GST Updates

Need for Simplification and removing Ambiguities in GST:-Issues requiring attention for GST Council

 

  1. Re-credit of Late Fees: It is worthwhile to Highlight that vide Notification No. 76/2018-Central Tax, Late Fees has been waived for the registered persons who failed to furnish the return in FORM GSTR-3B for the months of July, 2017 to September, 2018 by the due date but furnishes the said return between the period from 22nd December, 2018 to 31st March, 2019.

 

However, since GST was a new law, it would not be exaggeration that every tax payer has at some time or other has deposited Late Fees for delay in filing of the return. Those taxpayers who have complied with the legal provisions and have filed the returns in time and have contributed in the timely collection and deposition of tax have been left aside and made to feel the brunt of late fees and no relaxation has been given to them with the re-credit of Late Fees.

 

The principle of equity requires that since late fees has been waived for person who have file their returns between period 22nd December 2018 to 31st March 2019 for the period July 2017 to September 2018; late fees of persons who have filed their returns earlier should also be re-credited.

 

  1. Need for Simplification of Format for Annual Returns and Reconciliation Statements: Formats for Annual Returns and Reconciliation Statement in GST have been released and the due date for filing of the same have been extended till 30th June 2019.

 

In the Working Paper of GST Reforms and Intergovernmental Considerations in India published by the Department of Economic Affairs, Ministry of Finance, Government of India the objective of tax reforms was stated as follows:

 

“Another important objective of tax reform is simplification of tax administration and compliance, which is dependent on three factors. The first determining factor for simplicity is the tax design itself. Generally, the more rational and neutral the tax design, the simpler it would be to administer and encourage compliance.”

 

It further goes onto provide that

 

“The tax return for such a system can be as short as the size of a postcard. It would simplify enforcement, and encourage voluntary compliance.”

 

In the above backdrop few of the issues amongst many issues, it is humbly submitted:

a) Need for simplification of formats: The returns were meant to be simple but have been made complex. The formats have been released, they are very complex and would be very difficult for small and medium business to comply with. There is dire need to simplify the formats.

b) New Information required in Annual Return: Annual Return seeks from the taxpayer information regarding bifurcation of Input Tax Credit in ITC for Capital Goods, Inputs and Input Services etc. which was never sought earlier while filing of GSTR-3B and GSTR-1. These information would require entire rewriting of accounts by the taxpayers which would be a tough exercise for the taxpayers as without such exercise, it would be impossible for the information to be extracted.

c) Person required to file both Annual Return and Reconciliation Statement: A registered person would be required to file both Annual Return and Reconciliation Statement. The procedure would involve filing of two statements by a single person. This would again lead to compliance burden on small assessee as presently the limit of Reconciliation Statement is Rs 2 Crore. It would be worthwhile if requirement of filing of both Statements by a person is modified and a reconciliation statement is drawn in a manner wherein a person who is required to file Reconciliation Statement is not required to file Annual Return separately. The same was happening in VAT Regime as well wherein a person who was required to File VAT Audit Report was not required to file VAT Annual Return Separately.

 

Suggestion: Thus request you to provide with a simplified format with less of a compliance burden and facility to correct the errors earlier made without which the annual return would be having little significance .

 

  1. Increase in Threshold Limit for the person required to get Accounts Audited in GST: At present the limit of Accounts to be Audited in GST is Rs 2 Crore which is a very low limit and requires reconsideration. The limit should be enhanced to Rs 10 Crore which would relieve small and medium business from the compliance work. It would not be wrong to state that the small and medium business are already reeling under the high compliance cost and therefore additional burden of Audit under GST requires reconsideration. It would be apt to highlight the data for taxpayers with annual turnover and % of revenue contributed by them as per the minutes of GST Council of meeting held on 10th November 2017 which would clearly highlight that the annual limit of Rs 2 Crore requires reconsideration:

 

Turnover % of Return Filed out of total returns filed % of revenue Contributed out of total revenue
Less than Rs 1.5 Crore 80.12% 5.58%
Less than Rs 2 Crore 80.71% 6.68%
Less than 2.5 Crore 82.17% 7.59%
Less than 5 Crore 84.57% 10.69%
Less than 25 Crore 90.76% 19.83%
Less than 100 Crore 94.31% 30.63%
More than 100 Crore 5.69% 69.37%

 

Suggestion: Thus, if the government sincerely wants to monitor the high end taxpayers with the requirement of Audit of Accounts then the limit may be fixed to Rs 10 Crore by which it would be able to monitor taxpayers who contribute about 85-90% of the revenue and the taxpayers under audit would also be limited to 10-12% of the total taxpayers.

