GST Returns Formats

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-CA Gadia Manish R

GST Returns Formats          

Dated: 27th August, 2018

Currently, the GST Taxpayers are required to furnish the details of outward supplies in form GSTR 1 either monthly or quarterly based on their turnover. They are also required to furnish summarized details of all the outputs and inputs on a monthly basis along with the payment of tax through form GSTR 3B.

GST Council has now SUGGESTED NEW FORMATS OF THE GST RETURNS in the 28thCouncil meeting held on 21st July, 2018 and asked for the feedback from the Taxpayers.

We have highlighted some of the major changes that have been made in the upcoming formats of GST Returns for your ready reference.

Key Features forSUGGESTED Monthly filing of Returns:

  1. For the taxpayers having turnover:
Turnover Limit (Rs.) Currently Followed Proposed Formats
NIL
  • GSTR 3B- Monthly
  • GSTR 1- Quarterly
Quarterly*
Up to 1.5 Cr.
  • GSTR 3B- Monthly
  • GSTR 1- Quarterly
Taxpayer shall file any one of the following:

  •  Quarterly Return–Return will be similar to the monthly returns (with few exceptions).
  • GSTR – Sahaj – B2C Outward Supplies.
  • GSTR – Sugam – B2B and B2C Outward Supplies.
1.5 Cr to 5 Cr.
  • GSTR 3B- Monthly
  • GSTR 1- Monthly (from 1.5 Cr.)
Above 5 Cr.
  • GSTR 3B- Monthly
  • GSTR 1- Monthly (from 1.5 Cr.)

 

 

 

 

 

 

 

Taxpayers shall file the following:

  • Annexures of Supplies to Main Return by 10th of the following month.
  • Annexures of Inward Supplies to the Main Return.
  • Main Return – Form GSTR (auto populated) by 20th of the following month.

*Note 1: A registered taxpayer having no output tax liability and no claim of ITC will have to file one NIL Return on quarterly basis. Further, such taxpayer will be required to send a SMS in the first two months of the quarter in order to report NIL transaction. Facility for filing quarterly return shall also be available by SMS.

Note 2:Taxpayers having turnover of less than Rs. 5 Cr can opt for monthly filing of returns.

  1. The Form GSTR shall have two parts namely:
  • Annexure to main return:
    • Annexure of Supplies to Main Returns (Outward Supplies like GSTR-1):

A) Details of Outward Supplies, Imports and Inward Supplies Attracting Reverse Charge (RCM) shall be reported in the Annexure of supplies to Main Return on invoice to invoice basis.

B) Inward Supplies attracting Reverse Charge Mechanism (RCM) are to be submitted in thisAnnexures.Such supplies shall be reported GSTIN wise (wherever applicable) and net of credit and debit notes.

C) HSN Codes to be reported at 4 digits in case of supply of Goods and incase of Supply of Services HSN Codes shall be reported at 6 digits or more.

  • Annexureof Inward Supplies to Main Returns (Inward Supplies like GSTR-2):
    • Invoices uploaded in Annexure of Supplies shall auto – populateon near real time basis. Recipients have to take action on the same to Accept, Reject or to keep pending.
    • Supplies received from SEZ units may be auto-populated after establishing interface with SEZ online system. Goods imported on bill of entry maybe auto-populated after establishing interface with ICEGATE system.
    • Main Return:As per the data uploaded in the Annexures of Outward and Inward, amount shall auto-populate in the respective heads for computation of GST liability. Taxpayers needs to make payment in cash and file the return.
  1. Following are the key features w.r.t.NewAnnexure of Outward Supplies V/s. old GST Format:

 

Description Form GSTR 1 – Existing System. Annexures of Supplies – Proposed System.
Questionnaire Not Applicable. Applicable – Detailed Questionnaire regarding categories of Outward and Inward supplies needs to be selected.
Supplies to Registered and Un –Registered Person 1.  For Registered Persons – B2B.

  • Separate disclosure of Debit/ Credit Notes.

2.  For Un – Registered Persons separate disclosures:

  • B2Cs (Intra State andfor Interstateup to 2.5 lacs. Amounts are disclosed Net off Debit/ Credit Notes.
  • B2CL (Interstate more than 2.5 lacs). Separate disclosure of Debit/ Credit Notes.

 

1. For Registered Persons – Only B2B.

  • Table includes disclosure for Credit/Debits Notes. No separate table for disclosure of Debit/ Credit Notes.

2. For Un – Registered Persons:

  • Includes all the supplies made to URD.
  • Amount shall be disclosed Net off Debit/Credit Notes.
Advances Received and Adjusted. Separate Disclosure. No Disclosure in Annexures but will be disclosed in Main Return.
Exports Disclosure of Exports with LUT and with payment of Tax under single head “Export Invoices.” Separate disclosure for Exports with LUT and with payment of Tax.

 

SEZ Units / Developers Disclosure was under the head B2B supplies. Separate disclosure for SEZ with LUT and with payment of Tax.
Deemed Exports Disclosure was under the head B2B supplies. Separate Disclosure.
Outward Supplies under Reverse Charge Mechanism (RCM) Suppliers disclosethe details under the head B2B by selecting supplies made under RCM. No disclosure by the supplier.

Disclosure shall be reported by the Recipient.

  1. Procedure for availing ITC in Current system VS Proposed system.
Description Form GSTR 3B – Existing System Annexure of Inward Supplies – Proposed System
Forms Form GSTR 2 – Currently not to be filed.

Currently ITC is availed on self-assessment basis via Form GSTR- 3B.

Annexure of Inward Supplies- Details of auto populated supplies.

