FILING OF RETURNS UNDER GST INCLUDING MATCHING OF INPUT TAX CREDIT

FILING OF RETURNS UNDER GST INCLUDING MATCHING OF INPUT TAX CREDIT

DRAFT RETURN FORMS FORM NO DETAILS 1. GSTR 1 Details of outward supplies of taxable goods and/or services effected 2. GSTR 01A Details of outward supplies as added, corrected or deleted by the recipient 3. GSTR 02 Details of inward supplies of taxable goods and/or services claiming input tax credit 4. GSTR 02A Details of inward supplies made available to the recipient on the basis of FORM GSTR-1 furnished by the supplier 5. GSTR 03 Monthly return on the basis of finalization of details of outward supplies and inward supplies along with the payment of amount of tax 6. GSTR 03A Notice to a registered taxable person who fails to furnish return under section 27 and section 31 7. GSTR 04 Quarterly Return for compounding Taxable persons

DRAFT RETURN FORMS FORM NO DETAILS 8. GSTR 04A Details of inward supplies made available to the recipient registered under composition scheme on the basis of FORM GSTR-1 furnished by the supplier 9. GSTR 05 Return for Non-Resident foreign taxable person 10. GSTR 06 ISD Return 11. GSTR 07 Return for authorities deducting tax at source 12. GSTR 07A TDS Certificate 13. GSTR 08 Details of supplies effected through e-commerce operator and the amount of tax collected as required under sub-section (1) of section 43C 14. GSTR 09 Annual Return 15. GSTR 09A Simplified Annual return by Compounding taxable persons registered under section 8

FORM NO DETAILS 16. GSTR 09B Reconciliation Statement DRAFT RETURN FORMS 17. GSTR 10 Final Return 18. GSTR 11 Details of inward supplies to be furnished by a person having UIN

Details of Outward Supply GSTR 1 Sec 37 Every registered person shall file this return except following persons Input Service Distributors A non-resident taxable person Persons covered under Composition scheme Persons responsible for TDS and TCS To be filed on or before 10 th of following month. Registered Person can not file this return between 11-15 of each month Delay in filing cause payment of late filing fee Aggregate turnover of previous year reported First year manual entry Subsequent years auto populated

Details of Outward Supply GSTR 1 Sec 37 Furnishing invoice level detail is must for all B2B transactions. For B2C transactions, except inter state supply > 2.5 lakhs per invoice, give consolidated details. Indication of HSN / SAC code in the return. Not mandatory for preceding FY TO < 1.5 Crore (Both HSN/SAC) Preceding FY TO > 1.5 C < 5 C Minimum 2 digit HSN is mandatory from second year First year optional SAC is mandatory Preceding FY TO > 5 C Minimum 4 digit HSN & SAC are mandatory For all exports 8 digit HSN code is mandatory Commissioner may extend time limit for furnishing this return for reasons to be recorded in writing. If extended by CGST commissioner, it shall be deemed that SGST commissioner has also extended and vice versa.

Format of GSTR 1 & 2A

Details of Inward Supply GSTR 2A&2 Sec 38 Receiver is required to validate the details (as reflected in GSTR 2A & 4A in case of compounding dealers) furnished by supplier. The receiver is required to verify, validate, modify, or even delete, if necessary the details furnished by supplier. In addition to inward supply details, following details shall also be available in 2A ISD credit received (Auto-populated from GSTR 6 filed by ISD) TDS deducted by specified persons. (Auto-populated from GSTR 7 filed by deductors) TCS collected by E-commerce operator (Auto-populated from GSTR 8 filed by e-commerce operator) On or before 15 th of following month, any modification, deletion or inclusion of inward supplies by the receiver shall be furnished in GSTR 2. This shall be communicated to supplier in Form GSTR 1A

Details of Inward Supply GSTR 2A&2 Sec 38 Supplies on which RCM is liable to be paid shall be auto-populated from GSTR 1 to GSTR 2A. Details relating to import of goods and import of services shall also be given in GSTR 2 If supply is received in more than one lot, the invoice information should be reported in the return period in which last lot is received and recorded in books of accounts.

