On behalf of traders of the Country, we compliment you and the GST Council for collection of about Rs. 1 crore 33 lakh GST tax revenue for the month of February, 2022 which is almost 28 % increase in GST collection in about four years as in the first month of implementation GST collection for the month of August, 2017 was Rs.95633 lakh, However, we are of the opinion that the 28% increase in GST collection would have been more than 50% if efforts were made to widen the tax base as there is large potentiality of addition of more taxpayers into the fold of GST

Confederation of All India Traders

"Vyapur Bhawan"
925/1, Naiwala, karol Bagh,New Delhi-110005.
Phone: +91-11-45099884, Telefax:+91-11-45032665
Email: [email protected] Website: www.cait.in

Date: 15th January, 2021

Ref. No.: 3391/1/50

27th March, 2022

Smt, Nirmala Sitharaman
Hon'ble Minister for Finance
Government of India
New Delhi

Dear Smt. Nirmala Sitharaman Ji,

On behalf of traders of the Country, we compliment you and the GST Council for collection of about Rs. 1 crore 33 lakh GST tax revenue for the month of February, 2022 which is almost 28 % increase in GST collection in about four years as in the first month of implementation GST collection for the month of August, 2017 was Rs.95633 lakh, However, we are of the opinion that the 28% increase in GST collection would have been more than 50% if efforts were made to widen the tax base as there is large potentiality of addition of more taxpayers into the fold of GST. It is also not clear whether the GST collection figures are of gross value or net value. If It is gross value then substantial percentage of input which need to be paid to the input creditors also have to be deducted from the accrued value of tax revenue in order to specify the net GST revenue collection. However, the trading community of the Country is more interested in expanding the GST tax revenue significantly by working as an extending arm of the Government while stating that the tax evaders must be dealt with stern punishment.

Viewing the possibility of widening the tax base which in turn will accrue more revenue to both Central and State Governments, we are willing to partner with the Government as we feel that an increase in GST revenue will enable the Government to bring down tax rates under Income Tax. We suggest that the 'participatory governance' model as stated by Prime Minister Shri Narendra Modi needs to be given practical shape under GST by forming a joint committee at each District level composed of senior tax officials of the district and representatives of prominent trade associations of the respective district. Representation should also be given to traders under GST Council so that decisions be taken in a participatory and consensus manner.

We take this opportunity to add that for bringing more and more traders under the purview of GST, it is more important to simplify and rationalise the current state of the complicated GST tax system. There is a need to have a relook to GST Act as both Government and the traders have an experience of more than 4 years and based on that a refined GST tax structure can be carved out which will encourage the traders for more voluntary compliance whereas on the other hand both Central and Slate Governments will yield more substantial revenue. Multiplicity of forms, varied tax slabs, wrong placement of goods under different tax rates, excessive and discretionary powers to officials, cancellation of registration and attachment of bank accounts, several items which accrue negligible tax revenue have been put under higher tax slab, like provisions have brought disparity and distortions in the tax structure . Making mandatory GST registration for traders for conducting business on e-commerce is depriving small traders to take advantage of e-commerce trade. Likewise, there are several rules which are considered as roadblocks for widening the tax base.

We are also of the opinion that for widening the tax base under GST it is most important that ease of doing business should be provided to the business community across the Country. In the recent past, the Government while accepting the demand of CAIT ordered inclusion of traders under MSME category which is a praiseworthy step. It will be good if registration of Udhyam Aadhar may be made mandatory for conducting any type of business of sale of goods or providing services making Udhyam registration as Aadhar Card of any businessman. It will enable the Government to know the size of the retail market of India and better policies can be formed for the welfare of the traders. Multiple licences required to conduct business activities should be replaced by only one license. Likewise, multiple laws concerning internal trade should be reviewed and the laws which have lost significance in the current context should be abrogated and time needed amendments may be made in remain* laws. The retail trade could be made as an engine of growth for the Indian economy and can contribute magnificently to the 5 trillion economy vision of Prime Minister Shri Narendra Modi.

While assuring you of our utmost cooperation, we would like to discuss the issue in person and shall be grateful if an earliest appointment is accorded  to us.

Thank You. With regards

Truly yours

Praveen Khandelwal

National Secretary General

Confederation  of All India Traders