 

  1. GSTR3B to accept negative value: There should be facility in GSTR3B to insert negative value. GSTR-3B presently does not accepts negative value and thus is creating issues in proper filing of returns. There may be many instances like sales return under IGST during a month wherein the supplier does not have any sales under IGST. GSTR3B does not accepts negative value in such cases.
  2. Tax charged has been actually paid to the Government: Clause (c) of sub-section (2) of section 16 of CGST Act, 2017

 

Hon’ble Supreme Court in the case of Commissioner of Trade & Taxes, Delhi and others Vs. Arise India Limited and others [TS-2-SC-2018-VAT], dismissed the Special Leave Petition filed by the Revenue against the decision of the Hon’ble High Court of Delhi in the case of Arise India Limited and others Vs. Commissioner of Trade & Taxes, Delhi and others [TS-314-HC-2017(Del)-VAT]. Hon’ble Delhi High Court in its decision had observed that

 

“In the present case, the purchasing dealer is being asked to do the impossible, i.e. to anticipate the selling dealer who will not deposit with the government the tax collected by him from those purchasing dealers and therefore avoid transaction with such selling dealers. Alternatively, Section 9(2)(g) of the DVAT Act requires the purchasing dealer, after transacting with the selling dealer, to somehow ensure that the selling dealer does in fact deposit the tax collected from the purchasing dealer and if the selling dealer fails to do so, undergo the risk of being denied the ITC.”

 

The Hon’ble High Court further held that

 

In the event that selling dealer fails to deposit the tax collected by him from the purchasing dealer, the remedy for the department would be to proceed against the selling dealer for recovery of such tax. Further, in cases where the department is satisfied that there is collusion of purchasing and selling dealer then proceeding under Section 40A of the DVAT Act can be initiated.

 

In the above back ground, present law goes one step ahead and provides that the tax charged in respect of such supply has actually been paid to the Government either in

  1. cash or
  2. through utilization of input tax credit admissible in respect of the said supply

The provision uses the word “admissible credit”. But how can a recipient identify whether the credit availed by the supplier was admissible to him? Does this mean that the recipient of the goods or services or both would go and check the books of account of the supplier and act as an assessing officer himself whether the supplier utilizing the input tax credit is admissible to him or not.

Now suppose during the assessment proceedings, it is found that input tax credit availed by the supplier was not admissible to him. Then, in such a case, would buyer be denied the benefit of the input tax credit as supplier used inadmissible credit?

The important thing here is what the meaning of the word “admissible” is and how far it can be stretched. However, such a responsibility should not be casted upon the recipient of the supply. Further, the system at present being provided to the recipient does not support to identify that whether the supplier has paid the due tax on the supplies made to him.

 

The provision needs to be reconsidered in light of the above judgement of Hon’ble Delhi High Court and the facilities offered to the taxpayers for checking the tax paid by the supplier.

  1. Facility to have Multiple Trade Names: There should be a facility of have multiple trade names. As is known that there would be generally single registration on one PAN. Therefore in cases wherein there are multiple firms of a person in different trade names, it becomes impossible to run business. For e.g. a person has a business of Kirana and other business is of Manufacturing Utensils. Now it would be a lost cause to think that there can be a common trade name for such business and taking business vertical registration for the same would not be a feasible option looking to the increased compliances. Thus, there should be a facility to have multiple trade names in GST.

 

  1. Tax Paid on Input Services being ineligible for the purpose of claim of refund on account of inverted duty structure:-The manner of determination of refund on account of inverted duty structure has been prescribed as follows:

 

Maximum Refund Amount = = {(Turnover of inverted rated supply of goods and services) x Net ITC ÷ Adjusted Total Turnover} – tax payable on such inverted rated supply of goods and services.

