In depth analysis of GST return

CA Akshay Hiregange , Last updated: 08 April 2020
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SUMMARY OF NORMAL RETURN:

This document contains discussion on various details to be filled in the new ‘NORMAL' return. Readers could refer to the formats with instructions provided on the GST portal.In the mail also, it is being shared.

Coverage:

Introduction
Profile Updation
Form GST ANX-1& Amendment ANX-01A
Form GST ANX-2
Form RET-1 & Amendment RET-1A

Introduction Normal monthly return:

The registered person whose aggregate turnover during preceding financial year exceeded Rs. 5 crores, have to file normal return (i.e. RET-1) on monthly basis mandatorily.The registered person has to file 3 returns such as Form GST ANX-1, Form GST ANX-2 and Form GST RET-1 every month. In case of lesser turnover also, there is an option to file normal returns instead of SAHAJ / SUGAM return.

Here we would discuss each type of return form to be filed in details.

Profile Updation:

At beginning of every financial year, a profile updation form needs to be filled online by the registered person to intimate the department about type of GST return he wishes to file.

There are 3 types of returns such as Normal (monthly/quarterly), Sahaj and Sugam which could be selected for filing based on registered person's aggregate turnover during the preceding financial year.

The registered person could switch from one type of return to another in the following scenario.

From	To	Comments
Quarterly/Monthly (Normal)	Monthly/Quarterly (Normal)	• Once at time of filing first return. • It cannot be changed during the FY. • Have the option to change while filing first return in next FY.
Quarterly (Normal)	Sahaj/Sugam	Once in a FY at beginning of any quarter.
Sugam	Sahaj	Once in a FY at beginning of any quarter.
Sahaj	Sugam/Quarterly (Normal)	More than once in a FY at beginning of any quarter.
Sugam	Quarterly (Normal)	More than once in a FY at beginning of any quarter.

Form GST ANX-1: Annexure of outward supplies, imports and inward supplies attracting reverse charge:

Form GST ANX-1 would be for uploading the details of outward supplies, import of goods, import of services and inward supplies on which GST to be discharged under reverse charge.

Form GST ANX-1 would pop up with a questionnaire which is divided into 2 parts.

In Part A, registered person has to declare that all the details uploaded are deemed to be tax payable for such period and an option whether any changes in Part B questionnaire filed for last tax period.

In Part B, registered person has to select which type of transaction details to be uploaded by him.

Coverage and analysis of the contents of the form GST ANX-1:

To obtain clarity in relation to the contents below, it is suggested to view the ANX-01 format simultaneously (attached in email - page 5).

Contents	Coverage and analysis
GSTIN/UIN	• B2B, SEZ supplies, deemed export, import of goods from SEZ and missing documents (ITC claimed) transactions. • Inward supplies from registered parties attracting RCM. In case of supplies from URP where taxes to be paid under RCM, PAN number to be obtained.
Place of Supply (Name of State/UT)	All type of transactions except for export of goods and services.
Documents details 1. Type 2. No 3. Date 4. Value	• Type of documents such as invoice, debit note, credit note, bill of supply, bill of entry etc. • Document details to be uploaded for all transactions except for B2C, inward supplies attracting RCM and import of services. • Value here refers to total invoice value.
HSN code	• HSN code needs to be uploaded document wise for all transactions except for B2C cases(including RCM &imports). • Tax payers with annual turnover of more than 5 crore have to upload at least 6-digit HSN code. • Tax payers with annual turnover upto 5 crore shall have an optional facility to report HSN code or leave it blank.
Tax rate (%)	Tax rate for IGST to be selected from drop down and for CGST & SGST, same shall be applied at half rate.
Taxable value	Taxable value of supply to be uploaded here.
Tax amount (IGST/CGST/SGST/Cess)	• Tax amount would be computed automatically based on taxable value and tax rate mentioned. • Same cannot be altered and could adjust only by way of DN/CN • For Cess wherever applicable, to be keyed in manually.
Shipping bill/ Bill of export details (No and date)	For export of goods and import of goods from SEZ, shipping bill / Bill of export details available upto date of filing of the return to be disclosed and separate functionality would be given for remaining shipping bills not received before filing date.

Analysis of tables of Form GST ANX-1:

Here, we would analyse the tables given for different type of transactions and comparison with the present GST returns.

