First, exporters had no clear guidelines on how they can send their goods abroad. The Central Board of Excise (CBEC) came out with one clarification after another till six weeks after the new laws came into effect. There are many issues relating to supplies to Special Economic Zones (SEZ) units and developers that have still not been addressed. For example, whether a bill of export needs to be filed even when no incentives are being claimed; how to procure minor services like that of electrician, carpenter, plumber when they are not registered; how SEZ developers can pay in foreign currency for services supplied against a letter of undertaking and so on. In the meantime, some laws have been amended and tax rates have been changed in response to various representations.
To be fair, the GST laws were put into place after considerable discussions with stakeholders. The government answered many questions from the trade through tweets, circulars, advertisements in print media and its websites, although some of these replies are incorrect. It conducted many outreach programmes to increase awareness. Still, many exporters had to cope with wrong trade notices issued by the Customs department calling for incorrect declarations for drawback claims and are uncertain about getting their claims and fear unexpected tax liabilities. The confidence that GST Network is capable of handling the returns, payments, reconciliation, refunds, etc., has been badly shaken. Much depends on how it handles the workload in the coming months.
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