State-Delhi-minutes of GRC meeting held on 23.05.25
A meeting of Grievance Redressal Committee under chairmanship of Sh. Rajesh Sodhi, Principal Chief Commissioner, PCCO, CGST & CX, Delhi Zone was held on 23.05.2025. The minutes of the meeting are attached as Annexure-A.
Annexure-A
It was informed that Grievance Redressal Committee (GRC) Meetings will henceforth be held on a quarterly basis to address taxpayer grievances and suggestions related to operational issues, and to resolve as many matters as possible in the presence of departmental officers.
A. AGENDA POINTS SPONSORED BY CONFEDERATION OF INDIAN INDUSTRIES (CII)
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Double Taxation of IGST on Re-import of Goods Exported Without Payment of IGST under LUT– Under Notification No. 46/2017-Customs dated 30.06.2017, the exemption does not extend to IGST in such cases. As a result, IGST is payable upon re-import even though refund of ITC related to exports may be pending or already granted — leading to dual taxation and potential demands for refund recovery if the export is later deemed void. | Amend Notification No. 46/2017-Customs to provide IGST exemption where the ITC refund has not been granted, and clarify that no recovery of ITC refund will be made where IGST is paid on re -import of such goods. | The Committee took note of the concern and assured that the matter would be referred to the Board for further consideration. |
| 2 | Methodology Required Before Deviation from Established Classification / Discount Practices- CII expressed concern over sudden deviations from established practices related to product classification and trade discounts, which result in retrospective demands and litigation. | Adopt a holistic and prospective approach for changes in interpretation. Issue circulars to ensure uniformity and avoid retrospective taxation. | It was clarified that classification is governed by globally accepted tariff codes and not decided at the field level. Taxpayers may approach the adjudicating authority if they disagree with departmental classification or denial of discounts. |
B. AGENDA POINTS SPONSORED BY FEDERATION OF ALL INDIA VYAPAR MANDAL (FAIVM)
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Penal Provisions in Transportation of Goods- FAIVM raised concerns over harsh penal actions taken for clerical or minor errors in transportation documents, leading to seizure of goods and imposition of penalties up to 200% of the tax amount. | Such errors, where no tax evasion is involved, should be treated leniently. Only a Show Cause Notice (SCN) should be issued, and mandatory penalty deposit should be avoided. | The Committee advised that specific instances be shared with officers for redressal. The Special Commissioner, Delhi SGST, also assured a review of such cases. |
| 2 | Volume Discounts and Credit Notes- FAIVM highlighted that post-sale volume discounts given through credit notes are being misinterpreted by audit officers as taxable supplies, leading to unjustified GST demands and insistence on issuance of invoices by buyers. | Clarify that such volume discounts are not a separate supply and are price adjustments, not liable to GST, nor requiring any invoice from the recipient. | Taxpayers may approach senior officers of the Audit Commissionerate with documents if they dispute the audit observations. |
| 3 | Delays in Disposal of Appeal Cases– FAIVM reported a growing number of pending appeals, especially in SGST, due to initial implementation issues of GST and the 10% pre-deposit requirement, resulting in capital blockage. | Expedite appeal proceedings to relieve trader uncertainty and unlock working capital. | It was informed that no appeal older than six months is pending at the Centre. The Special Commissioner, Delhi SGST, also assured prompt disposal of pending appeals in his jurisdiction. |
C. Agenda Points Sponsored by ASSOCHAM
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Issues Pertaining to the Mandatory ISD Mechanism- The ASSOCHAM representative raised concerns regarding the mandatory Input Service Distributor (ISD) mechanism, seeking clarity on: – How invoices issued under Rule 54(1A) for ITC transfer should be reported in GST returns – Reporting of ITC reversals under Section 17(4) for reverse charge services where tax is paid by a regular registration – Reporting of ITC reversals under Section 17(5) for reverse charge services taxed under a regular registration | Disclosure in GSTR-3B and GSTR-6 or Separate Line item in GSTR-1 | The Committee clarified that this is a policy matter and advised ASSOCHAM to represent the issue to the Board, under intimation to PCCO. |