 

For the Explanation:- For the purposes of this sub-rule, the expressions –

(a) “Net ITC” shall mean input tax credit availed on inputs during the relevant period other than the input tax credit availed for which refund is claimed under sub-rules (4A) or (4B) or both; and

               

(b) “Adjusted Total turnover” shall have the same meaning as assigned to it in sub-rule (4).”;

 

The above definition and explanation was substituted by the Central Goods and Services Tax (Fourth Amendment) Rules, 2018 vide Notification No. 21/2018 dated 18th April 2018. The amended definition of “Net ITC” provides that it means input tax credit availed on inputs during the relevant period. However prior to the amendment the definition of Net ITC provided that “Net ITC” Means input tax credit availed on inputs and input services during the relevant period. Thus, as per the amended definition the scope of “Net ITC” has been restricted to Input Tax credit availed on inputs and input services have been taken out of the purview of refund on account of inverted duty structure. Thus position as it stands today is that in case of refund on account of inverted duty structure, no refund of input tax credit on input services would be allowed.

 

  1. Rule 42 and Rule 43: Denying eligible credit to the Taxpayers

 

At the outset and before moving to specific areas which requires reconsideration under Rule 42 and Rule 43, it would be apt to provide that entire scheme of reversal under Rule 42 and Rule 43 should be looked into and it’s a very subjective scheme with such gaps wherein a taxpayer would not be able to comply with the provisions either in entirety or without loss of genuinely eligible credit as some of the provisions under Rule 42 and Rule 43 take away genuinely eligible credit of the taxpayer.

 

a) 5% of Flat reversal of Common credit if any input or input service out of the common credit used for non business purpose: Presently Rule 42 requires a registered person to arrive at the common credit i.e. inputs and input services which cannot be identified on an invoice level basis that whether they have been used for making taxable supply or exempted supply. At times it is not at all possible to make such distinction.

 

Now consider an example wherein a person in purchasing wood and consumables from which he is manufacturing goods which are both taxable and exempted from the levy of tax. It is next to impossible for a registered person in such a case to identify which inputs have been used for making taxable supply and which inputs have been used for making exempt supply. In such a case, entire credit becomes common credit for such a registered person.

 

Rule 42 requires two kinds of reversal for common credit i.e.

 

  • Reversal of Common credit in the ratio of Taxable and Exempt Turnover

 

  • 5% Flat Reversal of the entire common credit wherein any input or input services has been used for non business purpose. The term non-business purpose has not been defined under the law. However, as a normal parlance we can define it as a use which is not related to the business. Rule 42 does not lays down any specific limit of the non-business purpose, and uses the language that “if common inputs and input services are used partly for business and partly for non-business purposes”. This is a sweeping language has a very wide ranging implications. Therefore, any non-business use as small as 0.01% of the entire common credit would trigger a reversal of 5% of the entire common credit.

 

Particulars Amount
Taxable Turnover Rs 98 Lakh
Exempted Turnover Rs 2 Lakh
Total Input Tax Credit Rs 18 Lakh
Common Credit Rs 15 Lakh

 

Say for e.g. one might say that out of the entire common credit of Rs 15 Lakh, a person has a small expenditure of non-business nature under telephone expenses or travelling expenses (which is inherent in such expenditure and cannot be identified on invoice level basis), therefore 5% flat reversal of the entire common credit would have to be made irrespective of any limit. This is a very harsh provision.  The impact of such miniscule use not identifiable at invoice level would result in loss of credit Rs 75 Thousand for the registered person.

 

 

Particulars   Credit Reversal
Reversal in the Ratio of Exempted turnover 15 Lakh/100 Lakh*2 Lakh 30 Thousand
5% Flat Credit Reversal 15 Lakh * 5% 75 Thousand

 

Suggestion: The rule requires reconsideration as adhoc reversal treating 5% of the entire common input tax credit being used for non business purposes is unparallel and harsh. It is not at all possible in certain areas where both taxable and exempted goods are being manufactured from the common input to identify at the invoice level which input has been used for taxable supplies and which has been for exempted supplies. It has to be borne in mind common Credit includes Input Tax Credit relating to Raw Materials and Input service used in manufacturing of both taxable and exempted goods for which proportionate reversal is already made and now making an additional reversal of 5% on such goods treating them as being used in non business purpose is entirely uncalled for. Just because these inputs and input services are part of common credit, it does not mean that wherein any part of common inputs or inputs services has been used for non business purposes, it should trigger flat reversal of 5% of the entire common credit.