Format of GSTR 2 & 1A

Monthly & Quarterly Returns GSTR 3,4&4A Sec 39 GSTR 3 is applicable to all regular tax payers other than persons opted for Composition scheme. (Auto populated from GSTR 1,2,6,7,8, E- cash/credit/tax liability ledger) Due date for payment of tax and filing this return is 20 th of following month. All compounding taxable persons are required to file GSTR 4 on or before 18 th of month following quarter along with payment of tax. Any person registered as Input Service Distributor shall file GSTR 6 every month on or before 13 th of the month succeeding calendar month. All non-resident taxable persons file GSTR 5 every month on or before 20 th of the calendar month or within 7 days after the last day of the period of registration specified in section 27(1) whichever is earlier. Commissioner may extend time limit for furnishing this return for reasons to be recorded in writing. If extended by CGST commissioner, it shall be deemed that SGST commissioner has also extended and vice versa.

Monthly & Quarterly Returns GSTR 3,4&4A Sec 39 Filing of nil returns are also compulsory even if no transactions have happened in any tax period. Rectification of Returns No provision exist as to filing of revised returns. In case of any errors/omissions made in earlier return can be corrected in the month or quarter where such errors are noticed by stating the relevant original invoices / debit notes / credit notes of earlier tax period. Above rectification cannot be done when these errors or omissions are found as a result of any audit, scrutiny, inspection or any enforcement activity by the department. No such rectification of any omission or incorrect particulars shall be allowed after the due date for filing of return for the month of September or second quarter following the end of the financial year, or the actual date of filing of relevant annual return, whichever is earlier.

Monthly & Quarterly Returns GSTR 3,4&4A Sec 39 It would not be possible for a taxable person to file a return for the current tax period unless all returns for earlier tax periods are filed by him. A registered person, claiming refund of any balance in the electronic cash ledger in accordance with the provisions of sub-section (6) of section 49, may claim such refund in Part B of the return in FORM GSTR-3 and such return shall be deemed to be an application filed under section 54. Where the time limit for furnishing of details in FORM GSTR-1 under section 37 and in FORM GSTR-2 under section 38 has been extended, return in FORM GSTR-3B, in lieu of FORM GSTR-3, may be furnished in such manner as may be notified by the Commissioner.

Format of GSTR 3

Matching, Reversal and reclaim of Input Tax Credit

Various cases under Matching of ITC SITUATION All Transactions where Input credit details of recipient are matched for output tax as stated by supplier and recipient. Transactions where input credit as claimed by the recipient is less than the output tax as declared by the supplier in their return Transactions where the input tax credit is duplicated by the recipient Transactions where the claim for input tax credit is higher than the output tax as declared by the supplier. Duplicated entry by recipient In case supplier corrects the data REMARKS The transactions are treated as matched. The transactions are treated as matched. Shall be communicated to the registered person in FORM GST MIS 1 Mis-match communication to both the parties. If not corrected by supplier the same shall be added to output tax liability of recipient. Interest is also payable. Same shall be added as output tax liability Output tax liability can be reduced by

Matching of Input tax credit Following details of inward supply shall be matched with details of outward supply With outward supplies furnished by corresponding taxable person in his return With the IGST paid on goods u/s 3 of Customs Tariff Act 1975 Fields which are matched GSTIN of supplier GSTIN of recipient Invoice / debit note number Invoice / debit note date Taxable value and Tax amount In case supplier has not paid the tax / filed the returns shall be treated as unmatched. In case time limit for filing of returns are extended, date of matching shall also be extended.

Matching of Input tax credit Where the credit in respect of inward supply is more than outward supply or Where the supplier has not declared the outward supply and the recipient has disclosed inward supply Both the above transactions are treated as unmatched transactions and shall be communicated to both parties. Where the supplier has not rectified above discrepancy in his valid return the same shall be added to output tax liability of recipient. Subsequently if the supplier has accepted in the subsequent return the same shall be reduced from the output tax liability of the recipient. In case any interest is paid by the recipient the same shall be eligible for refund by way of credit to his electronic credit ledger. Above communications shall be made in Form GST MIS 1 to the recipient and Form GST MIS 2 to the supplier through the common portal on or before the last date of the month in which matching has been carried out.