| 2 | GSTR-5A – Lack of ITC Reporting Facility for OIDAR Providers ASSOCHAM requested an amendment to Form GSTR-5A to enable OIDAR service providers to report and claim Input Tax Credit (ITC). | Form GSTR-5A should be amended to provide mechanism for an OIDAR service provider to avail ITC & Form GSTR-2A and 2B should be generated for an OIDAR service provider to facilitate the matching of invoices for availing ITC. | The Committee recommended that the issue be represented to the Board for necessary clarification. |
| 3 | Transfer of ITC in Case of Inter State Business and Change in Agent– ASSOCHAM sought a mechanism for seamless transfer of accumulated ITC in cases of inter-State business transfer or change of local agent for foreign shipping lines. | The Government may consider proposing an amendment or issuing a clarification to address this gap in the current GST framework. | The Committee stated that this is a policy matter and should be referred to the Board for consideration. |
| 4 | Facility for TCS Registration Cancellation– ASSOCHAM proposed a user-friendly option on the GST portal to facilitate TCS registration cancellation. | A dedicated facility/ solution may be introduced on the GST portal that allows the taxpayer to apply for the cancellation of their TCS registration in a straightforward and user- friendly manner. | The Committee advised raising the issue with GSTN for resolution. |
| 5 | Payment of Interest When Order Does Not Specify Amount- ASSOCHAM highlighted difficulties in paying interest when the order mentions a percentage but not a quantified amount, requesting system changes to address this. | The Government may introduce a mechanism that enables the payment of interest even when the order does not specify the interest amount in absolute terms. | As this is a system-based issue, the Committee suggested referring it to GSTN for resolution. |
| 6 | No Amendment Facility on E- Invoice Portal- ASSOCHAM expressed concern over the absence of a facility to amend e-invoices post-generation. | The Government may consider introducing an amendment facility within the e-invoice portal itself. Such a mechanism would allow taxpayers to rectify errors or update invoice details directly on the portal, ensuring that the e-invoice data remains accurate and consistent with the records maintained in the GST portal. | The Committee advised the trade body to submit a representation to the Board for consideration. |
| 7 | Delay in Uploading of Orders-in-Appeal (OIA)- ASSOCHAM requested adherence to Section 169 of the CGST Act for timely service of orders. | The authorities may be directed to promptly upload the order on the GST portal and to allow the company a fresh period of 15 days from the date of such uploading to comply with the requirements stipulated in the order. | The Committee assured that efforts are made to adhere to prescribed timelines. The Special Commissioner, Delhi SGST, also assured proactive disposal in his jurisdiction. |
| 8 | Delay in Refund Sanction- ASSOCHAM urged expedited processing of refund applications based on merit. | Clear Standard Operating Procedures (SOPs) should be established for the handling of refund applications, particularly during periods of staff transfers and file relocations. | The Committee assured that efforts are made to adhere to prescribed timelines. The Special Commissioner, Delhi SGST, also assured proactive disposal in his jurisdiction. |
| 9 | Delay in Appeal Hearings- ASSOCHAM emphasized the need for timely hearings post-appeal filing. | The Department shall establish and adhere to clear internal timelines for scheduling and granting hearings after an appeal is filed. | The Committee stated that hearings are being conducted in a time-bound manner and deviations should be reported to the Commissioner (Appeals). |
| 10 | Uploading Clarifications While Filing GSTR-3B- ASSOCHAM suggested introducing a feature for uploading supporting documents while filing GSTR-3B. | A facility be introduced within the GSTR-3B filing process to allow taxpayers to upload supporting documents substantiating any adjustments made in the return. | The Committee advised referring the matter to GSTN for consideration. |
| 11 | GST Refund Post-Merger- ASSOCHAM requested a circular clarifying the refund procedure for unutilized ITC in merger cases. | The GST Council shall address this issue by issuing a specific circular that clearly outlines the procedure for claiming refunds of unutilized ITC in cases of mergers where the GST registration of the transferor entity is cancelled. | The Committee clarified that the matter should be referred to the Board for policy-level consideration. |
| 12 | Appeal Timeline in Case of Rectification Application- ASSOCHAM highlighted confusion when appeals follow rectification requests under OIO but rectified orders are delayed. | The GST Council shall consider this issue and issue a clarificatory circular specifying the time limit for filing an appeal in cases where a rectification application has been made. | The Committee suggested submitting the issue to the Board for issuing a clarification. |