 

This is irrational and taxpayer should be allowed to opt for the input tax credit in respect of which he intends to opt for reversal for non business purpose rather than a 5% flat reversal of common credit.

 b) Provision for Flat 5% reversal of common credit results in reversal in excess of common credit:

 

Consider an example wherein a person in purchasing wood and consumables from which he is manufacturing goods which are both taxable and exempted from the levy of tax. It is next to impossible for a registered person in such a case to identify which inputs have been used for making taxable supply and which inputs have been used for making exempt supply. In such a case, entire credit becomes common credit for such a registered person.

 

Particulars Amount
Taxable Turnover Rs 2 Lakh
Exempted Turnover Rs 98 Lakh
Total Input Tax Credit Rs 18 Lakh
Common Credit out of total Input Tax Credit Rs 15 Lakh

 

Reversal in such a scenario comes out to be as follows:

 

Particulars   Credit Reversal (Rs in Lakh)
Reversal in the Ratio of Exempted turnover 15 /100 *98 14.70
5% Flat Credit Reversal 15 Lakh * 5% .75
Aggregate Reversal 15.45

 

In the above example, reversal is of Rs 15.45 Lakh as against common credit of Rs 15 Lakh. This is an absurd situation wherein total reversal comes out to be Rs 15.45 Lakh as against common credit of Rs 15 Lakh.

 

Suggestion: The reversal of 5% should be rationalized in place of an adhoc 5% reversal of entire common input and input service regardless of the fact that whether such input and input services have been used for non business purpose.

This is irrational and taxpayer should be allowed to opt for the input tax credit in respect of which he intends to opt for reversal for non business purpose rather than a 5% flat reversal of common credit and if at all reversal of 5% is kept under the law on the common credit then , reversal of 5% should be made on the credit left after deducting reversal of inputs credit used for exempt supplies, rather than on the entire common credit. 

 

c) Need to Rationalize provision for Reversal of Input Tax Credit under Rule 42 wherein input or input services purchased in one financial year have been used for exempted /taxable supply in the next financial year:

 

The law prescribes the procedure wherein entire input tax credit in a particular financial year has to be reversed in the ratio of exempted supply as against total turnover during the financial year.

 

Now supposedly, a person has made a purchase of Rs 20 Lakh in the year 2017-18 out of which exempted sales of Rs 10 Lakh were made during 2017-18 and rest of the material was in hand as on 31st March 2018. The raw material was used in manufacturing and supply of taxable goods in 2018-19.

 

In the present scenario, law requires reversal of common credit in the year when the input or input services are received. Therefore, in the year 2017-18, entire input credit of the registered person would be reversed as entire sales during the year 2017-18 was of exempted goods. The registered person would not be able to utilize the credit of such inputs in 2018-19 in which taxable supplies have been made although from the use of input and input services received in the year 2017-18.

 

Now taking the reverse case scenario, wherein a person has made a purchase of Rs 20 Lakh in the year 2017-18 out of which taxable sales of Rs 1 Lakh were made during 2017-18 and rest of the material was in hand as on 31st March 2018. The raw material was used in manufacturing and supply of exempted goods in 2018-19.

 

In the present scenario, law requires reversal of common credit in the year when the input or input services are received. Therefore, in the year 2017-18, no input credit would be reversed as entire sales during the year 2017-18 was of taxable goods. The registered person would be able to carry forward entire credit of such inputs in 2018-19 in which exempted supplies have been made although from the use of input and input services received in the year 2017-18 as law prescribes under section 17(2) read with rule 42 for reversal of input tax credit during the financial year and not beyond the particular financial year.

 

Suggestion: There is a need to rationalize Rule 42 with a view to allow credit in genuine cases and disallow credit wherein input or input services purchased in one financial year have been used for exempted/taxable supply in the next financial year.

 d) Exempted and Aggregate Turnover to be considered for the purpose of Input Tax Credit Reversal under Rule 42 and Rule 43

 

Consider that a taxpayer ahs two units in the same state under same GSTIN and he maintains two separate books of accounts for the units. The turnover and other details of the two units is as follows:

 

Particulars Unit-1 Unit-2 Aggregate
Taxable Turnover 100 Lakh 100 Lakh
Exempted Turnover 100 Lakh 100 Lakh 200 Lakh
Total Credit (A) 15 Lakh 15 Lakh 30 Lakh
Specifically Allowable Credit (B) 5 Lakh 5 Lakh
Specifically Disallowed Credit (C) 15 Lakh 15 Lakh
Common Credit ((A-(B+C)) Nil 10 Lakh 10 Lakh