Matching of Input tax credit - Examples S.No Particulars Amount 1 Supplier X Ltd 2 Receiver Y Ltd 3 Date of transaction 13-07-2017 4 Taxable value 10,00,000 5 Tax rate 18% 6 Outward supply Tax shown by X Ltd 1,80,000 7 Inward supply claimed by Y ltd 3,60,000 8 Return filed on 20-08-2017 9 Date of communication of mis-match 31-08-2017 10 Supplier to correct on or before 10-09-2017 11 Supplier not corrected output tax liability added to recipient 12 Interest payable 24% 13 Period of Interest (days) (15-08-2017 to 20-09-2017) 20-09-2017 37 days

Matching of Credit Notes Where the output tax is reduced by outward supplier by issuing a credit note, details of every such credit note issued should be matched with the corresponding reduction in the credit by the recipient of the amount involved in the credit note in his valid return filed for the current or subsequent tax period. E.g. CN for discounts, mistakes in invoice raised by supplier Where above matches communication will be sent to the supplier in GST MIS 3 When credit note and claim for reduction of output tax liability by the supplier exceeds, partly or wholly with the corresponding reduction in input tax credit by the recipient as declared in his returns The discrepancy will be communicated to both parties and shall be added to the output tax liability of the supplier. Form GST MIS 3 to supplier and Form GST MIS 4 to recipient. In case recipient fails to correct the mis-match the same shall be added to the liability of supplier. The supplier has to pay along with interest.

Matching of Credit Notes In case the recipient corrects his GSTR 2 subsequently then the same shall be reduced from the output tax liability of supplier. Interest paid excessively shall be re-credited to supplier s E-Cash ledger. However such interest shall not exceed interest paid by receiver for this transaction.

Matching of credit notes - Examples S.No Particulars Amount 1 Supplier X Ltd 2 Receiver Y Ltd 3 Date of Credit Note 13-07-2017 4 Taxable value 10,00,000 5 Tax rate 18% 6 Tax reduced by X Ltd in Aug 2017 1,80,000 7 Input Tax reduced by Y ltd Nil 8 Return filed on 20-08-2017 9 Date of communication of mis-match 31-08-2017 10 Recipient to correct on or before 15-09-2017 11 Recipient not corrected output tax liability added to Supplier 12 Interest payable 24% 13 Period of Interest (days) (15-08-2017 to 20-09-2017) 20-09-2017 37 days

Quarterly Returns 4&4A Sec 39 All inward supply & TDS details shall be auto-populated in 4A from GSTR 1 filed by outward suppliers TDS return (GSTR 7) filed by deductors GSTR 4 needs to be filed on or before 18 th of month following the quarter from the inputs received from 4A Compounding dealer is allowed to add, modify or even delete if required of the entries auto-populated in GSTR 4A. Compounding dealer will not have E-Credit ledger but have E-Tax liability register and E-Cash ledger. From the E-cash ledger he is required to discharge all his dues. A compounding dealer will report invoice wise details of his inward supplies (forward charge, reverse charge and import transactions) but consolidated details of his outward supplies.

Format of GSTR 4&4A

Returns by Non-Resident Taxable person GSTR 5 Required to file monthly return on or before 20 th of following month or 7 days within end of his registration period whichever is earlier. Not eligible to take CGST and SGST credit Section 17(5)(f) of CGST / SGST Acts. However eligible to take IGST credit. Hence, there will not be CGST / SGST credit columns in the return. He is required to report closing stock of goods for each month tax period.

Format of GSTR 5

ISD Returns GSTR 6 ISD shall file return in GSTR 6 on the basis of auto-populated entries in GSTR 6A ISD can add or modify or delete the entries auto-populated in GSTR 6A There will be separate ISD ledger in the return that will detail the opening balance of ITC (to be auto-populated on the basis of previous return), credit of ITC services received, debit for ITC reversal and ITC distributed and closing balance. Due date for filing the return is 13 th of following month. ISD is not liable under RCM hence RCM entries will not be available in the return.

Format of GSTR 6&6A

TDS & TCS Returns GSTR 7&8 To be filed on or before 10 th of every month. Entries in this return shall be auto-populated to GSTR 2A & 4A. Certificate of deduction shall be made available in GSTR 7A

Annual Return GSTR 9 & 9A Final Return 10 Reconciliation Statement in 9B Annual Return GSTR 9 & 9A Due date is 31st December of following year. GSTR 9A is for compounding dealers and GSTR 9 is for other dealers. Reconciliation Statement duly certified by Chartered Accountant or Cost Accountant GSTR 9B As per section 42, every registered shall get his accounts audited by CA or CMA and submit reconciliation statement in GSTR 9B. Due date is 31st December of subsequent financial year. Final Return by persons cancelling Registration Certificate GSTR 10 Within 3 months from the date of cancellation final return is to be filed.