| 13 | Generation of Acknowledgment Receipt for Demand Payment- ASSOCHAM recommended automatic generation of acknowledgment receipts upon payment of demand. | Upon making a payment towards an outstanding demand, the system should automatically generate an acknowledgment receipt. | The Committee advised referring the matter to GSTN as it is a system-related issue. |
D. Agenda Points Sponsored by Sales Tax Bar Association (STBA)
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Delay in Cancellation of Registration and Lack of Procedural Clarity- STBA flagged delays in cancellation applications and lack of reasoned show-cause notices, requesting adherence to the 30-day processing timeline and improved procedural transparency. | Ensure strict compliance with the 30-day processing timeline for cancellation requests, mandate issuance of properly reasoned show-cause notices in case proposed rejection, in cases where cancellation is rejected, provide a reasonable time window for the taxpayer to file any pending returns to avoid penal consequences, introduce a facility in the cancellation form to upload documentary proof of correspondence address, to avoid repetitive queries and save time for both taxpayers and officers. | The Committee acknowledged the concern and assured sensitization of officers on the matter. |
| 2 | Delay in Processing Core Field Amendments in Registration- STBA noted that further amendment requests are blocked until the earlier ones are resolved. | A mechanism be introduced to track and escalate delayed approvals, or allow submission of subsequent amendment requests conditionally, pending disposal of the earlier one | The GSTN representative assured that the matter has been noted and will be addressed appropriately. |
| 3 | Immediate Suspension of Registration Without Clarification Opportunity- STBA requested that taxpayers be given an opportunity to clarify before registration suspension. | Clarification of the taxpayer may be sought followed by SCN providing a reasonable opportunity to be heard. Only after evaluating the response, and if found unsatisfactory, should suspension or cancellation of registration be considered. | The Committee confirmed that officers will be sensitized to adhere to the existing guidelines. |
| 4 | Widely Spread CGST Offices Causing Operational Challenges- STBA highlighted logistical difficulties due to CGST Delhi offices being spread across the city. | Consolidation of departments to one or a maximum of two centralized locations, which would greatly enhance accessibility and reduce the compliance burden. | The Committee clarified that offices were established in various parts of the city to be closer to taxpayer jurisdictions and reduce travel for taxpayers. |
E. AGENDA POINTS SPONSORED BY PHD CHAMBER OF COMMERCE AND INDUSTRY (PHDCCI)
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Avoidance of Search in Non-Sensitive Cases: The PHDCCI representative raised concerns regarding the conduct of search operations by the Department in cases that can otherwise be resolved through the issuance of letters or notices. Examples include interpretation and classification issues or other non-sensitive matters. | Officer may initiate an inquiry through official correspondence, such as letters or notices, rather than directly proceeding to search the taxpayer’s premises. | The Committee acknowledged the concern and informed that officers would be suitably sensitized. Taxpayers who feel aggrieved may approach senior officers of the concerned Commissionerate for appropriate redressal. |
| 2 | Issues During Movement of Goods: PHDCCI highlighted the problems caused by the detention of vehicles during transit due to valuation, tax rate, or classification issues. | Instead of seizing the goods outright, the officer may consider retaining a sample of the goods for verification purposes and not detaining the vehicle along with goods | The Committee concurred with the suggestion. The Special Commissioner, Delhi SGST, also assured to look into such grievances under the purview of State GST. |
| 3 | Maintenance and Sharing of Note Sheets in Assessment Proceedings | It was suggested that note sheets should be maintained during GST and VAT assessment proceedings and copies shared with the assessee. | The Committee clarified that a Record of Personal Hearing is invariably issued by the adjudicating authority. In cases where it is not, taxpayers may approach senior officers at the Commissionerate/Zone/State level for redressal. |
| 4 | Appointment of Appellate Authority for Delhi VAT: The PHDCCI raised the issue of a long-pending vacancy in the post of Appellate Authority for Delhi VAT matters. | Appellate Authority for Delhi VAT matters may be appointed. | The Committee advised the trade body to escalate the matter to senior State GST officers for necessary action. |