Sr.No	Table No	Disclosure in NEW returns	In present GST returns
1.	3A. Supplies made to consumers and un-registered persons (Net of debit / credit notes) POS, TAX%, TV	Supplies to unregistered persons (B2C) to be reported net of DN/CN.	Supplies to B2C net of DN/CN are being disclosed in Table 7 of GSTR 1, place of supply and tax rate wise.
2.	3B. Supplies made to registered persons (other than those attracting reverse charge)(including edit/amendment) GSTIN, POS, DOC details, HSN, TAX%, TV	• Supplies to registered persons (B2B) to be reported in this table. • Supply of services by SEZ to DTA have to report in this table. • Supply of goods by SEZ to DTA to be disclosed in Table 3K by DTA. • Supplies to SEZ would be disclosed in Table 3E/3F. • Deemed exports where supplier is going for refund disclose in Table 3G.	Supplies to registered persons (B2B) and supply of services by SEZ to DTA are being disclosed in Table 4A GSTR 1.
3.	3C. Exports with payment of tax DOC details, HSN, TAX%, TV, SB	• Export of goods or services with payment of IGST to be reported in this table. • Shipping bills detailsto be disclosed.	Export of goods or services are being disclosed in Table 6A of GSTR 1.
4.	3D. Exports without payment of tax DOC details, HSN, TAX%, TV, SB	• Export of goods or services without payment of IGST under LUT or bond to be reported in this table. • Shipping bills detailsto be disclosed.	Same as above
5.	3E. Supplies to SEZ units/developers with payment of tax (including edit/amendment) GSTIN, POS, DOC details, HSN, TAX%, TV	Supply goods or services to SEZ with payment of IGST to be reported in this table.	Supply goods or services to SEZ are being disclosed in Table 6B of GSTR 1 with option to select with payment of taxes.
6.	3F. Supplies to SEZ units/developers without payment of tax (including edit/amendment) GSTIN, POS, DOC details, HSN, TAX%, TV	Supply goods or services to SEZ without payment of IGST under LUT or bond to be reported in this table.	Supply goods or services to SEZ are being disclosed in Table 6B of GSTR 1 with option to select without payment of taxes.
7.	3G. Deemed exports (including edit/amendment) GSTIN, POS, DOC details, HSN, TAX%, TV	• All supplies treated as deemed export to be uploaded in this table. • Where supplier is going for refund,disclose it here. If not, to be shown under Table 3B (B2B).	Deemed export are being disclosed in Table 6A of GSTR 1.
8.	3H. Inward supplies attracting reverse charge (to be reported by the recipient, GSTIN wise for every supplier, net of debit/credit notes and advances paid, if any) GSTIN/PAN, POS, HSN, TAX%, TV	• All supplies attracting reverse charge to be reported net of DN/CN/advances,GSTIN and rate wise. • If the supplies attracting reverse charge from unregistered person, then to be reported PAN-wise and tax rate wise.	Details of supplies attracting reverse charge are not being disclosed anywhere in GSTR 1 same are being disclosed in Table 3(1)(d) of GSTR 3B as consolidated value. It is not rate wise or GSTIN wise.
9.	3I. Import of services (net of debit/ credit notes and advances paid, if any) POS, HSN, TAX%, TV	• Import of services to be reported in this table rate wise and to be net of DN/CN/advance if any. • Services received from SEZ not to be reported in this table.	Details of supplies attracting reverse charge are not being disclosed anywhere in GSTR 1 same are being disclosed in Table 3(1)(d) of GSTR 3B as consolidated value. It is not rate wise.
10.	3J. Import of goods POS, DOC details, HSN, TAX%, TV	• Details of IGST paid on import of goods to be reported in this table. • These transactions would have suffered IGST and would not be considered for liability again.	Details of import of goods are not being disclosed in GSTR 1 and GSTR 3B for liability.
11.	3K. Import of goods from SEZ units / developers on a Bill of Entry POS, DOC details, HSN, TAX%, TV	• Goods received from SEZ on bill of entry to be reported in this table. • These transactions would have suffered IGST and would not be considered for liability again.	Details of import of goods are not being disclosed in GSTR 1 and GSTR 3B for liability.
12.	3L. Missing documents on which credit has been claimed in T-2 /T-1 tax periods (1 tax period for quarter) GSTIN, POS, DOC details, HSN, TAX%, TV	Where the tax payer availed ITC but documents not yet uploaded by the current tax period by the supplier after lapse of two tax periods (or 1 tax period for a quarter) to be reported in this table.	Earlier Information of defaulters and fraudulent practitioners were not traceable. Now possible.
13	DN/CN	• DN/SN issued by supplier other than reverse charge shall be reported in respective tables from Tables 3A-3G. • Where DN/CN issued for differences in tax rate, taxable value shall be zero and only tax amount would be reflected.	DN/CN issued by supplier for registered persons (B2B) are being disclosed in Table 9B of GSTR 1.
14	4. Supplies made through ECO liable under TCS	• Table 3B (B2B) - tax invoice for supplies made through ECO • TCS details to be deducted by ECO to be updated by the supplier in Table 4. • Supplies made through ECO, but not liable under TCS - need not disclose in Table 4.

Other important points:

1. Registered person could upload the document details on real time basis during the month or of prior period on or before due date for filing return for September from end of FY or actual date of filing annual return, whichever is earlier.

