Detailed analysis of new GST returns

GST NEW RETURNS

Introduction

Under the new GST return, there will be 1 main form viz. GST RET-1 (Normal), / GST RET-2 (Sahaj)/ GST RET-3 (Sugam) (i.e. the taxpayer will have to file any of the above forms) and two Annexures namely GST Anx-1 & GST Anx-2.

Date of Applicability: 01/04/2020

GST RET-1 v/s GST RET-2 v/s GST RET-3

*GST Anx- 1 & GST Anx-2 are to be filed along with above main returns.

Notes:

1. Periodicity of filing of returns i.e. quarterly or monthly cannot be changed once opted, for that financial year.

2. Change in Returns from one to another:

a) From,

• Sugam- Sahaj
• Normal (Quarterly) - Sugam
• Normal (Quarterly) – Sahaj

Can switch only once at the beginning of any quarter

            b) From,

• Sahaj- Sugam
• Sahaj- Normal (Quarterly)
• Sugam- Normal (Quarterly)

Can switch more than once at the beginning of any quarter

3. The taxpayer filing his return on monthly basis will not be able to upload the details of documents from 18th to 20th of the month following the tax period. The taxpayer filing his return on quarterly basis will not be able to upload the details of documents from 23rd to 25th of the month following the quarter.

4. Recipient will get credit during a tax period on the basis of the details of documents uploaded by the supplier up to the 10th of the month following the month for which the return is being filed for.

5. Liability on account of receipt of advances (in case of services) is to be reported directly in GST Return & not in Annexures.

Supplies attracting RCM is to be reported only by the recipient in Anx-1.

6. HSN Code is to be reported at least at 6 digits. (For turnover up to Rs. 5 crores, reporting of HSN Code is optional).

7. Matching Concept (Table 3L of GST Anx-1)

We will have to provide document wise details of the supplies for which credit has been claimed but the details of supplies are yet to be uploaded by the supplier(s) for two tax periods in case of monthly return filers and for one tax period in case of quarterly return filers.

8. Edit of Documents Uploaded by the Supplier

The details of documents uploaded will be made available to the recipient on a real-time basis. The uploaded documents can be amended up to 10th of the month following the month in which such documents have been uploaded & that too only those documents can be edited which have not been accepted by the recipient.

If it has already been accepted, it can edited only after it is reset/ unlocked by the recipient.

9. GST Anx-1A

This form is an amendment to GST Anx-1.

If invoices pertaining to month of April are uploaded by the supplier in the month of June, then, the amendment of such documents shall be made by amending the     return of April. The amendment form can be filed “n” number of times.

Amendment to FORM GST ANX-1 can be filed before the due date for furnishing of return for the month of September following the end of the financial year or the actual date of furnishing relevant annual return, whichever is earlier.

Payment can be made if liability arises due to filing of amendment return.

If liability becomes negative then no refund shall be paid. However, the negative liability will be carried forward to the main return (FORM GST RET – 1) of next tax period where adjustment can be made.

10. Documents of Prior Period i.e. of earlier periods:

Document has not been reported in FORM GSTR-1 and tax has also not been accounted for in FORM GSTR-3B

-In this case, document shall be uploaded in GST Anx-1 and tax shall also be paid along with applicable interest

Document has not been reported in FORM GSTR-1 but tax has been accounted for in FORM GSTR-3B

-In this case, document shall be uploaded in GST Anx-1 and adjustment of tax accounted for shall be made in table 3C (5) of FORM GST RET-1

Document has been reported in FORM GSTR-1 but tax has not been accounted for in FORM GSTR-3B

-In this case, uploading of the document shall not be required but adjustment of tax shall be made in table 3A(8) or 3C(5) of FORM GST RET-1, as the case may be.