In Pursuit of Knowledge

Salient Features of APVAT Law

Value added is the difference between the actual money value of sales and the money value of inputs. The measure for tax or the tax base is the incremental value, acquired since the last taxable transaction. VAT is comparable with the last point sales tax. VAT, it is said, removes cascading, both on exports and on domestic sales to achieve neutrality. A cascading tax results in increasing the cost of production. A cascading tax is also said to be non-transparent. Levy of tax at various stages of inputs used, makes the value of the finished goods sold higher, when it reaches the consumer. For example, in the case of an iron article sold to the consumer, there are taxes levied on the inputs; i.e., iron ore/iron scrap and iron sheets and finally on the finished goods i.e., iron article. To make the transaction non-cascading, one of the alternatives is not to levy at all any tax on the inputs. If for any reason, tax is levied on the inputs, such tax amount must be set off or reduced from the tax payable on the subsequent sale of goods/finished products.

  • Pursuant to the decision taken in the Conference of Chief Ministers held in November, 1999, the Empowered Committee of State Finance Ministers has been set up in New Delhi. After several rounds of meetings, the States have agreed to implement VAT system in the place of General Sales Tax.

  • The main aims are, to create common Indian market in the country, to remove the cascading effect to achieve neutrality, to make the administration more transparent, to curtail tax exporting to the other Sates, to broaden the tax base, to permit reduction in the rates of tax etc.

  • The A.P. State Legislature has passed the A.P. Value Added Tax Act, 2005 (Act No.5 of 2005) (in short Act). The Act has also received the assent of the President of India. The Act and the Rules made thereunder came into force with effect from 1-4-2005. The APGST Act, which was in force earlier has been repealed.

  • For the purpose of Registration under the Act, there is neither ‘yearly turnover concept’ nor ‘gross or total turnover concept’. The parameters are ‘period of 12 consecutive months’ and ‘taxable turnover.’ There are two categories of dealers i.e., Turnover Tax dealer (TOT dealer) and Value Added Tax dealer (VAT dealer). (Section 17 deals with registration).

  • Dealers having a taxable turnover not exceeding Rs. 5 lakhs in 12 consecutive months are exempt from registration and payment of tax.

  • Dealers having a taxable turnover exceeding Rs. 5 lakhs but not exceeding Rs. 40 lakhs in 12 consecutive months are to be registered as TOT dealers.

  • Dealers having a taxable turnover exceeding Rs.10 lakhs in the preceding 3 months or exceeding Rs.40 lakhs in 12 consecutive months are to be registered as VAT dealers.

  • Dealers mentioned in section 17 (5) are to be compulsorily registered as VAT dealers, irrespective of their taxable turnover. They are dealers having CST registration/interState transactions/dealers liable to pay tax on Schedule VI goods/agents of non-resident principals/dealers availing tax holiday/deferment/all hotels and restaurants.

  • There is also optional or voluntary registration as VAT dealer vide sec. 17 (6). See Rule 8 for Voluntary Registration.

  • There are six Schedules to the Act. Schedule I deals with goods, which are generally exempt from tax. Schedule II deals with zero rated transactions. Schedule III deals with Bullion and Specie and the goods made therefrom, which are taxable at 1%. Schedule IV lists the goods taxable at the rate of 4%. Schedule V is residuary; i.e., goods not mentioned in any other Schedule are taxable at the rate of 12.5%. Goods in the VI Schedule; i.e., liquor, diesel, petrol and ATF are taxable at special rates mentioned therein. Goods in Schedule VI are taxable at the point of first sale in the State. Works contracts and Lease transactions do not have uniform rate of tax as in the case of APGST Act. Tax is levied at the rate applicable to the goods.

    (Charging section is 4)

  • HSN code numbers are given to majority of commodities in the Schedules through Notifications for the purpose of interpretation and to avoid disputes pertaining to commodity classification.

  • TOT dealers are liable to pay tax at the rate of 1% on the taxable turnover, irrespective of the rates of tax in the Schedules. There is no composition for the TOT dealers. Payment of tax @ 1% by the TOT dealer is automatic.

  • VAT dealers have to pay tax on the sale of taxable goods, other than those mentioned in Schedule VI, at every point of sale at the rates mentioned in the Schedules.

  • There is also contingent purchase tax in certain circumstances, such as when taxable goods are purchased from non-VAT dealers and used in the manufacture of exempt goods or when they are sent on transfer basis to the other States, etc. Except Schedule III goods, the rate of purchase tax is uniformly 4% for all other goods. (See sec. 4 (4).

  • All dealers running hotels, restaurants, sweet shops etc., and having a taxable turnover of Rs.5 lakhs in the preceding 12 months or Rs.1.25 lakhs in the preceding 3 months have to pay tax @ 12.5% on 60% of the taxable turnover. Thus the effective rate is 7.5%. (Section 4 (9). They are also eligible for ITC.

  • There are no concessional rates of tax.

  • The main feature of the Act is ‘input tax credit’ (ITC). ‘Input tax’ means the tax paid or payable under the Act by a VAT dealer to another VAT dealer on the purchase of goods in the course of business. See sec. 2(19) and Sec.13). Tax paid on the purchases under the CST Act cannot be claimed as ITC. Only VAT dealers are eligible to claim ITC. TOT dealers are not eligible for ITC. Certain goods are not eligible for ITC. There are also certain restrictions as to quantum of eligibility of ITC. (Rule 20 deals with all such restrictions).

