Resumption of Blocking of E-Way Bill (EWB) generation facility.
1. The blocking of E way bill generation facility had been temporarily suspended by Government on account of Covid pandemic. In terms of Rule 138 E (a) and (b) of the CGST Rules, 2017, the E Way Bill generation facility of a person is liable to be restricted, in case the person fails to file their return in Form GSTR-3B / statement in CMP-08, for consecutive two tax periods or more, whether Monthly or Quarterly.
2. The blocking of EWB generation facility has now resumed on the EWB portal for all the taxpayers. Going forward, from the tax period August, 2021 onwards, the System will periodically check the status of returns filed in Form GSTR-3B or the statements filed in Form GST CMP-08 as per the regular procedure followed before pandemic, and block the generation of EWBs as per rule.
3. To avail EWB generation facility on EWB Portal on continuous basis, you are, therefore, advised to file your pending GSTR 3B returns/ CMP-08 Statement on regular basis.
4. For details of blocking and unblocking EWB, Click on below link:
Advisory for Taxpayers regarding Generation of EWB where the principal supply is Supply of services.
One of the common issued faced by taxpayers who are dealing with composite supply where there is requirement to ship goods also when executing a service contract. To address this GSTN has issued an advisory on the same.
1. Representations have been received from various trade bodies stating that they are not able to generate EWB bill for movement of those goods where their principle supply is classifiable as a service, since there is no provision for generating E-way Bill by entering SAC (Service Accounting Code-Chapter 99) alone on the E- way bill portal.
2. To overcome this issue, the taxpayers are advised as below:
a) Rule 138 of CGST Rules, 2017, inter alia, states “Information to be furnished prior to commencement of movement of goods and generation of e-way bill.-(1) Every registered person who causes movement of goods of consignment value exceeding fifty thousand rupees….” Thus, E way bill is required to be generated for the movement of Goods.
b) Therefore, in cases where the principal supply is purely a supply of service and involving no movement of goods, the e-way bill is not required to be generated.
c) However, in cases where along with the principal supply of service, movement of some goods is also involved, e-way bill may be generated. Such situations may arise in cases of supply of services like printing services, works contract services, catering services, pandal or shamiana services, etc. In such cases, e-way bill may be generated by entering the details of HSN code of the goods, along with SAC (Service Accounting Code) of services involved.
The gross GST revenue collected in the month of June’ 2021 is₹92,849 crore of which CGST is ₹16,424 crore, SGST is ₹20,397, IGST is ₹49,079 crore (including ₹25,762 crore collected on import of goods) and Cess is ₹6,949 crore (including ₹809 crore collected on import of goods).The above figure includes GST collection from domestic transactions between 5thJune to 5th July’2021 since taxpayers were given various relief measures in the form of waiver/reduction in interest on delayed return filing for 15 days for the return filing month June’21 for the taxpayers with the aggregate turnover upto Rs. 5 crore in the wake of covid pandemic second wave.
During this month the government has settled ₹ 19,286 crore to CGST and ₹ 16,939 crore to SGST from IGST as regular settlement.
The revenues for the month of June 2021 are 2% higher than the GST revenues in the same month last year.
GST collection after posting above Rs. 1 lakh crore mark for eight months in a row, the collection in June’2021 dropped below Rs. 1 lakh crore. The GST collection for June’2021 is related to the business transactions made during May’2021. During May’2021, most of the States/UTs were under either complete or partial lock down due to COVID. The e-way bill data for the month of May 2021 shows that during the month, 3.99 crore e-way bills were generated as compared to 5.88 crore in the month of April 2021, down by more than 30%.
However, with reduction in caseload and easing of lockdowns, the e-way bills generated during June 2021 is 5.5 crore which indicates recovery of trade and business. The daily average generation of e-way bill for the first two weeks of April 2021 was 20 lakh, which came down to 16 lakh in last week of April 2021 and further to 12 lakh in the two weeks between 9th to 22nd May. Thereafter, the average generation of e-way bills has been increasing and has reached again to 20 lakh level since week beginning 20th June. Therefore, it is expected that while the GST revenues have dipped during the month of June, the revenues will see an increase again from July 2021 onwards.
NIC is happy to release the application/tool, known as GePP-On, for entering invoices and generation of IRN. This is a browser-desktop based application which can also be used on the mobile devices, without having web application/portal. The application will internally talk to the e-Invoice APIs for all the functionalities.
This will be helpful for the taxpayers who have few invoices so that they can generate e-invoices without going for any API integration. The application is designed with simple forms for entering the invoice details. The application has all the features like : Generation of IRN, Cancellation of IRN, Generation of EWB by IRN, Printing of e-Invoice with QR Code, creation of Recipient master and HSN master, backup and restoration of his data etc. The application can also run in offline mode ie, when no internet is available, the taxpayer can enter all the details of invoice and keep it ready. As and when the internet is resumed, the invoice details can be submitted to the e-Invoice portal and IRNs can be generated. Another important point is that all the data entered by the taxpayers such as invoice data, master data are stored locally on the taxpayer’s system. The taxpayer can also backup and restore data on to another system, if required.
