ICAI has submitted 12 reasons for extension of the aforesaid deadline in the representation letter. ICAI has stated that the rationale of providing a cut-off date of 20 Oct. 2018 for availing iTC of invoices pertaining to FY 2017-18 is more related with the return filing system originally introduced (i.e. Form GSTR 1, 2 & 3) wherein a functionality of bi-lateral flow of ITC was built in and hence the flow of credit was restricted. However, now since the entire return filing system is based on monthly summary return in Form GSTR 3B and Annual Return in Form GSTR 9 along with reconciliation statement in Form GSTR 9C, there is a need to reconsider the due date for availment of input tax credit (ITC) and to extend the same upto 31 Dec. 2018 considering various practical difficulties being faced by the Trade and Industry,
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