Time Limit to carry forward credit under any existing law or on goods held in stock on the appointed day
Rule 1 of draft GST Transitional Provision Rules provides that every registered person entitled to take credit of input tax under Section 140 shall, within 60 days of the appointed day, submit an application electronically in FORM GST TRAN-1, duly signed, on the Common Portal specifying therein, separately, the amount of tax or duty to the credit of which the said person is entitled under the provisions of the said section.
Issue
The said time limit of 60 days is very less and also there exists no provision for extension of such time limit.
Suggestion
It is suggested that time limit of 60 days be reviewed and a provision for extension of time limit under special circumstances be provided to allow for proper compilation of carry forward of duties and taxes paid under the existing law and documentation thereof.
Source ICAI Suggestions on GST Rules Submitted to Govt of India