  • Generally only when output tax is payable, then only ITC is allowed. Output tax is the VAT payable on the sale of goods in the State. However the Act provides for treating certain transactions as zero-rated sales. See sec.2(47), sec. 8 and Schedule II. In respect of exports to foreign countries, in respect of inter State sales falling under the CST Act and in respect of sales made to the units located in Special Economic Zone, no VAT is payable. However such sales are treated as zero-rated transactions, making them eligible for ITC.

  • Exempt sale and zero-rated transaction are distinct and different. Both are not one and the same. In the case of an exempt sale, ITC is not allowed.

  • ‘Tax invoice’ (sec.2(35) is the primary document for claiming ITC.

  • Taxation of works contracts is altogether new. Under section 4 (7) (a) it is compulsory scheme. There are three types of composition schemes. Section 4 (7) (b) deals with composition by contractors doing works to State Government and Local authorities and the rate of tax is 4% on gross consideration. Section 4 (7) (c) deals with composition by contractors doing works to others and the rate of tax is 4% on gross consideration. Section 4 (7) (d) deals with composition by the builders who construct and sell houses, flats etc., and the rate of tax is 4% on 25% (effective rate is 1%) of the consideration received or receivable or the market value fixed for the purpose of stamp duty whichever is higher.

  • If the contractor paying tax under composition scheme brings/purchases goods from other States/countries/non-VAT dealers in A.P., tax has to be paid at the rates of tax mentioned in the Schedules on the value of such goods and not at the rate of composition.

  • TCS provision in section 22(3) is meant for contractors executing works for State Government and Local authorities. TDS provision in section 22 (4) is for other contractors. These two provisions were struck down by the Hon’ble High Court of AP in the case of L & T Limited vs. State of AP and Others (43 APSTJ 31). Consequent on the said decision, amendments are being made to these two sub-sections.

  • In another decision in the case of L & T Limited vs. State of AP and Others (43 APSTJ 77), the Honourable High Court of A.P., held that there can be only one taxable event of sale in the execution of works contract and that either the main contractor or the sub- contractor has to be taxed but not both under the VAT law.

  • The tax payable every month is output tax minus input tax credit. See Rule 19(3) for the formula.

  • There is no registration fee for getting registration. Every VAT dealer must be in possession of Tax-payer Identification Number (TIN) and every TOT dealer must be in possession of General Registration Number (GRN).

  • Entry tax paid under Entry Tax Act, 1996 (for motor vehicles) and Entry Tax Act, 2001 (for other notified goods) can be adjusted against VAT payable in the same tax period. See sec. 22(5).

  • Deputy Commissioner has power to grant instalments in case of arrears of tax.

  • There is no concept of yearly assessment. The entire scheme is ‘self-assessment’. ‘Tax period’ is a calendar month. The assessing authority may make an assessment, for example, for one month, 7 months, 13 months, 28 months etc. Audit by the Chartered Accountant/Sales Tax Practitioner has not been provided under the Act.

  • Provisions relating to appeals and revisions continue to be the same as in the repealed APGST Act, 1957.

  • ITC can be claimed in respect of the stocks held as on 1-4-2005, if such goods including capital goods were purchased during the period from 1-4-2004 to 31-3-2005. (See Rule 37). Inventory of stocks has to be prepared by 7-4-2005 and the claim must be filed before 10-4-2005. The amount of claim approved by the authority can be claimed in 6 equal instalments from August, 2005.

  • Amount representing excess ITC is to be refunded to the exporter within 90 days of the claim. (sec.38). In respect of dealers, other than exporters, refund of excess ITC is to be granted at the end of the second year after 1-4-2005; i.e., in April, 2007. Thereafter, it would be annual refund. However instructions have been issued in G.O.Ms. No.1580 Revenue dated 28-10-2006 to the effect that ITC up to Rs. 10,000 can be refunded by 31-10-2006 without pre-audit, credits between Rs. 10,000 and Rs. 50,000 to be refunded by 31-12-2006 without pre-audit, subject to furnishing of indemnity bond/bank guarantee, credits between Rs.50,000 and Rs.10 lakhs to be refunded by 31-12-2006 after conducting audit and credits exceeding Rs.10 lakhs to be refunded in April, 2007.

  • There is no power conferred on the Government to grant any exemption or reduction in the rate of tax. Hence no Notifications can be issued for this purpose by the Government.

  • Sec. 41 (3). The Commissioner may get the books of account maintained by any dealer audited by a Chartered Accountant or Cost Accountant or an enrolled Sales Tax Practitioner for any tax period. No circumstances and no guidelines are specified for getting such audit done.

  • Border Check posts and way bills continue to be there.

  • New concept in VAT law is ‘Advance Ruling’. A committee is constituted with Additional Commissioner as Chairman and two Joint Commissioners as members. (sec. 67).

  • Industrial Units availing tax holiday (exemption) have to compulsorily get converted into tax deferment units. On such conversion into tax deferment scheme, while the balance amount to be availed as on 1-4-2005 remaining the same, the balance period available as on 1-4-2005 will be doubled. (Rule 67). After 1-4-2005, there are no Tax Holiday units in A.P.

  • Importance is given to ‘time to apply for registration’. (Rule 5). ‘Effective date of registration’ has also its importance.

    (Rule 6.)

  • Another new concept is ‘Start up business’. (See Rule 9).

  • There is provision to file revised return, which is not there under the APGST Act. It has to be filed within six months of the relevant month. (Rule 23 (6)(a).

  • Where a VAT dealer fails to file a return, there is ‘unilateral assessment’, in which case, no show cause notice will be issued. (Rule 25 (1). If the return is filed, such assessment will be withdrawn. However penalty as in sec. 54 (3) becomes payable.

  • Rules 29 to 34 deal with the records to be maintained by the dealers.

  • Various authorities are prescribed under Rule 59.