" 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......"

#Amendment SrNo. 21: It may be interpretated that in case there are more than one unit in a single Special Economic, separate registration is required under GST for each and every unit subject to the conditions that may be prescribed by the Government.
It is hereby requested to clarify that in case there are more than one unit in different Special Economic Zones in same state, whether separate registration is required or not for each such unit.

A Single GST Tax Rate should be there. Multiple GST tax slabs are not required. No item or services should be exempted from GST whether it is fruits or vegetables.

Suggestion:
In the Proposed amendment Rule 17(3) of CGST Act 2017 the exempt supply include sale of land. It is presumed that the undivided share of land may also be involved in the proportionate share while calculating exempted supply. However the Share of land is not at all concerned and will badly impact on builder developer who intended to supply of construction of complex, Building, Civil Structure etc under SAC Heading 9954. The interpretation of the said clause has put 1/3rd share of IT

#Amendment SrNo25,
We Request the following amendment after the words cost accountant" or an Advocate or a 5 years experienced GSTP (as STP) and shall submit a copy of audited annual accounts....."

#AmendmentSrNo25 Burden of double audit should be avoided. since verification of
all records are integrated part of books of account only, which falls under the
ambit of section 44AB of The Income Tax Act, 1961 duly with Trading A/c, P&L &
Balance Sheet. Hence Annual return be certified by any of the Tax Professional
recognized under the GST Act, in service for not less than 5 years, duly passed GSTP examination.

#AmendmentSrNo25 The word audit should be replaced by the word ``verified`` for the limited purpose of filing of Annual returns in form GSTR 9 and reconciliation statement. And the powers shall be given to all the registered GST Practitioners having an experience of 5 years standing in practice.

#AmendmentSrNo25 The word audit should be replaced by the words ``verified`` for the limited purpose of filing of Annual returns in form 9 and reconciliation and the powers shall be allowed to all registered GST Practitioners having an experience of 5 years stand in practice.

#GSTAmendment
PFA the proposed suggestions by ASAV Attorneys & Advisors LLP, South Ex-II, New Delhi

I am a Mutual fund agent just like Insurance agent who earn a living by distributing mutual fund schemes where the investment is collected in the name of Muual fund company.We are liable to pay GST at a very high rate without collecting from investors.It is our request to roll back the ongoing mechanism which is quite regressive for our work.