Important changes related to QRMP Scheme implemented on the GST Portal for the taxpayers
The changes announced are really a welcome move as it reduces the burden of QRMP Taxpayers for consolidating the data and the filing the returns.
Few important changes related to QRMP Scheme implemented on the GST Portal for the taxpayers are as given below:
A.Auto population of GSTR-3B liability from IFF and Form GSTR 1 : A taxpayer under QRMP Scheme can declare their liability through optional IFF for Month 1 and Month 2 of a quarter & Form GSTR-1 for Month 3 of that quarter. Declaration of liability in these forms would now be auto-populated in their Form GSTR-3B (Quarterly) for that quarter, based on their filed Form GSTR-1 and IFF. These fields are editable and in case their values are revised upwards or downwards, the edited field(s) would be highlighted in red colour and a warning message will be displayed to the taxpayer. However, the system would not prevent taxpayer from filing of Form GSTR-3B with edited values.
B.Nil filing of Form GSTR-1 (Quarterly) through SMS : Nil filing of Form GSTR-1 (Qtrly) through SMS has been enabled for taxpayers under QRMP Scheme. They can now file it by sending a message in specified format to 14409. The format of the message is < NIL > space < Return Type (R1) > space< GSTIN > space < Return Period (mmyyyy) > . Example: NIL R1 07XXXXX1234H8Z6 062020 (where return period must be last month of the quarter)
However, NIL filing through SMS can’t be done in following scenarios: •If IFF for Month 1 or 2 of a quarter is in Submitted stage, but not Filed. •If invoices are Saved in IFF for Month 1 or 2 of a quarter, which was not submitted or filed by due date.
C.Impact of cancellation of registration on liability to file Form GSTR-1 : In case registration of a taxpayer under QRMP Scheme is cancelled, with effective date of cancellation being any date after 1st day of Month 1 of a quarter, they would be required to file Form GSTR-1 for the complete quarter, as the last applicable return. For example if the taxpayer’s registration is cancelled w.e.f. 1st of April, he/she is not required to file Form GSTR-1 for Apr-June quarter and Form GSTR-1 for Jan-Mar Quarter shall become the last applicable return. However, if the registration is cancelled on a later date during the quarter, the taxpayer would be required to file Form GSTR-1 for Apr-June quarter. In such cases the filing will become open on 1st of month following the month with cancellation date i.e. if cancellation has taken place on 20th May, Form GSTR-1 for Quarter Apr-June can be filed anytime on or after 1st of June.
We would like to advise a word of caution, please cross check the numbers auto populated as it help to identify any issues in auto population.
Taxpayers having turnover above Rs 500 crores are required to issues e-invoices from 1st Oct 2020.
As part of Digitization, e-invoices issued by the taxpayers will be auto-populated to GSTR – 1. This was supposed to happen from 13th Nov 2020. Due to some unforeseen technical issues, the same is not happening as planned.
Taxpayers who are waiting for the auto-population are advised to file the returns for the month of November 2020 and not to wait for the same.
e-invoice data will be auto-populated into GSTR – 1 from the tax periods October and November will start from 13th December 2020 and it is expected to take couple of weeks.
e-invoice data for the month of December is expected to be auto-populated from the first week of December in T+2 days.
Certain notified taxpayers have to prepare and issue their invoices by obtaining Invoice Reference Number (IRN) from Invoice Registration Portal (IRP) (commonly referred as ‘e-invoices’).
Upon successful generation of IRN, details of such e-invoices will be auto-populated in respective tables of GSTR-1. The same can be downloaded as excel file as well.
In case the GSTR-1 for corresponding period was already filed by the taxpayer, then, the details from einvoices can be downloaded as excel file only.
The details would be auto-populated based on document date.
Auto-population into GSTR-1 is as follows:
Columns of GSTR – 1 Auto-populated
Outward Supplies to Registered Person, other than Reverse Charge
B2B – 4A transactions expect for the following transactions i)Supplies attracting reverse charge ii)Supplies made through e-commerce operations
Outward Supplies to Registered persons attracting reverse charge
Table 6A – Exports
Credit/Debit Notes Issued to Registered persons
Table 9B – CDNR
Credit/Debit Notes issued for exports (unregistered persons)
Table 9B – CDNUR
6. The item-level details in the document will be aggregated at rate-level for the purpose of auto-population into GSTR-1. For the auto-populated invoices, below additional details will also be displayed. a. Source (e-invoice) b. Invoice Reference Number (IRN) c. Invoice Reference Number Date (IRN Date)
7. After auto-population of details from e-invoices, in case of cancellation of IRN, such documents will be deleted in the respective table.
8. Details of e-invoices auto-populated in GSTR-1 can be edited/deleted by the taxpayer. However, in such cases, the ‘Source’, ‘IRN’ and ‘IRN date’ fields will be reset to blank in respective tables of GSTR-1. Such edited documents will be treated as if they were not auto-populated but uploaded separately by taxpayer.
9. Before filing GSTR-1, taxpayers are advised to review the details of e-invoices auto-populated in specified tables:
a. By viewing them online on GST Portal, or b. By downloading the JSON from GST Portal, or c. By using APIs via GSP
Taxpayers are advised to modify/update only those documents where the details auto-populated from einvoices are not as per the actual invoice issued.
Taxpayers are required to add details of supplies made in respective tables of GSTR-1, other than those auto-populated from e-invoices.
An additional facility of consolidated download of all documents auto-populated from e-invoices is available in GSTR-1 dashboard. For this, you can use ‘Download details from e-invoice (Excel)’ button on GSTR-1 dashboard. It may to be noted that the auto-populated details in this excel file are as reported on e-invoice portal Invoice Registration Portal (IRP). So, any subsequent modifications made to the auto-populated documents (in GSTR-1 tables) would not be reflected in this excel file.
Taxpayer can use the link ‘e-invoice download history’ to view the list of last five downloaded files. On click of the link, you can download the file.
The excel file downloaded from GSTR-1 dashboard page will have details of all the e-invoices received from Invoice Registration Portal (IRP) including cancelled invoices. Following additional information relating to such e-invoices will also be available: a. Invoice Reference Number (IRN) – 64 string hash b. Date of Invoice Reference Number (IRN date) c. e-invoice Status – Valid/ Cancelled d. Date of auto-population/ deletion (in case of canceled IRN) will be the date when the e-invoice details are auto-populated in GSTR-1 or when the IRN was cancelled. Any subsequent modifications made to the auto-populated documents (in GSTR-1 tables) would not be reflected in this excel file. e. GSTR-1 auto-population / deletion status (either of the following): • Auto-populated, • Deleted, • Auto-population failed, • Deletion failed f. Error in auto-population/ deletion – Error description, if any