Exceptions : Details would not be allowed for uploading from 18th to 20th in case of monthly returns and 23rd to 25th in case of quarterly return.

2. Any documents details uploaded after filing return for month would be added to liability of such subsequent month in which details are uploaded.

3. Advances& advance adjustments would not be reported in GST ANX-1, instead RET-01.

4. Recipient would get credit based on documents uploaded by supplier up to 10th of following month to which such documents pertain to.

5. Details of documents prior to introduction of new return scheme disclosed in the new return would be subject to payment.

6. Only supplier can make edits/amendments.

7. Editing of documents up to 10th of following month - The supplier could edit or amend details if recipient has not accepted. If recipient accepted, then he has to reset / unlock such documents. All the amendments could be done only by supplier.

8. Edit/Amendment after 10th of the following month - Details uploaded up to 10th of following month would be auto-populated to recipient and he has to accept/reject or pending such documents.

• Rejected documents would be conveyed to supplier only on filing of return by recipient.

• Edited documents would auto-populate for recipient once more.

9. Shifting of documents - Where particulars of documents are correct but disclosed in wrong table. The recipient would reject the same. Instead of amending it, a facility to shifting such documents to appropriate table would be provided.

10. In relation to amendments to documents issued to person not filing GST returns, supplier could amend any time.

Amendment in Form GST ANX-01A:

1. Table 3B, 3E, 3F and 3G - B2B, Supplies to SEZ and Deemed exports - amendments to be done through GST ANX-01 only.

2. Other Tables being 3A, 3C, 3D, 3H, 3I, 3J, 3K amendment to be made through Form GST ANX-01A.

3. Table 3L cannot form part of amendment table. Edit and amendments also may not be allowed in Form ANX-01.

4. For changes in Supplies made through ECO liable under TCS (Table 4) - Original and revised GSTIN to be provided.

5. Invoices/documents on which refund has already been claimed, would not be open for amendment.

6. Although not notified, in the press releases it was provided that Amendments would be allowed for a maximum of 2 times only.

Form GST ANX-2: Details of auto-drafted inward supplies:

To obtain clarity in relation to the contents below, it is suggested to view the ANX-02 format simultaneously (attached in email - page 12)

1. In Table 3A of form GST ANX-2, the details of outward supplies uploaded by the supplier would be auto populated to the recipient with the option to either accept, reject or keep pending.

2. In Table 3B and 3C of form GST ANX-2, ITC details of import of goods from SEZ and overseas would be taken from Table 3J and 3K of form GST ANX-1 for initial period and then same is expected to be auto populated from ICEGATE in future.

3. Recipient could accept (only) upto 10th of the following month. After 10th of following month, recipient may accept, reject or keep pending of documents auto populated in his annexure.

4. If no action taken on documents, it is deemed accepted upon filing the return and ITC would appear in table 4A of GST RET-01. Therefore, to reduce burden on administrative team, suggested to perform reject and keep pending function only, rest would be deemed accepted.

5. Once the tax payer completes the process of accept, reject or keep pending, a summary of ITC would be generated.

6. Accepted documents means supplies received and details given in documents reported in form GST ANX-1 of supplier are correct and same would not be available for amendments for supplier.

7. Any errors in the documents such as wrong HSN, tax rate, wrong GSTIN which cannot be corrected through financial DN/CN, are to be rejected.

8. Rejected documents would be shown to supplier and he could make corrections in subsequent GST ANX-1.

9. Pending documents would be where recipient deferred the decision of accepting or rejecting the invoices. Ex: Not received goods and would not be available to supplier for amendments.

10. Supplier return filing status would be made known to recipient after the due date for filing the return.

11. Where document accepted and ITC availed and in future such documents need to be rejected, a separate functionality would be given for reversal along with interest.

12. There could be situation where the supplier has not filed the GST RET-01 for two consecutive tax periods but continues to upload the documents in form GST ANX-1. In such scenarios, the documents are auto populated to recipient only with option of either reject or keeping pending. Accept function would be allowed after the supplier files the return in form GST RET-1 (along with payment).

Form GST RET-1: Monthly / Quarterly (Normal) Returns:

Form GST RET -1 would be auto populated from the data uploaded in form GST ANX-1 and form GST ANX-2 by the registered person. There would be few tables where the registered person has to key in the details.

