Why taxpayers got confused as to what is the last date of filing FORM GST TRAN-1 owing to the consecutive press release, notification, and order issued by CBEC?

Many taxpayers are confused regarding the last date of filing Form GST TRAN-1. In the press release made by Ministry of Finance regarding the recommendations made by GST Council in 21st meeting at Hyderabad on 9th September, it was disclosed that the "the due date for submission of FORM GST TRAN-1 has been extended by one month i.e. 31st October 2017."  The clear understanding from this was derived that now FORM TRAN-1 can be filed until 31st October. 

After this, to give the legal effect to the decisions made, Seventh amendment to the CGST Rules, 2017 was released vide Notification No. 34/2017 – Central Tax dated 15 September 2017 and further the Order No. 02/2017-GST dated 18th September, 2017 was also released. 

Order No.02/2017 says that time limit for declaration in FORM GST TRAN-1 under Rule 120A of the Central Goods and Service Tax Rules, 2017 shall be extended till 31st October 2017. Read the Order below:

Now, further Rule 120 is in relation to the revision of the  FORM GST TRAN-1 already filed. So the question was raised as to whether the order notifies the revision date or extends the original filing period.  Rule 120A reads as below:

120A. Every registered person who has submitted a declaration electronically in FORM GST TRAN-1 within the time period specified in rule 117, rule 118, rule 119 and rule 120 may revise such declaration once and submit the revised declaration in FORM GST TRAN- 1 electronically on the common portal within the time period specified in the said rules or such further period as may be extended by the Commissioner in this behalf. 

Although, it is clearly visible that the Order No. 02/2017 contains error because the revision date was not notified earlier, then no point of extending it arises, but still it created the ambiguity.

Now, CBEC has released the Order No. 03/2017-GST, clarifying that the last date of filing FORM GST TRAN-1 shall be extended till 31st October 2017. Read the order at https://taxgrid.in/2017/09/21/extension-time-limit-filing-gst-form-tran-1/