Submission of my Comments on Refund Process in GST on mygov.in. Detailed Comments can be viewed by clicking on the Link
Small Extract of my submission is as follows:
a) Interest Payable to the assessee on refund is 6% and Interest Recoverable at the rate of 18% from the assessee on delay in payment
Further, there also needs to be a check that when there is default of the taxpayer, the interest payable by the assessee is 18% and when there is default of the government or its officials, the interest payable to the taxpayer is 6%. This is huge disparity and it’s understood that as the taxpayer is making use of the public money when there is delay in payment of taxes and he has to be penalized for the same but the penalization cannot be at such a higher rate.
b) Aggregate Time limit for processing of refund should be fixed at thirty days:
The draft proposal requires reconsideration and subjectivity should be mitigated with clear and unambiguous words.
Prescribing such long duration for processing of the refunds of 30 days for communication of deficiency and 90 days for the process of refund would only lead to blockage of the working capital of the taxpayer and unnecessary harassment.
There should be a total time limit of 30 days for the processing of the refund and if the assessee fails to submit the documents or application could not be processed for the want of documents and submissions from the assessee then in such case the assessing officer can reject the application by speaking order.