One has to thoroughly understand the nature of business with a view to quantify the severity of the impact of GST. Analyzing and understanding the contracts, transition issues, input tax mechanism, restrictions, blocked credits with a view to forewarn the assessee. we categorize in “A” to “E”.
A. Mismatching ITC ( General)
1 Book vs GST return reconciliations
2 Non filing OR Delay Filing.
3 Non maintenance of quantitative register, quantity reconciliations.
4 Not Taking ITC on RCM Paid.
5 Non making entry.
6 Supplier/Service provider issues only bill but not paying GST and not submitting Returns
7 As per Notice issued for GSTR-3B and GSTR-2A,i.e.DCR
B. Reversal of ITC / Wrongly availed ITC ( Section 17(5) or 18 )
8 ITC on composite dealer purchases.
9 Not reversing ITC on common expenses in proportionate to sales exempted.
10 Non reversal of ITC on wastage, lost, samples, fire accident, etc
11 Taking ITC on blocked credit and not reversing the same: passenger vehicle, food items and insurance etc.
12 Not reversing ITC when supplier payment is not made within 180 days With interest.
13 Non Reversal of ITC on Creditor Balance Write-Off.
C. PROCEDURES AND MISTAKES
14 No GST number in purchase Invoice.
15 Actually selling one taxable goods but declaring under exempted goods.
16 Non payment of GST on industrial estimated buy products, waste production.
17 Regular to composition Change : stock declarations and payment of GST on the Stock.
18 Special issues of composition dealers transfer from regular to composition vice versa.
19 Non submissions of quarterly form ITC-04 form for jobwork movement details.
20 Non Declaration of Stock and machinery with Job workers as on 30.06.2017.
21 Non submissions of debit note and credit note for subsequent rate,quantity difference
22 No payment of GST on used machinery sales, assets sales, vehicle sales, etc.
23 Canteen recovery from employees but GST not paid.
D. REVERSE CHARGE MECHANISM or TAX OMISSIONS
24 Not Reversing ITC on RCM Paid on Blocked Credits (building material, labour, etc)
25 Not Taking ITC on RCM Paid.
26 Not paying RCM on many 9(4)items. Building labour, Vehicle Maintenance, Rent, (URP)
27 Not paying RCM on 9(3) items advocate, govt services, freight.
28 Selling 100% exempted goods but not paying RCM U/s. 9(4), 9(3),
E. TAX OMISSIONS OTHER THAN RCM
29 Initially exempted items but subsequently taxed items but GST not paid.
30 Not Paying Tax on Canteen and Other Recoveries from employees.
31 Non disclosure of discounts , purchase returns in return.
32 No receipt of goods and assets sent on job work and returned within time 1/3 yrs..
33 In house job worker have crossing 20 lakhs and not having GST registration number.