E-filing of all purchases and sales

20.5.2014​ TO THE HON'BLE COMMISSIONER, COMMERCIAL TAXES KARNATAKA RESPECTED SIR , Sub: E-filing of all purchases and sales Ref: Notification dated April 29, 2014 We refer to your Notification dated April 29, 2014 issued by your kind office.. In this regard, we wish to submit as under: 1. We refer to the Subject Notification which requires e-uploading of all purchases (local and Interstate), all sales (local, interstate and exports) and all debit notes and credit notes for all dealers whose total turnover is Fifty Lakh Rupees and above. 2. Sir, we believe that such compliance procedures added to the already existing mandatory e-sugam compliance has put the selling dealers under the role of a compliance manager rather than a business men. Your kind office is already aware of the fact that in our Association, majority of the dealers don’t have personal computer in the Shop. The accounts are being prepared in Khata books which are prepared manually. The online return is only being filed with the help of local consultants who assists them in filing the returns by computing the gross sales and purchases figures with the help of a manual ​account​ books. 3. Sir, the Notification has casted a huge unprecedented burden on the Selling Dealers to record all purchases and sales in the prescribe format and upload it on the website of the Commercial Taxes Department. In our humble view, we feel that this is leading to the stage wherein the small time dealers (Proprietors and Partners of firms) would now need to set his business aside and take up the role of an accounts officer in charge of uploading all his purchases, sales, debit notes, credit notes and so on rathe ​r​ than focusing on vital business decisions. 4.Sir, the compliance procedures warranted under the Notification appear to be unreasonable and unjust when compared to the nature of businesses and the manner in which they are being operated. While at the same time, every movement of goods in and out of Karnataka mandates generation of e-sugam how does the subject Notification now wishes to move one step ahead and casts an additional burden on every dealer to also e-upload every purchase and sale of goods at the same time. Sir, this new mandate clubbed along with e-sugam seems to be arbitrary and unreasonable. 5. Sir, it is also our submission that the Statute along with the Notifications issued thereunder should be such that it does justice to the parties – both to buyer and the seller. It does appear that this mandate of e- uploading all purchases and sales by both buyer and seller and also at the same time generating e-sugam for every movement of goods would result in an absurdity. It is our submission that this would be very tedious and probably beyond possibilities of most of the non-qualified and incompetent and non-computer efficient dealers. 6. Sir, we believe that the implications brought about by the subject Notification do not at the same time have any nexus with the present infrastructure that the dealers are equipped with. The subject Notification has the ability to even impact the livelihood of dealers if these dealers are to reach anywhere near to complying with the complete set of conditions and compliance procedures brought about by the subject Notification. 7. Sir, in our humble view, we request you to please re-consider this unprecedented additional liability that is being cast on all dealers. There are dealers both in retail segments and wholesale who sell goods valued at a very low price and are manually preparing the tax invoices on a day to day basis. Even their Sales is presently exceeding Rs. 50 Lakhs when calculated for a year as a whole which is enough to satisfy the condition of the subject Notification. We request you to please take the above on record and help us to resolve the burden that our members are faced with..Khaga has always supported the commercial tax department in all the initiatives and we feel that to-gether we can ... ​ SIR..WE ASSURE YOU OUR BEST SERVICES AND KIND CO-OPERATION ALL THE TIMES..​ Thanks and regards, SAJJAN RAJ MEHTA CHAIRMAN,TAXATION KHAGA 09845501150