LEVY OF LATE FEE SEC 47 Delay in filing Annual Return Rs 100 per day for each of day of default subject to a maximum of quarter percentage of his turnover in the state or Union Territory. Delay in filing other returns Rs 100 per day for each day of default subject to a maximum of Rs. 5000

Critical points to be seen before first GST return Statutory Forms of old period Clear all the pending forms on or before 30 th June. If it is not received before appointed day better pay off the liability and raise debit notes to customers. Perform cenvat credit reconciliations before appointed day All missed out credits are to be taken (subject to 1 year limitation which is not applicable for capital goods). Because if not carried forward in GST not possible to take later. Cenvat credit would not have been taken just for the reason that audit person has advised that these are not creditable kindly check the eligibility as per CCR and take credit before June 30th

Critical points to be seen before first GST return No concept of centralized billing in GST. If Service provider has centralized billing now needs to take state wise registration change in billing pattern is essential customer agreements need to be changed. Dispose of all the existing cases with the department especially with regard to cenvat credit. As per section 142(6)(a) in case out come comes in the new law only refund route is permissible and no credit is available. Stock transfer to other states 5% reversal is essential as per TNVAT Act Now it is essential to think of the need to retain stocks which are not going to be sold up till 30 th June, 2017.

Critical points to be seen before first GST return Depreciation condition continues in GST also If cenvat is taken on duty portion then depreciation is not available in GST also. Balance 50% on capital goods for all the previous years kindly check whether correctly availed. See all your vendors list wherever bulk goods have been purchased from dealers who have got FSD but duty not passed on enquire Though goods are received from FSD or SSD or registered importer always see incase the FSD/SSD has taken credit u/s 140(3) always ensure that he passes on the benefit by way of reducing the prices.

Critical points to be seen before first GST return Rule 6 of Cenvat Credit Rules verify the formula followed incase excess credit has been taken attempt it to take back very example manufacturer also having trading turnover Rule 6 followed but 6% or proportionate reversal is not on the basis of entire sales turnover but only on 10% of COGS. Amendment in Apr 16 in Rule 6 go by common credit only and not the total credit taxable credit take full credit exclusive exempted don t take take only the common credit for rule 6 reversal. During audit RCM liability would have been shown but may not have been availed avail before 30.06.2017

Critical points to be seen before first GST return Post pone purchase decision even acquisition of assets for official use since the same will be available as credit post GST. This point is very vital in respect of traders. Wherever rate is higher in GST always try to liquidate the stock as much as possible. Present pricing mechanism Relevance of Fiat India case now

LIST OF FORMS FOR PAYMENTS S.No Form No Title of the form 1 GST PMT 01 Electronic Liability Register of registered person (Part I: Return related liabilities (Part II: Other than return related liabilities) 2 GST PMT 02 Electronic Credit Ledger 3 GST PMT 03 Order for re-credit of the amount to cash or credit ledger on rejection of refund claim 4 GST PMT 04 Application for intimation of discrepancy in Electronic Credit Ledger/Cash Ledger/Liability Register 5 GST PMT 05 Electronic Cash Ledger 6 GST PMT 06 Challan for deposit of Goods and Services Tax 7 GST PMT 07 Application for intimating discrepancy in making payment

ELECTRONIC CASH LEDGER (FORM GST PMT 05) SEC 49 Deposit of tax, interest, penalty, fee or any other amount by a taxable person credited to this ledger. Payment mode Internet banking Credit / debit card NEFT RTGS Over the Counter Payment through authorized banks (thro cash/cheque/dd) up to Rs. 10000 per Challan per tax period. Limit thro OTC not applicable to Govt depts and PO recovering any outstanding during investigation Any other mode as may be prescribed

ELECTRONIC CASH LEDGER (FORM GST PMT 05) SEC 49(1) STEPS INVOLVED Generate a challan in Form GST PMT 06 on the common portal Such challan shall be valid for 15 days A temporary identification number shall be generated Date of credit in govt account is deemed to be date of deposit and not the actual date of debit to taxable person s account. (Unlike the present law) On successful credit a Challan Identification Number (CIN) shall be generated. After generation of CIN the same shall be credited to EC ledger. In case no CIN is generated or no communication is sent to common portal Use Form GST PMT 07 for intimating the discrepancy.