 

Now for the purpose of reversal of the Input Tax Credit for the purpose of Rule 42 (and incase of capital goods Rule 43), exempted turnover would be considered that of GSTIN rather than of Unit-2 only wherein there both supply of exempted and taxable goods and entire credit of Unit-1 has already been reversed by the taxpayer. Therefore Reversal which would have been 5 Lakh (i.e. 10 Lakh*100 Lakh/200 Lakh) considering turnover of Unit-2 only would increase to Rs 6.67 Lakh considering aggregate turnover of GSTIN for the purpose of reversal of Input Tax Credit (i.e. 10 Lakh*200 Lakh/300 Lakh).

 

Suggestion: The provision for reversal requires reconsideration and registered person should be allowed to reverse the credit on exempted turnover for a particular unit if separate accounts have been maintained rather than considering the turnover of the entire GSTIN. 

 e) Interest to be paid for reversal of Input Tax Credit under Rule 43 of CGST Rules, 2017:

 

A Registered person can claim Input Tax credit of Tax paid on purchase of capital goods in the month when the capital goods are received. Subsequently, Input Tax Credit is required to be reversed on a monthly basis for the next sixty months if the capital goods are used for the purpose of supply of exempted goods as well as taxable goods. The rule provides that on such reversal being made for every month during the period of sixty months, registered person would be liable to pay applicable Interest for the reversal made from the date of availment of input tax credit.

 

This is a very hard provision and requires reconsideration. The registered person has claimed credit of tax paid on receipt of capital goods as per the provisions of CGST Act, 2017 and at the time of purchase he does not know whether and how much he would be using the capital goods in the supply of capital goods. If the credit has to be reversed, it is because of circumstances which were not known to him at the time of availment of Input Tax Credit. Thus the provision to burden him with additional liability of interest for reversal requires reconsideration. Further the language of the provision does not make any distinction for the liability of interest between the cases wherein the registered person was able to adjust entire input tax credit against the output tax liability or in cases wherein, the excess balance was lying in his electronic ledger and he was not able to adjust any part of the credit of the capital goods.

 

Suggestion: The provision regarding payment of Interest on the reversal of credit on capital goods requires reconsideration and should be done away with as the registered person does not know at the time of availment of credit regarding the quantum of the capital goods to be used for taxable or exempt supplies and if the taxpayer does not reverses the credit on capital goods as per procedure laid down in Rule 43, then applicable interest should be paid but from the date when the reversal was required to be made rather than from the date when the credit was availed.

 

  1. Need for Clarity on certain issues:

There needs to be a clarity on certain issues which required clarification form the Council

  1. Supply of services from Branch Offices to Head Office and Vice Versa
  2. Payment of Tax on Ocean Freight under Import of Service
  3. Treatment of Gifts and freebies supplies in schemes by FMCG and Pharma Dealers.
  4. Eligibility of Input Tax Credit to Exporters for the Period July To September 2017 wherein Goods were exported against Higher Drawback
  5. Clarity on Taxation of Solar Power Plants-70/30 Taxation Regime

The issues are having wide ramifications and requires urgent clarification to prevent undue hardship to the dealers.

 

  1. Calculation of Penalty Payable under Section 73 and 74 of CGST Act, 2017

Section 73 of CGST Act, 2017 pertains to Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised for any reason other than fraud or any willful misstatement or suppression of facts and section 74 of CGST Act, 2017 pertains to Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilised by reason of fraud or any wilful misstatement or suppression of facts.

 

The section requires payment of penalty by the taxpayer at various instances. There has been lack of clarity regarding the amount on which penalty is to be paid by the taxpayer wherein h tax which has not been so paid. Whether the amount of penalty has to be calculated after deducting Input Tax Credit from Output tax or whether penalty  has to be deposited on Output Tax without deducting the Input Tax Credit.