The details which the registered person needs to key in are discussed below:

Sr.No	User Input	Analysis of NEW returns	In present GST returns
1.	Liability relating to the period prior to the introduction of current return filing system and any other liability to be paid.	• The liability pertaining to tax periods prior to new return format which were uploaded in GSTR 1 but payment not made in GSTR3B yet. Such liability to be added manually by tax payer in this table. • Where the tax payer had not disclosed the liability in GSTR 1 and GSTR 3B, such transactions to be uploaded in form GST ANX-1 and not to be reported in this table.	Was to be merged with current month data based on Circular 26/2017.
2.	Advances received (net of refund vouchers and including adjustments on account of wrong reporting of advances earlier).	Where GST to be discharged on advances received for services to be reported in this table after giving effect to refund vouchers if any.	Advance amount received are disclosed in Table 11A of GSTR 1 and payment would be done in GSTR 3B.
3.	Advances adjusted	Advance amount received in earlier tax period and adjusted against the supplies being shown in this table. Excess adjustments if any, shall be accounted in next tax period.	Advance amount adjustments are disclosed in Table 11B of GSTR 1.
4.	Details of supplies having no liability	The following details to be reported • Exempt and NIL rated supplies • Non-GST supplies • Outward supplies attracting reverse charge net off DN/CN • Supply of goods by SEZ to DTA	• Details of NIL rated, exempted and non-GST supplies were disclosed in Table 8 of GSTR 1. • Details of outward supplies attracting reverse charge were disclosed in Table 4B of GSTR 1.
5.	Eligible credit (after 1st July, 2017) not availed prior to introduction of this return but admissible by law.	Any eligible credits not availed in GSTR 3Bcould be reported in this table as this would not auto populate in GST ANX-2. ITC in relation FY 2018-19 (subject to time limit), and FY 2019-20 to be disclosed.	FY 2017-18 credit upto March 2019 GST returns.
6.	Provisional ITC on documents not uploaded by suppliers (net of ineligible credit).	The tax payer could avail the eligible ITC on documents which are not uploaded by supplier upto a maximum of 20% of ITC furnished by vendors. Based on section 43A of CGST Act (Amendment yet to be notified) Once the supplier upload document in subsequent tax periods, then tax payer has to accept and reverse the same manually.	NA
7.	Upward adjustment in ITC due to receipt of credit notes and all other adjustments and reclaims.	There would be a situation where CN issued against an invoice on which recipient availed NIL or partial credit. Acceptance of CN would lead to reversal of credit. It may lead to double reversal of credit. To avoid double reversal of credit this table has been provided.	NA
8.	Supplier not eligible for credit (including ISD credit)Supplier Out of net credit available in Table 4A)	The tax payer has to accept all eligible and ineligible credit in GST ANX-1 and same would be auto populated in GST RET-1. Out of total credit in Table 4A, ineligible credit needs to be reversed in this table.
9.	Reversal of credit in respect of supplies on which provisional credits has already been claimed in previous tax periods but documents have been uploaded by supplier in current tax period	Where the recipient availed ITC based on self-assessment but document not uploaded by supplier in such tax period but when supplier upload such document in subsequent tax period, recipient has to report in this table for reversal. Otherwise it would amount to double availment of ITC.
10.	Reversal of ITC as per law (Rule 37, 39, 42 & 43)	The following reversals to be reported in this table. • Rule 37 - Reversal of ITC in case of non-payment of consideration within 180 days to supplier. • Rule 39 - ISD reversal • Rule 42 - Manner of distribution and reversal of ITC on inputs and input services. • Rule 43 - Manner of distribution and reversal of ITC on capital goods.	Rule 37 and 39 reversal are being disclosed in Table 4(B)(2) of GSTR 3B Rule 42 and 43 reversal are being disclosed in Table 4(B)(1) of GSTR 3B
11.	ITC on capital goods	Out of ITC available in Table 4C, ITC claimed on capital goods to be reported in this table.
12.	ITC on services	Out of ITC available in Table 4C, ITC claimed on services to be reported in this table.

Other important points:

1. Facility to file NIL return through SMS would be made available if no supplies made or received.

2. Interest and late fee to extent of late filing of return, making late payment of taxes, uploading preceding period invoices computed by system. But interest due to reversal etc… shall be entered by tax payer on self-assessment basis.

3. Suggested utilization of ITC will be made available in system. Tax payer can change as long as per provisions of Act.

4. Value of inward supplies under RCM and import of services will not add to turnover. Only added to liability.

Amendment in Form GST RET-01A:

1. Amendment can be filed for a month/quarter only. (multiple months/quarters cannot be merged into one period)

2. Where an amendment results in additional tax liability - payment to be made.

3. Where an amendment results in negative tax liability - refund shall not be provided, although, it would be carried forward to GST RET-01 of the next month for adjustment of liability.

4. Revised values to be provided in amendment return, and not additional values. (i.e. Original value 100, additional value 20, revised value 120).

5. Amendment to ITC to be shown in the main GST RET-01 and not here.

6. Although not notified, in the first press release of July 2018, it was provided that Amendments would be allowed for a maximum of 2 times only. Clarity needed on this.

The authors can also be reached at mahadev@hiregange.com, akshay@hiregange.com and abhilash@hiregange.com