GST Composition Scheme-Better or Myth ?

Under various laws, there is a provision of Composition scheme which is for the small businesses and in GST regime also Composition Scheme for many startups and Small & Medium Enterprise (SMEs) has been introduced.

But is it really worthy opting for this scheme? The clear analysis in our blog will help you in forming an opinion.

Benefits of GST composition scheme

As mentioned earlier, the benefits of this scheme will only be available to small taxpayers. Registration for this scheme is optional and the taxpayer needs to apply for it every year. It offers several benefits:

1) Reduced tax liability

Probably the biggest benefit of registering under compounding scheme is the reduction in taxes. Tax rates under composition scheme are expected to be in the range of 1% to 5% which is considerably lower than standard tax rates under regular GST scheme.

2) Limited compliance

Another major advantage of composition scheme is that it promises to reduce the number of documents and processes required for compliance with GST law. Where a normal taxpayer will be required to file a minimum of 3 returns in a month, a compounding dealer will be asked to file only 1 return that is GSTR 4 every quarter of a year.

3) Ease of doing business

Reduced tax liability and limited compliance will make it easy for small businesses to grow and flourish. On one hand, reduced taxes will result in the surge of profit margin while on the other limited compliance will reduce hassles allowing a party to focus more on his business.

Limitation of GST Composition Scheme:

1) No inter-state business:

Tax benefits of GST compounding scheme are only given if a taxpayer carries his business within the boundaries of a state. A taxpayer registered under the composition scheme is barred from carrying out inter-state transactions and cannot affect import-export of goods and services. Thus, he is compelled to carry only intra-state transaction and limits the territory of his business.

2) No Credit of Input Tax:

Compounding scheme has no provision of input credit on B2B transactions. Therefore, if any taxable person is carrying out business on B2B model, such person will not be allowed the credit of input tax paid from the output liability. Also, the buyer of such goods will not get any credit of tax paid, resulting in price distortion and cascading effect.

3) Pay tax from your own pocket:

Although the rate of composition/ compounding tax is expected to be very low, a taxpayer under this scheme is not allowed to recover such tax from his buyer. The taxpayer is not allowed to raise a tax invoice. Consequently, the burden of such tax is kept on the taxpayer himself and this has to be paid out of his own pocket.

4) Penal provisions:

While taking advantage of GST Composition Scheme, one needs to take utmost care as the penalty is severe. If the taxpayer is found wrongly registered under this scheme while not fulfilling eligibility criteria and therefore avoiding normal taxes. Then the person will have to pay normal taxes along with penalty equal to 100% of normal taxes levied upon him.

After understanding the Pros and Cons of GST Composition scheme we are sharing our Analysis of this scheme:

GST Composition Scheme has no double taxation element and does not run contrary to the concept of GST.

However, any small manufacturer is not allowed to take input credit of his purchases and again he is paying the turnover tax of 2%. It looks simple but, there is a catch in this scheme as explained.

When he sells his goods, it is the BILL OF SUPPLY and he is not collecting any tax. But, his buyer has to collect full tax when he further sells the goods in retail. Which means the holder of the Composition scheme is almost at par with the regular taxpayer by paying on turnover apart from sacrificing input credit. This brings him at par with the regular taxpayer.

Besides this we believe that the one who opts for Composition scheme is at the great disadvantage vis a vis Big dealer, in the following scenario: I take the case of two manufacturers.
One like me who opts for the Composition scheme with turnover less than 100 Lacs. Second a big manufacturer who is out of the Composition Scheme.

While making my product, I sacrifice input credit on my inputs and pay 2% GST on my turnover, which works out to be equal to full GST rate. But I am issuing BILL OF SUPPLY to my buyer. Now when my buyer sells the product further he charges full GST say 12% from his buyer but can’t take any input credit on the purchase made from me since it is a bill of supply.

Now take the case of a big dealer against whom I am competing. Such big registered dealer when sells, is allowed to collect tax from the buyer but will claim input credit also so net incidence is very less. And again his buyer when sells further will take input credit of the tax which he paid.

Under the situation, not many will be interested to buy from the dealer with the Composition Scheme like me since the buyer is notionally/apparently burdened with much higher tax burden when he sells the goods further as he is not getting input credit.
So either he will refuse to buy from me or wants me to cut the rate equal to GST rate so that he is not affected.