ELECTRONIC CASH LEDGER (FORM GST PMT 05) SEC 49(1) STEPS INVOLVED Amount available in E Cash ledger may be used to pay tax, interest, penalty, fee or any other amount payable under the Act in the manner prescribed. TDS deducted u/s 51 or TCS collected u/s 52 shall be credited to this ledger. Amount claimed as refund shall be debited to E cash ledger. If the refund claimed is rejected either partially or fully the amount debited earlier to the extent of rejection shall be recredited.

ELECTRONIC CREDIT LEDGER (FORM GST PMT 02) SEC 49 Every claim of input tax claimed shall be credited to this ledger and include following ITC on inward supplies from registered tax payers ITC distributed by ISDs ITC on Input of Stock held/ semi-finished goods or finished goods held in stock on the day immediately preceding the date from which the taxpayer became liable to pay tax Provided he applies for registration within 30 days from the date of his liability. Permissible ITC on inputs held in stock and inputs contained in semi- finished or finished goods held in stock on the day of conversion from composition scheme to regular tax scheme. Credit carried forward during transition period ITC eligible on payments made on RCM.

ELECTRONIC CREDIT LEDGER (FORM GST PMT 02) SEC 49 In case of any discrepancy noticed registered person may communicate the same through Form GST PMT 04 Amount in E Credit ledger may be used to pay output tax payable under the Act. Amount claimed as refund shall be debited to E credit ledger. If the refund claimed is rejected either partially or fully the amount debited earlier to the extent of rejection shall be recredited.

ELECTRONIC CREDIT LEDGER (FORM GST PMT 02) SEC 49 MANNER OF UTILISATION OF ITC INPUT TAX IGST CGST SGST UTGST OUTPUT TAX IGST CGST SGST/UTGST CGST IGST SGST IGST UTGST IGST

ELECTRONIC TAX LIABILITY LEDGER (FORM GST PMT 01) SEC 49 This ledger is debited by following amount Amount payable towards tax, interest, late fee or any other amount payable as per return filed as determined by proper officer during investigation or otherwise Amount of interest payable as a result of mis-match u/s 42/43. Any amount of interest that may accrue from time to time. Above liability shall be discharged by credit of following amounts TDS u/s 51 / TCS u/s 52 reflected in E-Cash ledger. Amount from E Credit ledger Amount from E Cash ledger

ELECTRONIC TAX LIABILITY LEDGER (FORM GST PMT 01) SEC 49 ORDER OF DISCHARGE OF TAX Self assessed tax and other dues arising out of previous tax periods Self assessed tax and other dues arising out of current tax periods Liability arising out of demand notice or adjudicated proceedings PRESUMPTION AS TO INCIDENCE OF TAX IS PASSED ON Unless otherwise proved it shall always be presumed that incidence of tax on goods or services is passed on. All ledgers are state specific balance of one state ledger can not be used to pay another state liability

PROVISIONS RELATING TO INTEREST ON TAXES PAID SEC 50

PROVISIONS RELATING TO INTEREST SEC 50 CIRCUMSTANCES WARRANTING PAYMENT OF INTEREST 1. Delay in payment of taxes either in full or part including delay in deposit of TDS / TCS. 2. Undue / excess claim of input tax credit u/s 42(10) For recipient 3. Undue / excess reduction in output tax liability u/s 43(10) For Supplier RATE OF INTEREST Not exceeding 18% for circumstance 1 above Not exceeding 24% for circumstance 2&3 above

PROVISIONS RELATING TO INTEREST SEC 50 OTHER IMPORTANT POINTS ON INTEREST Manner of computation of interest No SCN if tax + interest is paid hence no penalty Sec 73 (5)&(6) If tax + interest is paid within 30 days of receipt of SCN no penalty is payable Sec 73(8) The provision is similar to Excise and service tax provisions. In VAT laws it is at the discretion of adjudicating authority to drop the penalty. Some states have mandatory penalty provisions. Hon ble SC in the case of Prathiba Processers Vs UOI held that interest provision is automatic since it is compensatory in nature and not penal in character.

