New Issue - Penalty on making supply without issue of Invoice.

S. 122(1)(i) - making any SUPPLY without issue of any Invoice - attracts penalty,

but, some SUPPLIES are authorised to be made without issue of invoice [read Tax invoice as per s. 2(66)]
S. 122(1)(ii) - has somewhat correct version ' invoice or bill'
but again, the term 'bill' used in sec. 122(1)(ii) and sec. 132(1)(b) is an undifened one.

New Issue - On the Definition of 'Valid Return'-
“valid return” means a return furnished under sub-section (1) of section 39 on which self-assessed tax has been paid in full; Sec. 2(117)
Clearly, it is not applicable for Composition Taxable Persons who submits their return u/s- 39(2).
Are their return, even if submitted without full payment, still considered 'Valid'?

New Issue - On the definition of 'Aggregate Turnover'
What is the purpose of separately mentioning -(i) export and (ii) inter-state supply in the definition of 'Aggregate Turnover'? - S. 2(6)
this may create confusion with the broader terms 'taxable supply' and 'exempt supply' during calculation of A.T.

New Issue - on issue of Tax invoice before making a supply
Sec. 31(1) and 31(2) authorises to issue a Tax Invoice 'before' making a supply.
Sec. 122(1)(ii) and sec. 132(1)(b) prescribe for penalty and punishment respectively, for issuing tax invoice without making a supply.
Within what time (after issuing the Invoice) supply should be made to avoid penalty or punishment?

AmendmentSrNo#25
we Request the following amendment
After the words cost accountant “ or a GSTP having 5 years of experience (as STP) and passed the examination conducted by NASIN and shall submit a copy of audited annual accounts......"

HINDU UN DIVIDED FAMILY-Immediate need that HUF must compel to register under the GST portal. Because more than 90% of HUF file has been utilised by Traders those doing without bills and to cover their Cash on Hand, simply and WITHOUT ANY OTHER VALID REVENUE SOURCES HUF PERSONS REPORTING INCOME FROM HUF & PAYING LESSER INCOME TAX , THEY EVADING INCOME TAX AND ALSO TAXES UNDER GST. SO SAFE GUARD REVENUE BRING HUF UNDER GST.

#37..Eligible duties in Explanation-I is in respect of inputs in stock or inputs contained in semifinished or finished goods in stock as on the appointed day. But the CENVAT credit in sub-section (1) is not pertaining to any stock but it is the closing balance in the CENVAT a/c in returns. Eligible duties in Explanation-II pertains to the goods or services received on or after the appointed day. Both the situations are not connected with that of Sub-section (1). It is better to add Exp.III

Dear Sir,

We humbly demands further amendment in Section 35(5) and Section 44(2).

The word “audited by a chartered accountant and cost accountant and other records and shall submit a copy of the audited” shall be deleted and will be substituted as “Examined by a GST Practitioners” and other record and other records and shall submit a copy of the verified annual accounts,”

In section 44 and sub section (2) the word “audited” shall be replaced by “examined”.

Dear sir please provide right to GSTP for audit work and also i suggest you please work your website because some time create problem to us. and please do not exam for gstp who is registered in early law (VAT).

Request the following amendment
After the words cost accountant “ or a GSTP having 5 years of experience (as STP) and passed the examination conducted by NASIN and shall submit a copy of audited annual accounts......”