Order No.03/2017 was released by CBEC to clarify that the last date of filing FORM GST TRAN-1 is extended till 31st October 2017, but the order talked about only CGST Rule 117 and this created confusion on the extension of the last date for submission of Transition for the purpose of CGST Rule 118, 119, 120. Read below to understand the scenario in details

Answer  – Earlier there was confusion as to whether CBEC has extended the last date for filing FORM GST TRAN-1 till 31st October 2017 or not.  To clarify this situation CBEC Released Order No. 03/2017-GST, wherein it was clearly mentioned that time limit for furnishing FORM GST TRAN-1 has been extended under rule 117.
Now the new confusion was created among the taxpayers that whether the order has been released only for the purpose of Rule 117 and those dealers who have to furnish FORM GST TRAN-1 under CGST Rule 118, 119 and 120 have to file the TRAN-1 form till 30th September only?

Although there was no room for confusion if the law was interpreted properly because Rule 118, 119 and 120 didn’t had any provision which gave the power to extend the last date for filing FORM GST TRAN-1. Rule 117 has the power under which the date of filing form can be extended and therefore the same was only mentioned in the released order. However, now to further make the situation more clear Notification No. 36/2017 – Central Tax has been released which notifies the Central Goods and Services Tax (Eighth Amendment) Rules, 2017. In these amendment rules, the amendment has been made in Rule 118, 119 and 120 to incorporate the provision which provides the power to extend the last date of furnishing the form.
For example, earlier CGST Rule 118 used to be read as :

118. Declaration to be made under clause (c) of sub-section (11) of section 142.- Every person to whom the provision of clause (c) of sub-section (11) of section 142 applies, shall within a period of ninety days of the appointed day, submit a declaration electronically in FORM GST TRAN-1 furnishing the proportion of supply on which Value Added Tax or service tax has been paid before the appointed day but the supply is made after the appointed day, and the Input Tax Credit admissible thereon.

and now after amendment, it shall be read as :

118. Declaration to be made under clause (c) of sub-section (11) of section 142.- Every person to whom the provision of clause (c) of sub-section (11) of section 142 applies, shall within the period specified in rule 117 or such further period as extended by the Commissioner, submit a declaration electronically in FORM GST TRAN-1 furnishing the proportion of supply on which Value Added Tax or service tax has been paid before the appointed day but the supply is made after the appointed day, and the Input Tax Credit admissible thereon.

So now Order No. 03/2017-GST makes sense to general taxpayers as it means that extension of date under Rule 117 means that date gets extended for the purpose of other rules also.