PROVISIONS TAX DEDUCTED AT SOURCE SEC 51

PROVISIONS RELATING TO TDS SEC 51 PERSONS LIABLE TO DEDUCT TDS Department / establishment of Central / State Governments Local Authorities Government Agencies Persons or category of persons notified by government on the recommendation of the council. 1% on payment or credit made on the notified supply of goods / services. Total value of supply under a contract exceeds Rs. 2.5 lakhs No deduction if location of supplier and place of supply is in a state or UT which is different from the state or UT of registration of recipient. Due date of deposit is 10 th of following month of deduction

PROVISIONS RELATING TO TDS SEC 51 Payment of TDS by debit to E-cash ledger TDS certificate in GSTR 7A containing following Contract value Rate of deduction Amount deducted Amount paid to the appropriate government Any other particulars as may be prescribed TDS certificate to be given within 5 days of remittance. If certificate not given late fee of Rs. 100 per day from 6 th day onwards subject to a maximum of Rs. 5,000 Non-remittance of TDS attracts interest as per sec 50(1) Deductors to file GSTR 7 on or before 10 th of following month

PROVISIONS RELATING TO TDS SEC 51 After filing of GSTR 7 TDS shall be reflected in E-cash ledger of deductee. Excess / erroneous remittance can be claimed as refund as per sec 54 subject to a condition that the amount is not credited to E-cash ledger of deductee.

PROVISIONS RELATING TO TDS SEC 51 COMPARITIVE REVIEW OF TDS PROVISIONS S.NO State VAT Laws CGST / SGST Act 1 Applicable only to Works contractors Applicable to supplies notified 2 Two different standard rates Only one rate of 1% - but CGST 1+SGST 1 3 Refund provisions are not clear They are clear 4 TDS at the time of payment made Payment or credit in books 5 No TDS on Interstate supplies

PROVISIONS TAX COLLECTED AT SOURCE SEC 52

PROVISIONS RELATING TO TCS SEC 52 RELEVANT DEFINITIONS Sec 2(41) - electronic commerce means supply of goods or services or both including digital products over digital or electronic network Sec 2(42) - electronic commerce operator means any person who owns, operates or manages digital or electronic facility or platform for electronic commerce Whether OLX / Quickr e-commerce operator and liable for TCS?

PROVISIONS RELATING TO TCS SEC 52 Exception from Collection of TCS by E-com operator Where services provided by the operator covered by Sec 9(5) of the Act. Where consideration is paid directly by the recipient to supplier If the operator is just an agent like quickr / olx Failure to collect tax will attract penalty of Rs. 10000 or TCS whichever is higher sec 122(1) Operator to file GSTR 8 on or before 10 th of following month Supply of goods / services made through it TCS to be remitted within above date. Entries of GST 8 shall be auto-populated to Part D of GSTR 2A TCS to reflect in E-Cash ledger of Suppliers. Annual TCS statement to be filed by operator before 31 st

PROVISIONS RELATING TO TCS SEC 52 Mis-match between value of supplies reported by operator and supplier in their respective returns shall cause Mismatch enquiry from the proper officer. If mis-match not corrected by supplier offence gets confirmed Under reporting by supplier shall cause to be paid along with interest u/s 50. An officer not below the rank of DC may issue notice to operator to produce details of supplies effect through it or stock of goods of suppliers held in the warehouse managed by operator. Failure to reply for the notice within 15 days may cause penalty up to Rs. 25,000/-

CERTAIN CRITICAL ASPECTS IN PAYMENT PROCEDURES

CERTAIN CRITICAL ASPECTS 1. Mr A has supplied goods worth of Rs. 1 lakh to Mr B. Mr. B has refused to pay GST of 18% on the supply. However, he has paid Rs. 1 lakh in full payment. a) Whether Mr A is relieved from his liability? b) Can Mr A pay GST on inclusive basis? 2. Would the solution be different in case in the above example Mr A has collected tax of 12% instead of 18%. 3. In the above example, in case Mr A has collected 28% instead of actual 18% tax, can he retain the excess amount collected? (Sec 76) 4. Is it mandatory for Mr A to disclose amount of tax in case as per contract price is inclusive of all taxes? 5. Above supply is actually Inter state supply but Mr A has wrongly considered as Intra-state supply. (Sec 77) 6. In case in a e-commerce transaction a customer has refused to accept the supply when the transaction is on COD?