 

It is humbly submitted that Input Tax credit available to the assessee is a tax already lying with the exchequer, therefore treating the entire output tax payable as tax not paid will be harsh on the assessee and would not be within the four corners of legal jurisprudence.  Therefore, benefit of the tax already deposited with the exchequer and lying with the assessee as Input Tax Credit should be allowed to be adjusted against the output tax liability before arriving at the penalty amount to be paid. In the previous regime as well, there have been numerous decisions wherein penalty ahs been held to levied on net payable amount.

 

 

  1. Need for Restricting Late Fees uptoTax Liability in cases where Tax liability is less than Rupees 5000/-

 

One of the biggest demands from the trade alongwith the facility to file quarterly returns and facility to revise returns is to restrict the amount of late fees. GST Council in 23rd Meeting held on 10th November 2017 decided to restrict the maximum amount of late fee payable to the extent of output tax liability in a return by exercising powers under Section 128 of the CGST Act, 2017. However for some reasons the decision never got implemented.

 

The relevant minutes of the meeting are as follows:

 

Agenda item 7 (vi): To restrict the maximum amount of late fee payable to the extent of output tax liability in a return by exercising powers under Section 128 of the CGST Act, 2017

 

“53. Introducing this agenda item, the Secretary stated that representations had been received that in some cases, late fee payable for delayed filing of Return exceeded the principal amount of tax and interest by a very large amount and this was deterring the small and medium business from filing Returns. He stated that the Law Committee had recommended that the maximum amount of late fee payable by a taxpayer could be restricted to the amount of tax payable in a return in case such amount was less than 5,000 rupees by exercising the powers conferred under Section 128 of the CGST Act. He further stated that during the officers’ meeting held on 9 November, 2017, it was also decided that the late fee for taxpayers who filed Nil returns should be only Rs.20 per day (Rs.l 0 CGST and Rs.l 0 SGST). He suggested that the Council could approve these proposals.

 

The Council approved these proposals.

 

  1. For Agenda item 7(vi), Council approved the following:

 

(i)           The maximum amount of late fee payable by a taxpayer shall be restricted to the amount of tax payable in a return in case such amount is less than 5,000 rupees;

 

(ii)         The late fee for taxpayers who filed Nil returns shall be Rs.20 per day (Rs.10 CGST and Rs.10 SGST).”

 

The said decision of GST council is yet to be implemented even though the trade has suffered on account of such lack of implementation and people with nil turnover or minimal turnover have been made to pay heavy late fees.

 

  1. Change of Place of Supply Rules in case of accommodation services-

 

Place of supply in case of accommodation services is location of immovable property. Demand had been raised all across the sector to modify and have a relook at the provision. The council agreed to the same and decided to have a relook at it has been put on hold for a long time to come. Agenda Item 9 of the 25th GST Council Meeting provided as under:

 

“In case of B2B supply of accommodation services like hotels, etc. the place of supply of service should be the location of the registered person and not where the hotel etc. is located in order to permit availment of input tax credit to the registered person. The Hon’ble Minister from Kerala stated that a hotel service was availed where the place of consumption was, that is, where the hotel was located and it was not a B2B transaction. The Commissioner (GST Policy), CBEC stated that on account of place of supply rules, persons registered, say in Bengaluru or Mumbai, were not organizing conferences etc. in Kerala or any other State as they were not getting input tax credit and they were moving these conferences to cheaper destinations in the South-East Asian countries.”

 

It was agreed as follows:

 

20.4. For Agenda Item 9, the Council agreed to the proposals for changes in the GST Law as presented in Annexure I to Agenda Item 9 with the following modifications I suggestions: –

 

  1. The place of Supply Rules for B2B supply of accommodation services (Sl.No.42 of Annexure I) to be discussed along with the rate of tax on accommodation services;

 

The said proposal is yet to be implemented and would result in benefit to the trade as huge credits have been denied to the trade due to place of supply provisions.

 

  1. Need to Rationalize ITC-04-Presently ITC-04 has to be filed by persons sending goods for Job Work. The form is very complicated and requires reconsideration and needs to be simplified as the small and medium business are finding it hard to fill and submit the form.

 

  1. Clarification Regarding TCS being part of Value of Supply: It has been clarified vide Circular No. 76/2018, that taxable value for the purposes of GST shall include the TCS amount collected under the provisions of the Income Tax Act since the value to be paid to the supplier by the buyer is inclusive of the said TCS. It is humbly submitted that the above clarification is not correct in light of the legal provisions and principles. Therefore it requires reconsideration and revisit.
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