the above two tools should not be dispensed
with.
6. With the existing manpower constraints and distribution of units amongst
state and centre, there could be a skewed coverage of scrutiny of the new
returns and therefore, there is a need for the department to revisit the
parameters for selection of cases for internal audit / detailed scrutiny and a
certain and penalty for non-filing of returns and for furnishing wrong
information in the returns.

7. It is also suggested the periodicity for filing the returns and the reporting
format should be aligned for exclusive service providers and manufacturers
so that no issues arises and further since a single return means laying a
single platform for all central excise and service assessees who are similarly
placed.
8. Further, it is also suggested that along with the single financial annual return,
it could be considered to align payment of taxes on the same periodicity for
service tax and central excise assessees alike atleast for those assessees
coming under the jurisidiction of Central Government exclusively in the
GST regime as it would bring down paper work and further there is no
likelihood of cash flow problem envisaged, since the assessees, both central
excise and service tax, under the exclusive Central Government jurisidiction
model of GST are only bigger assessees having a turnover of more than
Rs.1.5 crores.
9. It would be prudent to introduce the single return even in lieu of monthly
returns during the GST rollout for those assessees under exclusive Central
jurisidiction as that would not be a precursor to introduction of GST but also
go a long way in the harmonization plans which were long back proposed in
2012 itself.
10. It may also be ensured that this common annual return for exclusive
assessees under the Central GST administration be approved by the GST
council or to be included in the proposed GST legislations directly.