Service Tax -Centralised registration procedure
The DG, Service Tax has issued guidelines on the procedure for centralised registration of assessees located in the jurisdiction of more than one Chief Commissioner. Based on the DGST’s letter, many commissioners have issued Trade Notices. A look at the elaborate procedure will convince an applicant that it is not worth the trouble. Every simplification and facilitation in Central Excise invariably results in inexplicable complications and tons of wasted paper. Here are the basic requirements according to the DG.
1. A Check list along with the application for registration.
2. All the conditions prescribed in the check list to be complied which is to be verified by the Assistant Commissioner/Deputy Commissioner and Commissioner before sending it to the DG.
3. The applicants should send their applications to their Jurisdictional Assistant Commissioner/Deputy Commissioner which will ultimately reach the DG.
4. The Commissioner should send the application to the DG under intimation to his Chief Commissioner.
5. The DG will examine the application and grant permission for registration.
6. The Commissioner would then issue the registration certificate under intimation to the DG and his Chief Commissioner.
Just see how many copies are to be made and how many trips the papers will go to and from many levels of officers. For a simple registration! And is there any time frame for the registration process to be completed? It takes about 15 days for a paper to reach from one section to another in a Commissionerate. When will the application reach the DG and come back? And when the department is talking so much about computerisation, why can’t the DG take the application online and give the registration within a few minutes?
The check list requires the applicant to give information on
1. Residential address of proprietors/partners/directors.
2. Proof of address of the registered premises.
3. Bank account numbers.
4. List of branches, offices or premises of the assessee along with the names of persons.
5. Details of the accounting systems adopted and the method to ensure that no transaction remains unaccounted.
6. An undertaking that information records and data will be made available within ten days to the audit team.
7. Separate lists of records maintained at the branches and the registered premises.
8. List of reports submitted by branch offices to the head office.
9. A recapitulation statement showing service wise quantum of service rendered.
10. Information on how Data/Information is transmitted from branches to head office.
11. Information as to whether recoveries are affected through Credit/Debit notes.
12. Whether penal interest is collected.
13. Branches wise series of invoices with a few sample copies of invoices.
All this information is to be certified as correct by the Managing Director and the concerned Chartered Accountant. The field formations are to verify annually that the information is correct and valid. The DG does not clarify as to who should certify if there is no Chartered Accountant or MD. Maybe registration will be refused.