GST Action Plan for Sep 2020

September 2020 is viewed as a huge month for any Financial Year as it incorporates significant compliances under the Goods and Services Act. Here, I give you the rundown of exercises which ought to be performed by an enrolled individual under GST.

Expansion of Due Date of different Returns and decrease in the Interest and Late fees due to COVID - 19 Pandemic

The Government of India has expanded various returns on account of the pandemic through reducing the interest amount and the late fees. The rundown of such extended returns are as per the following:

1. Form GSTR-3b:-

   Taxpayers who has Turnover more than Rs. 5Crore:-Late fees has been reduced to limit of Rs. 500 and Nil for Nil Returns, if the returns are filed till 30th September'2020

2. Form GSTR-3b:-

   Taxpayers having turnover less than Rs. 5 crores in previous FY in respect of States of Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh or the Union territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands and Lakshadweep

   Month	Original Due Date	No Late Fees/ Interest if filed by	Interest @9% for period till date 30th September, 2020 (post 30th Sep-18%)	Late fees
   February 2020	22th March, 2020	30th June,2020	w.e.f 1st July, 2020	Maximum Rs. 500 and NIL for NIL Returns if returns filed till 30th September, 2020
   March 2020	22th April, 2020	3rd July, 2020	w.e.f 4th July, 2020
   April 2020	22th May, 2020	6th July,2020	w.e.f 7th July, 2020
   May 2020	22th June, 2020	12th September, 2020	w.e.f 13th September, 2020
   June 2020	22th July, 2020	23rd September, 2020	w.e.f 24th September, 2020
   July 2020	22th August, 2020	27th September, 2020	w.e.f 28th September, 2020
   August 2020	22th September, 2020	1st October, 2020	No Relief

3. Form GSTR-3b:-

   Taxpayers having turnover less than Rs. 5Cr in previous FY in respect of States: Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha or the Union territories of Jammu and Kashmir, Ladakh, Chandigarh and Delhi

Reconciliation of Outward Supplies made during the FY 2019-20 according to Books of Account with the Returns filed and modifying/adjusting the equivalent

Under GST, the last date to include any missing outward sales is the due date of filing return for the time of September'2020. Thus, the registered person will undertake the reconciliation so as to discover any missing invoices which were forgotten about during the period.

Also, basis the reconciliation undertaken, if any invoices reported earlier are not correct, the same has to be adjusted/modified till the filing of GSTR-1/GSTR-3B for the month of September’2020. No amendment/addition of invoices are allowed after the due date of filing GST Returns for the month of September’2020.

GSTR 2A Reconciliation for FY 2019-20

Under GST Act, reconciliation implies recording each transaction that occurred during a period while also ensuring that the data filed by the provider matches with those of the receipients. This empowers one to ensure that no sales or purchase are missing or wrongly detailed in the GST returns. In this way, it is mandatory for each taxpayer to reconcile their Input Tax Credit (ITC) with Form GSTR-2A toward the end of every month/quarter of the Financial Year and avail the missed-out credit or reverse the excess ITC claimed earlier. Any left out ITC for the FY 2019-20 might be misfortune to the registered person if not claimed within the due date of filing GSTR-3B.

Throughout the pandemic, the Government vide a notice has given a condition that GSTR-2A compromise for the period February'2020 to September'2020 must be undertaken cumulatively and total ITC availed in the GSTR-3B from February 2020 to September 2020 can't surpass over 10% of eligible credit available in GSTR-2A.

Reversal of ITC on account of Non-Payment of Consideration within 180 Days (Rule 37)

This rule infers that when an enlisted person who has availed ITC couldn't pay the full value of inward supply alongside the tax amount to the supplier within the timespan of 180 days then the ITC claimed on such inward supplies should be reversed and if a part of invoice amount is paid, at that point ITC will be reversed on a proportionate basis.

The registered person shall do a creditor ageing as on 30th September, 2020 and guarantee that there are no creditors which has not been paid for the supplies made in the year. Any sum pending to be payable to creditors for over 180 days, the ITC on the equivalent will be reversed.

Apportionment of ITC attributable to Exempt Supplies under Rule 42 & Rule 43

Rule 42 and Rule 43 states the system of appointment of ITC in regard of inputs or input services or capital goods which attract the provisions of Section 17(2), being partly utilized for the purpose behind business and somewhat for different purposes, or partly used for taxable supplies including zero rated supplies and partly for affecting exempt supplies.

The apportionment has to be undertaken on monthly basis while filing GSTR-3B of the relevant month. However, the apportionment 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 (i.e by the due date of GSTR-3B of September,2020 for FY 2019-20)

GST Audit for the FY 2018-19

The due date of furnishing GSTR-9 & GSTR-9C is as follows:

GSTR 9

GSTR 9C

*Filing of GSTR-9C for FY 2018-19 has been made optional for MSMEs with an aggregate turnover of less than Rs. 5 crore.