Singh also mentioned that a number of provisions are being enacted bypassing both the GST Council as well as the legislatures. Like, the recent amendment in GST Rules for restricting tax credits was also made without even of an iota of discussion in the Council. The delegation of authority provided to a Committee of Officers (GST Implementation Committee) was meant for mundane matters while the same is being misused to carry out substantive changes.

Some key points raised in the letter are as below.

A number of provisions have been enacted in recent times through the route of subordinate legislation (Rules) bypassing both the GST Council as well as the legislatures. It is the basic principle of justice system that substantive rights of a person cannot be taken away except by a due process of law. The recent amendments in GST Rules (like restricting tax credits) have far reaching implications and were made without even of an iota of discussion in the Council. The delegation of authority provided to a Committee of Officers (GST Implementation Committee) was meant for mundane matters while the same is being misused to carry out substantive changes.

With oversight given a go-by harassment of tax-payers has taken an entirely new dimension with officers resorting to threats of arrest, provisional attachment of productive assets and freezing of bank accounts without any established norms.

Some issues that require urgent discussion in the context of Covid are as follows:

a) Should we exempt GST on hand sanitizers, face mask, gloves, PPE Kits, temperature check equipment, oximeters, ventilators and the like?

b) With interest rates down by close to 200 basis points, shouldn’t we cut down the interest rate under GST law (as also under other tax laws)?

c) With tax-payers’ officers shut and staff working from home, how should the information needs of the department authorities during enquiries be met without physical contact?

d) How do we provide relief to sectors most impacted by Covid e.g. MSMEs, aviation, hotels, restaurants, entertainment, commercial reality, retail?

e) Do we need to make amendment in law to allow donations of goods for Covid without denying tax credits on inputs used in their manufacture or purchase?

f) Whether an amnesty scheme is needed to condone delays in payment of taxes during Covid period?

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