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GST Update on TRAN 1 Not Accepting The Details Of Service In Transit

GST Update on TRAN 1 Not Accepting The Details Of Service In Transit

Filing of TRAN-1 is necessary for carrying forward the credit from Central Excise and service tax regime to GST regime. The transitional provisions relating to admissibility of credit have been provided in section 140 of CGST Act, 2017. Sub section 5 of this section reads as follows:-

"(5) A registered person shall be entitled to take, in his electronic credit ledger, credit of eligible duties and taxes in respect of inputs or input services received on or after the appointed day but the duty or tax in respect of which has been paid by the supplier under the existing law, subject to the condition that the invoice or any other duty or tax paying document of the same was recorded in the books of account of such person within a period of thirty days from the appointed day:

Provided that the period of thirty days may, on sufficient cause being shown, be extended by the Commissioner for a further period not exceeding thirty days:

Provided further that said registered person shall furnish a statement, in such manner as may be prescribed, in respect of credit that has been taken under this sub-section."

The analysis of above section makes it clear that the above referred section allows the credit in respect of eligible tax on input service that is received on or after the appointed ay but the tax on which has been paid by the supplier under the existing law. 
The format of TRAN 1 provides the following details to be furnished at column 7(b):-
"Amount of eligible duties and taxes/VAT/[ET] in respect of inputs or input services under section 140(5)"
However, the online utility of TRAN 1 released on 21.8.2017 has following title at column no. 7(b):-
"Details of the inputs held in stock(Eligible Duties and Taxes) "
Thus, the column 7(b) in online utility of TRAN-1 does not have mention of input services in its title. However, the first detail to be filled in under this column has the description of "Registration no. of supplier/Input Service Distributor". This means that this column is meant for availing the credit of both inputs and input service as the input service distributor can distribute only the credit of input service. 
Further, there are details like "Quantity" and "UQC" to be filled in this column. There is no quantity in case of services and this field is mandatorily to be filled; otherwise one cannot proceed. It is also not accepting "0", thus, any figure (even if it is 1) is to be mentioned. Also, there is no unique quantity code for services as there is no quantity at all in case of services. However, if we are filling "N.A." in this column, we can proceed.
The above difficulties are being faced practically while filing the TRAN-1. Since there is ambiguity in the descriptions provided in the column 7(b) as per format and as per online utility, there is confusion which needs proper and timely remedy as the due date of filing this return is approaching.

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