A spotlight on return filing under GST regime

Anushri Gupta , Last updated: 18 January 2016
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DGGST and not DGST!!

Yes, the Government has renamed Directorate General of Service Tax (DGST) as Directorate General of Goods and Service Tax (DGGST) w.e.f. 01.08.2015….GST is making headlines, Draft reports on GST are being released every now and then, popular forum messages are showcasing GST, seminars and discussions are being held ….we can say GST has become the talk of the town!!

Yet we have no idea when will it be on the floors? Well after the GST bill(The Constitution 122nd Amendment) Bill, 2014 could not be passed in the monsoon session and winter session, the government now plans to take it up in the Budget session.

Well, we can just say, sooner or later- it will be there for sure. Next year we may be filing just GSTR (GST Return) instead of Service Tax, Excise, Vat and other indirect tax returns.

Here’s an insight into the return filing under GST regime.

The Joint Committee has submitted its report on ‘Business Process for GST on GST Return’.

8 forms GSTR-1 to GSTR-8 have been drafted. 3 ledgers namely Input Tax Credit Ledger, Cash ledger and Liability ledger shall also be maintained on the taxpayer’s dashboard.

GSTR-1 to GSTR-3 and GSTR-8 are the regular return forms to be filed by all regular/normal taxpayers.

Every return form is designed to capture some general as well as specific information. The forms have been carefully designed to enable the auto population of data from one form to other so as to minimize duplication in feeding the forms and also to enable cross checks.

The information that would be captured by each form is summarized in the following table:

Form	Information to be captured	Due date	Auto population
GSTR-1: For Outward Supplies made by the Taxpayer	Invoice level supply information to be provided for all B2B supplies, interstate B2C supplies with invoices above Rs. 2.5 lakhs(for invoices below Rs. 2.5 lakh only state wise summary to be provided) in GSTR-1 HSN codes for goods and Accounting codes for services (SAC) to be provided by taxpayers in prescribed manner according to their turnover. To distinguish SAC from HSN, prefix “s” would be added to SAC. Details relating to place of supply Details relating to supplies attracting reverse charge Details for advances received and tax paid on advances Details of supplies exported Separate tables for details of revision of invoices, debit/credit notes and correcting errors Details for NIL rated, exempted and Non-GST outward supplies	10th of next month	-
GSTR-2: Inward supplies received by a taxpayer	Final invoice level inward supply information Details of import of goods and services Details of ITC for inputs/Capital goods Separate tables for details of revision of invoices, debit/credit notes and correcting errors Details for NIL rated, exempted and Non-GST inward supplies Separate table for ISD credit received, TDS credit received	15th of next month	Inward supply details auto populated after 11th of succeeding month from GSTR-1 of counterparty suppliers Details from GSTR-2 to be auto populated in ITC ledger
GSTR-3: Monthly GST returns	Details of turnover Final aggregate level outward and inward supply information Separate tables for calculating tax amounts, capturing TDS received and Tax liability under CGST, SGST, IGST and Additional Tax. Details of revision of invoices Details of interest, fees, penalty and other liabilities Information about ITC, cash and liability ledgers maintained on real time basis Details of ITC utilized, net tax payable and paid, other payments and ITC balance Details of cash balance	20th of next month	Will be auto populated using own ITC , cash and liability ledgers,GSTR-2 & counterparty GSTR-1,6,7
GSTR-4: Quarterly return for compounding taxpayers	Pay taxes at fixed rate without any Input tax credit facilities Indicate total supply value, tax paid, invoice level purchase information Details of import and export also to be given	18th of the month next to quarter	Invoice level purchase information shall be auto drafted from supply data of counter party taxpayers (GSTR-1)
GSTR-5: Return for non-resident tax payers	Return to be submitted for the period of registration If registration for more than 1 month, monthly return also to be filed	Within 7 days after the date of expiry of registration
GSTR-6: ISD return	Final invoice level inward supply information separately for goods and services Details of invoices and GSTIN of receiver of credit	15th of the next month	Invoice level information on the basis of GSTR-1 of counterparty suppliers
GSTR-7: TDS return	Details of supplier and invoices against which TDS has been deducted Details of TDS against CGST, SGST and IGST Details of interest, penalty, fees and other payments	10th of the next month	Details of Interest, penalty, fees and other payments auto populated from debit entry in Cash ledger
GSTR-8: Annual Return	Captures minutest details of income and expenditure of taxpayer and regroups them in accordance with monthly returns Gross profit/loss arrived on basis of this statement shall tally with gross profit/loss indicated in the P& L A/c of the dealer. Copies of audited annual accounts of dealers to be submitted along with Information regarding quantity of goods also to be submitted here Total supply value to be reconciled with taxable value based on Valuation rules	31st December following the end of relevant financial year	Consolidated statement of purchases and supplies based on monthly returns would be provided as a facilitation measure.

The auto population is depicted as follows:

Some Salient features:

Goods and Service tax registration number (GSTIN) for each taxpayer and Unique ID for UN organizations and embassies to be allotted. Some states like Punjab have already started validating PAN of taxpayers to enable quick and easy allotment of GSTIN
Taxpayers having multiple registrations for different business verticals within a state have to file GSTR-1, 2, 3 for each registration separately.
Taxpayers eligible for compounding scheme may opt against it to make their supplies eligible for ITC in hands of purchasers.
Concept of TDS, TDS returns and TDS credit introduced
Concept of Input service Distributor under the existing Service Tax law retained in GST regime
If return filed without payment of self-assessment tax, it would be treated invalid and would not be considered for matching of invoices and inter-governmental fund settlement.
ITC ledger, Cash ledger and Liability ledger maintained on taxpayer’s dashboard will be auto populated from previous tax period return data.
Return to be filed online or offline (then uploaded later) at GST common portal (GSTN). GSTN will facilitate periodic (may be daily, weekly etc.) upload of information to minimize last minute load on system.
Returns may also be filed through Apps using Application Programming Interface (APIs)
There would be no revision of returns. All adjustments/modifications in the monthly returns pursuant to post-sales discount, sale-purchase return, under reported invoice, ITC revision etc. can be made in the succeeding months by way of debit/credit notes, separate tables for revision of invoices and correcting errors.
A separate reconciliation statement duly certified by a Chartered Accountant shall be filed by taxpayers who are required to get their accounts audited under Section 44AB of Income Tax Act, 1961.

To conclude, we can say that although one return is to be filed for all the indirect taxes under GST regime, return filing and supplying invoice level information on a monthly basis would be a tedious exercise for the taxpayers, especially the small ones.

Introduction of GST is a major tax reform, a new roadmap to indirect taxation! Let’s hope it makes return filing simpler where the taxpayers can just ‘File, smile and Go’.

-Presented by CA Anushri Gupta
anushrigupta.16@gmail.com