SKP Group
SKP GST Update
24 April 2017
New GST Rules released by the CBEC
With a spate of rules being released recently by the Central Board of Excise and Customs (CBEC), another set of draft Goods and Services Tax (GST) Rules covering the following areas were issued on 19 April 2017: 
  1. Draft Accounts and Records Rules
  2. Draft Advance Ruling Rules
  3. Draft Appeals and Revision Rules 
The notable aspects of the rules are:

Draft Accounts and Records Rules 
  • Accounts and records are to be maintained separately for each line of activity such as manufacturing, trading and provision of service. A separate account for receipt of advances and adjustments therein has to be maintained.
  • Books of account should be kept at the principal place of business and other places of business mentioned in the certificate of registration.
  • Records may be maintained in an electronic form and a log of every entry edited or deleted should be maintained.
  • The rules provide for specific records to be maintained by the following categories of persons:
    • Agents
    • Works contractors
    • Owner or operator of warehouse
    • Transporters
  • If any taxable goods are found to be stored at any place other than the premises declared for storing of goods, the goods shall be deemed to be supplied and tax may be determined.
 Draft Appeals and Revision Rules 
  • Appeals before the appellate authority/appellate tribunal can be filed electronically in prescribed forms and a hard copy of the certified copy of the decision or order appealed against along with supporting documents should be filed within seven days.
  • On filing an appeal electronically, a provisional acknowledgement shall be issued to the appellant immediately.
  • The appeal shall be treated as filed only when the final acknowledgement indicating the appeal number is issued.
Draft Advance Ruling Rules 
  • An application for obtaining an advance ruling shall be made in FORM GST ARA-1 to the Authority for advance ruling on the common portal with a fee of INR 5,000.
  • An appeal against such Advance Ruling shall be filed in FORM GST ARA-2 to the Appellate Authority for advance ruling with a fee of INR 10,000.
  • The above-mentioned appeal should be accompanied by relevant documents supporting the grounds mentioned thereunder.
SKP's comments
The release of these draft rules takes the number of rules on various subjects of GST Law to 14. This clearly signals the intent of the government to move speedily for implementing GST. It is expected that after considering various recommendations and representations of the stakeholders, the final nod of the GST Council may be received in the next meeting scheduled on 18-19 May 2017.

This is the best time for industry bodies to make a representation to the GST Council to rationalise the draft provisions in respect of:
  • Way Bills – which seeks to continue the check post regime at state borders under the existing law, delaying free movement of goods.
  • Accounts and records – which puts an onerous requirement of maintaining extensive records on suppliers and logistic players.
  • Registration – to provide for centralised registration of service sector industries having multiple branches and to remove registration requirement for offices from where no taxable supplies would be undertaken. 
There have been murmurs that some provisions put an onerous requirement on businesses which go contrary to the intended purpose of introducing ease of doing business through the GST Law.
The GST rules can be accessed on the following link:
19 Adi Marzban Path | Ballard Estate | Fort | Mumbai 400 001 | India
+91 22 6730 9000 | |
Mumbai | Pune | Hyderabad | New Delhi | Chennai | Bengaluru
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