Points & Precaution before you file your GST Returns for the Month of September-2021: CA Sharad Thawali

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Points & Precaution before you file your GST Returns for the Month of September-2021: CA Sharad Thawali

In the GST system, there is no option to revise the GST return. The only option with the taxpayers is to rectify their errors & mistakes in the GST returns till September. It is the final deadline now for error correction of FY 2020-21.
After the return for September 2021 is filed, no amendment, changes or rectifications can be done afterwards and so taxpayers need to cautious and must reconcile their books and returns & make the final adjustments in this month to avoid all the possible consequences.
There are lot of precaution which taxpayers must take before they file their GST returns, more particularly for the month of September.
Here is a compilation of the some of the key precautions and points which taxpayer and tax professionals must take before filing their GST returns of September Month..
Last chance to availment of Input Tax Credit for F.Y 2020-21:
1. It may be noted that as per Section 16(4), a registered person shall not be entitled to take ITC in respect of any invoice or debit note for the supply of goods or services or both after the due date of furnishing of the return under section 39 for the month of September after the end of the financial year to which such invoice or debit note pertains or furnishing of the relevant annual return, whichever is earlier.
2. As a result, if any ITC in relation to any invoice/debit note pertaining to F.Y 2020-21 has not been claimed by the taxpayer then the same should be claimed in the month of September 2021.
Take care of Rule 42 & 43 for apportionment of ITC:
1. If the taxpayer is engaged in exempt supply as well as taxable supply then ITC is required to be reversed in a proportion of exempt supply to total turnover as per Rule 42 & 43 while filing GSTR-3B.
2. Such reversal of ITC shall be calculated finally for the financial year before the due date for furnishing of the return for the month of September following the end of the financial year to which such credit relates.
3. If reversal made in GSTR-3B results in short or excess amount, then it has to be either reversed or claimed as the case may be.
Reversal of ITC due Non Payment of Consideration within 180 days as per Rule 37.
1. One of the provision there is a high level non-compliance is with regard to Rule 37 which requires that a registered person, who has availed of an input tax credit on inward supply, but fails to pay to the supplier thereof then the amount of value not paid and the amount of ITC availed to such amount within 180 days from the date of the issue of the invoice is required to be reversed.
2. In short, all taxpayers should check if the payment in respect of all the purchases made up to 31st March 2021 has been made to the supplier. If not, then the ITC is required to be reversed/
Check & Reconcile Outward Supply as per books of Accounts/ Outward Register with the GSTR-3B filed for the FY 2020-21
1. September of the month is the time wherein every taxpayer must reconcile the outward supply as per books of accounts with the GSTR-3B filed.
2. Any correction, modification or amendment for the FY 2020-21 can be done only till September 2021.
3. In short, if any sales have been wrong reported, short reported or excess reported then the same need to be rectified in the return for the month of September 2021.
Correction in GSTR-1:
GST don’t have a system of revision or rectification after the GSTR is filed.  If any amendment is to be done in relation to outward supply, then ONLY option could be to do it September – 2021.
Issuance of Credit Notes
1. GST compliance has to be done in a time bound manner.
2. As per Section 34(2) of the CGST Act, all Credit notes pertaining to F.Y.2020-21 cannot be issued after filing the return for the month of September 2021.
3. In short, any credit note for FY 2020-21 if left unissued may be issued in this month of September – 2021.
Reconcile the ITC appearing in GSTR-2A/ 2B with the purchase & Inward Register.
1. There are some errors which is possible on either side.
2. Either purchases may  not booked by the purchaser or the purchase is booked but the seller have not incorporated the same in their GST returns.
3. All the ITC as appearing in GSTR-2A/ 2B but not booked in Inward / purchase register should be recognised & reconciled accordingly.
4. Similarly, all ITC which has been recorded in the books of accounts but not reflected in GSTR-2A/2B should be checked and must pursue the same with the supplier so that it gets reflected in GSTR-2A/ 2B.
Every taxpayer must ensure strict compliance with the limits specified under 36(4) for claiming ITC.

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