Turning "ease" of doing business into "unease"

Significant changes have been brought in vide Notification No. 94/2020-Central Tax dated December 22, 2020. The key changes are:

1. Registration is now liable to be cancelled even for cases where Input Tax Credit (ITC) has been availed in violation of S. 16 of CGST Act or where GSTR-1 shows revenue in excess of that disclosed in GSTR-3B for same period - so unfettered powers to the authorities now even for clerical mistakes on the part of taxpayers. Now each month's return has to be accurate, zero margin of error and we all have to become supercomputers with highly efficient systems and process.
2. Suspension of registration can be done even without providing a reasonable opportunity of being heard - What happened to the principle of natural justice ? It seems that we are now all guilty till proved to be innocent and the onus is on us too.
3. The restriction of availing only 10 per cent of eligible credit as reflected in GSTR-2A has been reduced to 5 per cent w.e.f. January 1, 2021 - Well, as if 10% was a lot. Reducing it further will add to the cash flow issues. Compounded complexity due to QRMP scheme now since more returns will be on quarterly basis by many SMEs. Those corporates having a large supplier base falling into less than Rs 5 cr. will need to spruce up and do mathematical magic to ensure they do not end up with cash liability in one month and excess tax credit in another.
4. New rule 86B added w.e.f. January 1, 2021 to provide additional conditions for claim of ITC and the challenges are in below paragraphs. What was the need, I ask ? Keeping track of 1% ? Seriously ?
5. If taxable value of supply in a month exceeds INR 5 million, then ITC can be utilised against tax liability only to the extent of 99 per cent of such liability. Balance 1 per cent will need to be paid in cash. For this purpose, the supply shall not include exempt and zero rated supplies.
6. The above restriction will not apply in specified conditions which include

                                                  i.    The taxpayer or specified persons have paid income tax exceeding INR 0.1 million in each of the two previous financial years

                                                ii.    The taxpayer has received refund of more than INR 0.1 million in preceding financial year on account of unutilised ITC

                                               iii.    The taxpayer has paid the tax liability in cash in excess of 1 per cent during the period from beginning of financial year till current month in the aggregate

                                               iv.    The taxpayer is a government department, PSU, local authority or a statutory body

The above changes shall come into effect from the date of notification in the Gazette unless specifically provided.

To top it all, where the responsibility of government comes in, they have given themselves more relaxations. Where they were supposed to provide registration within 3 day, now they can do so within 7 days. Additionally, they have put on the burden of not just Aadhar based authentication for any new registration, they also have power to compulsorily do a physical verification of premises before grant of registration. Inspector raj back again.

So, gear yourself up for a turbulent and complexity ridden 2021 as far as GST is concerned. Make a mistake and suffer for it, that seems to be the new mantra of doing business