Things to do in Year-end Closing and New Financial Year under GST

A. Registration

• If the Registered person / eligible taxpayer wishes to opt for Composition Scheme under GST, then it can be done online in common portal by filing Form CMP-02 before 31st March of the financial year.
• Review that all the new place of business (if any) or closed business place (if any) have been incorporated in the GST Registration Certificate or not. If not, amend the GST registration certificate on an immediate basis.

B. Invoice Related

1. A New unique series / serial number of invoices to be issued for the new financial year, so that there will be no duplication or repetition of invoices of the preceding financial year. It is being advised to maintain different unique series / serial number of the invoices issued if the registration has been taken in different states.
2. All the necessary information as per the GST laws must be present in the invoices like GSTIN of the Recipient and Supplier, Address of the Recipient and Supplier, Place of Supply, GST Amount Bifurcation, Invoice number not exceeding 16 digits etc.
3. Invoices to be issued by the registered person should contain 4 digit HSN Code if aggregate turnover in the preceding financial year is upto Rs. 5 Crores or should contain 6 digit HSN Code if aggregate turnover is more than Rs. 5 Crores in the preceding financial year.
4. Currently, E-invoicing is applicable to those registered persons whose aggregate turnover in the preceding financial year is more than Rs. 5 crores.
5. Further, 6 digit HSN code is mandatory for issuing E-invoices.
6. Documentation required for supplies received from unregistered persons(RCM):

• Self-invoice to be made; if not done, then ITC claimed on the RCM may be questioned in the assessments / audit by the department.
• Payment voucher to be made for all the payments made to the RCM vendors whether registered or not.

C. GST Returns and Books of Accounts

1. It is being advised to reconcile Sales Turnover, Credit Notes, Output tax as per Books of Accounts with GST Returns filed (GSTR-1 & GSTR-3B) for the last year.
2. Reconcile any difference between GSTR-1 & GSTR-3B filed for the year and reason of such differences should be known to the taxable person so that they can present their case at the time of audit / assessment.
3. It is being advised to reconcile Input tax credit (ITC) as per Books of Accounts with ITC claimed in GSTR-3B subject to matching of ITC with GSTR-2B downloaded from the GST portal.
4. Reconcile GSTR-2B with ITC claimed in GSTR-3B as well as ITC in Books of Accounts within 30th November of following year so that any missed ITC / excess claim of ITC be considered in the GSTR-3B till 30th November of the following year.
5. If any ITC is not claimed in GST returns while reconciling GSTR-2B, the registered person is eligible to avail such ITC within 30th November of the following year or the due date of filing of Annual Return, whichever is earlier.
6. It is being advised to get confirmation from the suppliers in the following cases:

• In case they have filed GSTR-1 but not filed GSTR-3B; that when the supplier will file their GSTR-3B, the ITC already claimed by the registered person would not get disallowed. And advised to save the e-mail of all the correspondence with the supplier in this regard.
• In case they have filed GSTR-3B but not filed GSTR-1. It is being advised to direct the supplier to file their GSTR-1, else the ITC would not be available to the registered person since it will not show in their GSTR-2B.
• In case they have not filed both GSTR-1 and GSTR-3B; then direct the supplier to file both the returns immediately and to follow-up on regular basis. Further, all the correspondences / e-mails sent to the supplier to be saved by the registered person which will help them in their assessments / audit.
• Review ineligible and blocked ITC in the books of accounts and check whether any ineligible / blocked ITC have been inadvertently claimed in the GST returns. If yes, reverse the same.

7. Review any liability under reverse charge as per books of accounts that whether such reverse charge liability have been shown in the GSTR-3B or not and whether their payment have been made or not. If any RCM liability is pending, then pay the same along with the appropriate interest.
8. After payment of the reverse charge liability, review whether it has been claimed in the GSTR-3B or not.
9. Any output tax liability missed or any credit notes missed in the GSTR-1 & GSTR-3B for the last financial year will be shown within 30th November of the following year or the due date of filing Annual Return, whichever is earlier.
10. It is being advised to review the payment to the vendor within 180 days from the date of invoice, if not, then ITC needs to be reversed. Once, the payment is made to the vendor, then ITC can be reclaimed without any time limit.
11. Ensure whether GST has been paid on the other income (leviable to GST) and on sale of assets (if any). If not, pay the GST along with the interest.

D. Other Important Points

• Every registered exporter who wishes to export goods or services without payment of IGST shall apply for renewal of LUT (Letter of Undertaking) at the end of financial year, for the next F.Y. 2023-24 in order to continue their export of goods or services.
• Ensure to file the GST refund application (if any) within 2 years as specified in GST laws.
• File ITC-04 on Half-yearly basis for the registered persons whose aggregate turnover is more than Rs. 5 crores and on yearly basis for those whose aggregate turnover is upto Rs. 5 crores.
• The facility to Opt-in or Opt-out of the QRMP Scheme for the first quarter of 2024-25 will be within 30th April, 2024.
• Check whether the accounts as well as documents / records have been kept as required under the GST laws.

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