Therefore we think it needs amendment and the bill of supply from the Composite dealer should be considered as TAX PAID INVOICE for all purposes only then this scheme gives relief to the small dealers. There is nothing wrong in giving it the status of TAX PAID INVOICE sine he is paying 2% tax on turnover and also foregoing input credit which works out equal to the full tax. In the present scenario, he or she can’t compete with the big dealers/manufacturers as explained above.

Further, I see little sense in not allowing them to sell out of state. When he is not allowed to claim input credit he should be allowed to sell anywhere.

Conclusion for GST Composition Scheme:

Therefore we suggest that composition scheme shall be availed only by very small scale businesses whose complete business segment is Business to Customer (B2C).  And we strongly believe that it needs amendment and the bill of supply from the Composite dealer should be considered as TAX PAID INVOICE for all purposes only then this scheme gives relief to the small dealers.

References for GST Composition Scheme: for Composition Scheme


Easy steps for filing Letter of Undertaking (LUT) Under GST for Exports

Most of the registered person wants to avail the option of export without payment of IGST but confused on the process, documentation. The detail in our blog will help you in understanding the process comprehensively :

(1) Any registered person availing the option to supply goods or services for export without payment of IGST shall furnish, prior to export,

  • A bond or
  • A Letter of Undertaking

The format is given in Page 31-33 of GOI resource to the jurisdictional Assistant/Deputy Commissioner.

Inside bond and LUT the exporter conveys that he is binding himself to pay the tax along with the interest specified under Section 50(1) within a period of —

1 Within a period of 15 days after expiry of 3 months. If 3 months have passed after issue of invoice and goods are not exported yet.
2 Within a period of 15 days after expiry of 1 year. If 1 year has passed after issue of invoice and the invoice amount in convertible foreign exchange not credited.


(2) The details of the export invoices contained in FORM GSTR-1 furnished on the common portal shall be electronically transmitted to the system designated by Customs which is Under progress currently and a confirmation that the goods covered by the said invoices have been exported out of India shall be electronically transmitted to the common portal from the said system.

(3) Where the goods are not exported within the time specified in above table and the registered person fails to pay the tax and interest amount mentioned in the above table , the export as allowed under bond or Letter of Undertaking shall be withdrawn forthwith and the said amount shall be recovered from the registered person.

With effect from 04th October, 2017 through Notification LUT/ Bond for Exporters GOI has given following clarification.

All Exporters allowed for LUT

The facility of export under LUT has been now extended to all registered persons who intend to supply goods or services for export without payment of IGST 

Who are not allowed for LUT

Who have been prosecuted for any offence under the CGST Act or the IGST Act, 2017 or any of the existing laws and the amount of tax evaded is 2,50,000 or more.

Documents for LUT

LUT should be on the letter head of company along with following documents :

  1. Letter of Under Taking (Annexure 1.)
  2. Listing of address located in (Name of state ) for GSTN No. …………………..(Annexure 2)
  3. Copy of GSTN along with Additional place of business (Annexure 3).
  4. Circular no. 8/8/2017-GST dated 04th October, 2017 issued relating to letter of undertaking for exports (Annexure 4)
  5. POA Copy of Authorized Signatory (Annexure 5)
  6. Pan Card Copy of Company (Annexure 6)
  7. Pan Card Copy of Authorized Signatory (Annexure 7)
  8. Passport copy of Authorized Signatory (Annexure 8)
  9. Witness Proof Photo ID Proof (Annexure 9)
  10. BRC’s/ FIRC More than 1 Cr. To prove that export realization were more than 1 Cr in 2016-17, if yes (Annexure 10)
  11. Copies of Export Bill/Invoice (Annexure 11)
  12. Undertaking/ declaration on letter (Annexure 12)

Request you please acknowledge the receipt of this letter.


These clarifications bring much needed relief for the exporters with regard to export without payment of IGST. Exports had come to a halt in the absence of clarity on procedure for submission of bond/ LUT for exports. While exporters have option to export by filing of LUT/ Bond or pay IGST and claim refund.


GST Forms for Exporters

Notification for Exporters on 4th Oct, 2017