| 5 | Errors in Form SPL-01/SPL-02 on GST Portal: Concerns were raised regarding persistent errors in the order details and tax amount columns in Forms SPL-01/SPL-02 on the GST Portal, especially in view of approaching filing deadlines. | The issue may be resolved at the earliest | GSTN informed that the issue is expected to be resolved by the first week of June 2025, after which the forms can be submitted on the portal. |
| 6 | Bulk Upload Facility in IMS | The PHDCCI requested a feature to upload actioned items in bulk using Excel/JSON files in the Invoice Matching System (IMS). | GSTN responded that functionality to select multiple invoices at a time is already available, and an offline tool is under development by the concerned team. |
| 7 | Pending Refunds under Delhi SGST: The trade body highlighted delays in refund processing by the Delhi SGST Department. | Refund process may be expedited | The Special Commissioner, Delhi SGST, assured that efforts will be made to expedite the processing of pending refunds. |
| 8 | Sharing of Contact Details with Banks Post GST Registration: PHDCCI reported that newly registered taxpayers are receiving unsolicited calls and emails from banks, suggesting that their contact details may be shared. | Contact details of new registrants may not be shared with banks | It was clarified that no taxpayer details are shared by the Department or GSTN with third parties without a formal request. |
| 9 | Provision for Reimbursement Details in Returns | A column in GST returns may be introduced for reimbursement details to avoid audit objections. | The Committee advised the trade body to submit a formal representation for consideration. |
F. AGENDA POINTS SPONSORED BY CONFEDERATION OF ALL INDIA MICRO & SMALL SCALE INDUSTRIES (CAMS)
| Sl. No. | Issues raised | Suggestion by the trade body | Recommendation of GRC |
| 1 | Digitally Signed Intimations with QR Code | All official intimations should be digitally signed and include a QR code for authenticity. | The Committee welcomed the suggestion and noted that most intimations are already issued through e-office systems with digital signatures. Additionally, a Document Identification Number (DIN) is included, which can be verified on the CBIC website. |
| 2 | Complete Digitization of Taxpayer Interactions | All GST-related communications, including audits, should be conducted exclusively online. | The Committee clarified that audits of small taxpayers are generally document-based. Physical visits to premises are carried out only when necessary and with the approval of the Audit Commissioner. |
| 3 | Appeal pending in Gujarat SGST for last three years against levy of penalty by SGST search team in respect of goods sold by a taxpayer registered in Delhi jurisdiction. | Requested for intervention to expedite the resolution of the appeal | The Committee advised to send a formal request for onward submission to Gujarat SGST. |
G. OTHER ISSUES
(i). IGST Transfer Issues from Customs Portal to GSTN Portal
A representative from the Confederation of Indian Industry (CII) requested a meeting with GSTN to discuss issues related to the transfer of IGST data from the Customs (ICEGATE) portal to the GSTN portal.
Recommendation of the Committee:
The SVP, GSTN, informed that functionality to fetch such data from ICEGATE is already available. Taxpayers facing issues are advised to raise a grievance ticket for resolution.
(ii). Display of Late Fee in Returns
Trade bodies recommended that the GST Portal should display the calculated late fee while filing returns.
Recommendation of the Committee:
GSTN representatives took note of the suggestion for appropriate action.
H.TRADE FACILITATION MEASURES IN DELHI ZONE
The Chair apprised the trade bodies of various trade facilitation initiatives undertaken in the Delhi Zone. These include:
- Regular outreach programs such as Samvad sessions with specific trade sectors.
- Encouraging GST registration to enhance economic participation.
- A revamped CGST Delhi Zone website: gstdelhizone.gov.in, offering taxpayer-centric features and updates on outreach programs.
- Decentralization of CPC to the Division level.
- Issuance of Trade Notice No. 01/2025 dated 23.05.2025 detailing the functioning of the Grievance Redressal Cell and launch of the dedicated grievance email: grievance.cgstdelhi@gov.in for complaints regarding violations of Instruction No. 04/2025-GST dated 02.05.2025.
The Confederation of All India Micro & Small Scale Industries appreciated the recent session on audit procedures conducted by Audit-II Commissionerate, terming it beneficial for small taxpayers.
The Chair encouraged stakeholders to share feedback on the registration process via the above-mentioned grievance email.
The meeting concluded with a vote of thanks to the Chair.
Share this content:
Post Comment