 

 

Supplies received from B2B

 

  • Consolidated figures under the head Eligible ITC.

 

 

 

 

 

  • Invoices uploaded by supplier are auto populated in Annexure of Inward Supplies.
  • Taxpayer needs to take action of Accept, Reject or keeps the invoice pending.
Inward Supplies paid under Reverse Charge Mechanism (RCM).
  • The person claiming such credit needs to report the total amount of such credit in Form GSTR- 3B.

 

 

 

 

 

 

  • No disclosure is required to be made in this Inward Annexure. Import and SEZ transactions will get auto populated here.
  • Rest other RCM’s (i.e., GTA, Legal Services etc.)  relatedamount will auto populate in the main return.
Availing of Input Tax Credit. ITC is availed on self-assessment basis by disclosing the overall figure.

 

 

ITC is to be availed by taking actions against all the invoices which are auto-populate in the Annexure of Inward Supplies.
Reversal of Input Tax Credit.
  •  ITC is reversed by disclosing the figures under head “ITC Reversed.”

 

 

 

  • Invoice level ITC not claimed needs to be done in this annexure.
  • Other reversal of ITC is to be done in the main return.

 

For Example:

Where the supplier has issued three invoices for the month of July i.e. Invoice No. 1, 2 and 3 respectively, hehas disclosed the invoices as follows:

Invoice No. 1 – Uploaded on 8th August.
  •  Recipient can avail the Input Tax Credit in the return of July which is to be filed on 20th August.
  • Recipient can take action on these invoices Accept/ Reject/ Pending from 11th August.
Invoice No.3 – Uploaded on 13th August (i.e., after 10thAugust)
  • Invoice would be accounted towards the liability payable by the supplier in his return of the tax period of July.
  • Recipient will have to avail the Input Tax Credit in the return of August which is to be filed on 20thSeptember.
  • In the transition phase of six months after the new system of return is implemented, the recipient will be able to avail input taxon self-declaration basiscredit even on the invoices not uploaded by the supplier by 10thof the next month or thereafter using the facility of availing input tax credit on missing invoices.
Invoice No. 2 – Not Uploaded by the supplier.
  • Such invoices will be called as “Missing Invoices.”
  • In the transition phase of six months after the new system of return is implemented, the recipient would be able to avail input tax credit on self-declaration basiseven on the invoices not uploaded by the supplier by 10th of the next month or thereafter using the facility of availing input tax credit on missing invoices.
  • Missing invoices shall be reported by the supplier in the main return for any tax period with interest or penalty as applicable. Reporting of missing invoices by recipient can be delayed up to two tax periods to allow recipient to follow up and get the missing invoice uploaded from the supplier. Information about missing invoice uploaded by the recipient shall be made available to the supplier. Taxpayers filing quarterly returns shall report missing invoices in the next quarter.
  • In case of default in payment of tax by the supplier, recovery shall be first made from the supplier and in some exceptional circumstances recovery of input tax credit from the recipient shall be made through a due process of service of notice and issue of order.

 

Key Features for PROPOSED Quarterly filing of Returns:

  1. Taxpayers having aggregate turnover up to Rs. 5 Cr. in the last financial year can file quarterly return. However they may opt for monthly filing of the return. There shall be an option available for filing monthly or quarterly return at the beginning of the year and generally thereafter they would continue to file the return during the year as per the option selected. However taxpayer can change from monthly to quarterly or vice-versa shall be allowed only once and at the beginning of any quarter.
  1. They are required to pay their taxes on monthly basis and avail the Input Tax Credit (ITC) on self declaration basis for payment of taxes.
  1. Taxpayers shall have an option to file any one of three forms:

Quarterly Return– Return will be similar to the monthly returns (with few exceptions.)

GSTR – Sahaj – B2C Outward Supplies.

GSTR – Sugam – B2B and B2C Outward Supplies.

  1. Following are the points which are to be considered filing the above returns:
GSTR – Sahaj GSTR – Sugam Quarterly Returns
 

  • Returns can be filed if supplies are made to consumers and Un- Registered Persons (B2C).
  • The ITC which has been availed during the first two months of the quarter will be adjusted from the claim, if balance becomes negative, then it will be added into the liability for the same quarter.
  • The tax paid during first two months of the quarter will be adjusted against the Total Liability of the quarter.

 

 

 

  • Returns can be filed if supplies are made to consumers and Un- Registered Persons (B2C) and Registered Persons (B2B).
  • Taxpayers will have to upload the details in the Annexures of supplies which are in the similar for monthly returns.
  • Details of the invoices can be uploaded anytime during the quarter. Supplies other than B2B and B2C will not be disclosed in Annexure of Sugam.
  • Summary of Invoices will auto populate in Form GSTR – Sugam for the payment of Taxes.
  • The ITC which has been availed during the first two months of the quarter will be adjusted from the claim, if balance becomes negative, then it will be added into the liability for the same quarter.

 

 

  • Taxpayershaving Imports or Exports having turnover up to 5 Cr shall opt for filing of quarterly returns.
  • Invoice Annexure would be similar to the main return.
  • Actions w.r.t those of pending and missing invoices are similar to the main return.

 

 

 

 

 

 

  1. Payment of liability declared in the return shall be discharged in full at the time of filing of the return by the supplier.

 

We would like to state that the above proposed system may take 4-6 months for implementing and replacing the existing system. In the meanwhile we recommend you to kindly go through the proposed system and incorporate the changes in your accounting /GST software.

 

CA Manish Gadhia

-CA Gadia Manish R

Manish Gadia is a chartered accountant in practice since 1997. He is partner in `M/s GMJ & Co, Chartered Accountants’.

 

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