1. Dahisar CPE Study Circle
Recent Changes in Form 704
By
CA. Nimesh Dedhia

2. Amendment to Form 704
 Notification
– New version 2.0.0 of Form 704 introduced by
Notification No.VAT/AMD/2013/1B/ADM-8
dated 23/08/2013.
 Made changes in:
Letter of Submission
Part-1
Schedule – I, III, IV & V
Annexure – E
Annexure – G
Annexure – I
Annexure J1 & J2
Removal of Annexure J3 & J4

3. Letter of Submission
• Previously dealer was required to submit Balance Sheet,
Profit & Loss Account, Statutory / Tax Audit Report, Trial
Balance in case of Multi-State Activity and Part-I of Form 704
along with Letter of Submission.
• Then by Trade Circular No.16T of 2011 dated 11/11/2011
they have removed the requirement to submit Balance Sheet,
Profit & Loss Account, Statutory / Tax Audit Report and Trial
Balance in case of Multi-State Activity from the year 20102011.
• Now they have removed the “Enclosures” & as per the
instruction no.27 delar is now required to submit only Letter of
Sumission & Ack of Form 704 filed.
• Submission of Part-1 is required or not?

4. Letter of Submission
• Now if dealer is accepting the auditor’s recommendation & tax
is payable, dealer is required to give payment details in Letter
of Submission.

5. Part - 1
• Previously words were used as “We here by annex a copy of
……” & “ And annexed herewith…..”

6. Part - 1
• In table-1, serial no.5(a)(ii) return in form 424 is inserted along
with form 405.

7. Part-1
• In table-1, serial no.2(B)(b) selection of annexure J3 & J4
have been removed.
• In table-1, serial no.2(B) clause (C) & (d) are clubbed as
clause (c).

8. Part-1
• Clause (d) and Clause 7 below table 5 are newly inserted.

9. Part-1
• Enclosures at the end of Part-1 are deleted

10. Schedule – I, III, IV & V
• There are few changes in this schedules
with respect to Purchase tax on Purchase
of Cotton or Oil seeds from Unregistered
Dealer and transferred to OMS Branches
or Agents or used in Manufacturing of tax
free goods or taxable goods & goods so
manufactured are transferred to OMS
Branches or Agents. The said changes
has been made due to insertion of Section
6A & 6B w.e.f. 01.05.2012.

11. Schedule – I, III, IV & V
• Clause f1 has been newly inserted to provide for
“Any other e.g. Purchase Tax, Late Fee (Please
Specify)” (Clause a1 is also inserted for Purchase
Tax, so why they have mentioned Purchase Tax in
Clause f1 also?)

12. Annexure - E
• Heading changed to “Computation of set-off claim on the
basis of Tax Paid Purchases” from “Computation of set-off
claim on the basis of Tax Paid Purchases effected from
Registered Dealers”
• Section-1 heading changed to include Purchase Tax paid on
URD Purchases. New raw inserted to incorporate purchase
tax payable.

13. Annexure - E
• In Section-2 new row no.12 is inserted to incorporate
purchase of taxable goods from registered dealer on which
set-off is not claimed.

14. Annexure - E
• Section-4 : The row no.3 has been divided into row no.3 &
row no.3A

15. Annexure - E
• Section-5 : The row no.10 & 11 has been inserted to provide
details of total tax paid purchases effected from registered
dealers on which set-off is calculated and allowed under rule
52A & 55B along with Rule 52.
52A. Set-off in respect of goods manufactured by Mega Unit
55B. Applicability of set-off to developers and units in Special Economic Zone.

16. Annexure – G, I, J1 & J2
• Annexure – G : Additional rows has been
inserted upto 5000 in place of 1000.
• Annexure – I : Additional rows has been
inserted upto 5000 in place of 1000.
• Annexure – J1 : Additional rows has been
inserted upto 5000 in place of 1000.
• Annexure – J2 : Additional rows has been
inserted upto 5000 in place of 1000.

17. Removal of Annexure J3 & J4
• Both the annexure J3 & J4 have been
removed.
• So now details of Debit Note & Credit Note
required to be net off with J1 & J2.
• This changes in line with annexure filed for
non audit cases.
Issue:
If there is only Purchase Return or Sales
Return of any party, where to give detail?

18. Thank you
Email: nmdedhia@gmail.com