Note on New Procedure in Maharashtra for CST Forms

Sales Tax Department has changed the procedure for application of Declaration Forms w.e.f 01.02.2014 vide Circular No.4T of 2014

From M B Abhyankar 

mbabhyankar@gmail.com

Existing Procedure for online applications upto 31.01.2014

1. Upto 31.01.14, the e-application form was simple and the dealer had to provide basic information such as TIN no. and Name of the dealer as well as supplier, description of goods purchased, No. of invoices and Value of purchases made, e-mail Id and mobile number of supplier.
2. Once the application was filed, the department used to cross-verify the same with the information available with them such as validity of registration certificate of the dealer, description of goods, and whether the returns are filed for the period for which application for forms is made. After verification was done, forms were printed and sent directly to the registered address of the dealer.
3. This process of the department was time consuming and forms were not received by the dealer within the stipulated time-period of 45 days from the date of application. Various reasons were given by the Sales Tax Department such as huge backlog of applications, shortage of stationery and man-power. Also in most cases dealer has to make various rounds of the department for getting the status of forms applied and in most cases forms were received after 2 to 3 months from the date of application.

As a result of the above difficulties faced by the dealers, the Sales Tax Department has started a new procedure from 01.02.2014 for filing of online form applications and getting the forms within the T+1 days on their e-mail Id.

New Procedure for Application of Declaration Forms w.e.f 01.02.2014

1. As per the new template for on-line C Form application, the dealer shall be required to make separate application for each period. Earlier the application for more than one period was possible in a single application.
2. The dealer can make only two applications for a particular period irrespective of number of suppliers.
3. Three separate Annexures have been prescribed for each of the Forms viz.
   1. C-Form & F Form
   2. Certificates in Form H
   3. Declaration in Form E-1 & E-II
4. C Forms have to be applied on quarterly basis. But the dealers with periodicity of six monthly returns have an option of changing their periodicity to the quarterly and apply for the CST declarations on quarterly basis. Such application for change in periodicity has to be done at the beginning of the year.
5. The declarant before applying for CST declarations shall ensure that the turnover of inter state transactions is within the limits of the turnover of interstate transactions shown by him in the return covering the period of transactions.

Additional details are required for filing new applications

6. This new procedure is available for declarations pertaining to period 01.04.2008 onwards.
7. Declaration Forms will be electronically issued to the declarant on the registered E-mail Id.
8. Quantity of Goods is required to be given in the application form. Hence, the dealer will have to prepare the purchase register with the column of Quantity in it. Alternatively, for manufacturing goods Cenvat register can be used as a reference for inserting the invoice quantity column with a link to document no., while for traded goods different register with quantity column shall be prepared separately.
9. The description of goods mentioned in the application shall be prima facie matching with the Registration Certificate (R.C). If not amendment to R.C shall be first made before filing of on-line application of Forms.
10. In case there are more than one item of goods in the invoice, a single broad description of goods purchased shall be mentioned in the application.
11. The dealer shall be careful while applying for C Forms, since invoice date of the supplier shall be within the period selected for application. e.g If the dealer makes application for Quarter 1 i.e  Apr-13 to Jun-13, then the suppliers™ invoice date has to be within Apr-13 to Jun-13. The date of invoice cannot be before Apr-13, i.e application for prior period invoices will not be accepted by the system. The following procedure can be followed for application of on-line declaration forms.
12. With a view to ensure exhaustive control over issuance of C Forms for every eligible supplier invoice, basic data base should be dealer™s own Purchase Register even though actual application for C Form is made according to dates of invoice from supplier.
13. Maintain a Cumulative Purchase Register from Apr 13 onwards in Excel Format by adding Purchase Register for each month in the cumulative file. Consider this Cum. Purchase Register as a basic data base for making E applications.  Mark all interstate purchases in the cumulative register by putting some flag in the column created for that purpose. Have a column for C Form Number issued by Department against each purchase voucher. Update C form number column for the forms received from department during each quarter.
14. It is assumed that first E application under new system will be made in Apr 14 by using Cum. File for entire FY 13-14. This application will cover first three quarters of FY 13-14. This is to ensure that time lag of minimum 3 months from the end of the quarter will be maintained for making first application out of the two permitted applications for any quarter for which E application is made.
15. Separate 3 applications will be made for First 3 quarters by including in each application all purchase bills pending for C Form which have supplier invoice date falling in respective quarters.
16. Upon receipt of C Forms for each quarter column for C Form received will be updated in Cumulative Purchase Register file.
17. Purchase Registers for Apr 14, May 14 & Jun 14 will be appended to Cumulative file after the end of each month.
18. First E application for Jan-Mar 14 Qtr will be made in July 14 by using Cum. File referred to in (f) above.
19. Second E application for any quarter will be made after a gap of 1 year from the end of the quarter, so that any left out bills having supplier invoice dates falling in that quarter which have not been captured in First E application for that quarter can be covered under Second & Last application.
20. Accordingly second E application for Apr-Jun 13 Qtr will be made in Jul 14 using the Cum File referred to in (f) above.
21. Same process can be repeated in Oct 14 for First E application for Apr-Jun 14 Qtr and for second E application for Jul-Sep 13 qtr.
22. Any supplier invoices still not covered for any quarter can be applied through the third application for the said quarter which can be filed only after obtaining permission of Additional Commissioner of Sales Tax of the concerned location.
23. In case of dealers with voluminous data of purchases, options for customization in ERP Accounting Systems can be explored to avoid problems of working with huge excel files.

Representation & suggestions to be filed with Sales Tax Department:-

In view of various new difficulties arising out of this new procedure which are going to be faced by the dealers, we are filing a representation and suggestion with the Commissioner of Sales Tax for changes and modifications in the new procedure of online form applications along with additional areas of modifications.