Suggestions on special rules for delivery of goods and services without sales tax

The Central Board of Revenue has taken a very positive and long-awaited step to comfort the manufacturers-cum-exporters by introducing the special rules without sales tax for delivery of goods and services. I would like to give some suggestions to improve the provisions of the above rules to make them more effective and efficient.
For the purpose of computing 80% export out of the total manufactured products, it is suggested that in addition to the direct export and indirect export by the manufacturer-cum-exporter in the form of local supplies to those buyers who take such local supplies for future export should also be considered. All such local supplies, by the manufacturer-cum-exporter, meant for future export be charged at zero rate.
Wherein exceptional case, for reasons beyond the control of the manufacturer-cum-exporter or when master L/C is cancelled and the manufacturer-cum-exporter cannot export his finished goods within 12 months from the date of the first procurement or within the extended period as per rules, no penalty should be charged u/s 33 of the Sales Tax Act 1990 for selling the product in the local market since the default is not wilful.
Additional tax at a specialised rate (around the prevailing market rate of interest) may be charged to compensate the exchequer for the delayed receipt of the revenue (sales tax due on local supplies).
The manufacturer-cum-exporter should be required to file a monthly/quarterly activity report along with the return instead of filing with the department each L/C opened. This would reduce the unnecessary burden on both the tax-payer and the department.
The tax-payer would be saved from the filing exercise each time the L/C is opened and the department would be saved from maintaining and piling up the records of such LCs. However, an effective system of on the desk review of the monthly/quarterly activity report containing brief particulars of the LCs, including consumption of inputs and export of finished goods and inventory, be implemented, followed by an effective periodical audit as already envisaged in the draft rules. It would be better if the entire system should be on a supervised-self-assessment basis where the manufacturer-cum-exporter should voluntarily deposit tax due on the export shortfalls.
Though the proposed SRO revolves round the requirement of an inland Letter of Credit (L/C), it may not be practicable for a majority of the manufacturers-cum-exporters having multiple registered suppliers. The problems would increase further in case of services (processing etc).
It is also foreseen that the manufacturers-cum-exporters may have to go through the dual procedures (under the proposed SRO as well as the existing procedure of refund) where in some cases he could meet the requirement of opening the L/C and where he cannot. Besides the above, the manufacturers-cum-exporter would have to incur L/C and other documentary charges.
In view of the above it is proposed that the inland L/C condition be done away with and instead some alternative effective, convenient and economical procedures be devised to check malpractice's, eg, flying invoices. In this case the payments through banking channels may be made more effective in that the manufacturers-cum-exporter may be required to produce evidence beyond doubt for transfer of payment to the genuine suppliers, eg, asking the manufacturers-cum-exporters to provide the details of suppliers along with their bank account nos. which the suppliers must have already disclosed to the sales tax authorities, thereby affording an opportunity for cross check.