Additionally, mobile apps are released for Android and iOS on the same lines as given above. The taxpayer can download these on his mobile and use them accordingly.
There are around 9600 taxpayers who are already using NIC GePP-Tool for generation of IRN. The difference between Gepp-Tool and GePP-On is that in the former, taxpayer enters the invoice details, generates JSON file and uploads in the e-Invoice portal. Where as in the latter, the taxpayer can enter all the details and on click of a button, IRN is generated. This will facilitate a large of number of small taxpayers in the coming days when the no. of taxpayers is increased for e-invoicing.
Beta version of GePP-On is launched on the sandbox system for testing by the tax payers who are enabled for e-invoice generation.
The e-invoicing system is also available for the E-Commerce Operators (ECO) to report the invoices to the Invoice Registration portal, generated by them on behalf of the suppliers. The e-invoicing system identifies the e-Commerce operators based on the taxpayer type in the GST registration details. The taxpayer having the type as ‘TCS’ will be enabled for reporting invoices on the e-invoicing system as eCommerce Operator. However, it is important to note that E-commerce transactions can be reported by the E-commerce operators with “EcmGstin” attribute as their GSTINs. This means to say, that apart from specifying the Seller GSTIN in the payload, it is mandatory to specify the e-Commerce operator GSTIN in the “EcmGstin” attribute of the schema by e-Commerce Operator when he logs in using his user credentials.
e-Invoice APIs available for e-Commerce Operators • Generate IRN (for self or on behalf of suppliers) • Cancel IRN (applicable to only for those IRNs, generated by e-Commerce operator) • Generate E-Waybill • Cancel E-waybill (applicable to only for those IRNs generated by e-Commerce operator) • Get IRN (applicable to only for those IRNs, generated by e-Commerce operator)
Scope of Access to IRNs generated by e-Commerce operator and Supplier
Process for integrating on the Sandbox system The following procedure has to be followed by the e-Commerce operators to integrate their ERP systems to the sandbox system of IRP. • The Registration module in the sandbox system has an option ‘E-Commerce Operator’ • The e-Commerce Operator may select this option and enter the GSTIN of type ‘TCS’ and get registered in the sandbox portal, by authenticating with OTP sent to the GSTIN registered mobile. • API credentials such as Client-Id, Client-Secret, User-name and Password may be generated. • On logging into the sandbox tool, there is no need to add the GSTINs. • The payload to generate the IRN may be prepared and tested in the sandbox tool. • As already mentioned, the payload shall contain the Seller GSTIN, Buyer GSTIN and also the e-Commerce GSTIN along-with other details. • All other validations and schema and procedure mentioned in the sandbox portal may be followed. • While using the ‘Cancel IRN’,’ Generate EWB by IRN’, Cancel EWB’, ‘Get IRN’, send the ‘Supplier GSTIN’ in addition to other parameters
Process for integrating on the Production system The following procedure may be followed by the e-Commerce operators to integrate their ERP systems to the production system of IRP. • The TCS registered taxpayer will need to do login registration in the Invoice registration portal (https://einvoice1.gst.gov.in). If already registered, the taxpayer can login to the Invoice registration portal. • Select the API registration. • Submit the application for whitelisting the IPs along with summary test report. Up to 4 Indian Static IPs are allowed. • On submission of the application, the network team will scrutinize and whitelist the IPs. • API credentials such as Client-Id, Client-Secret, User-name and Password may be generated. • Create the username and password for the other PAN related GSTINs by selecting the above GSTIN. • Use above credentials, the payload to generate the IRN, may be prepared and IRN may be generated. • As already mentioned, the payload will contain the Seller GSTIN, Buyer GSTIN and also the e-Commerce GSTIN along with other details
Due to the ongoing second wave of the Covid – 19 pandemic, there are a lot of restrictions imposed on the business and common person to curtail the spread of the virus. As a part of lockdowns or restrictions, the trade and industry cannot run the business full-fledged and causing a lot of hardships in the filing of returns or meet the compliance requirements. Keeping in view of all these, the Government has provided relaxation under GST in for wavier/part wavier of interest, late fee and extension of due date for filing of returns.
Notification No 8/2021 – Central Tax Dated 1st May 2021 – Reduction & wavier of Interest for delayed payment of taxes
Interest will not be applicable for the delay in filing of returns for the first 15 days, and from 16th day to 30th day, it will be charged at 9%, and after 30 days, the interest rate will be 18%, i.e., the normal rate. The above benefit will be applicable for the following class of persons for the months of April and May 2021
Taxpayers having aggregate turnover above ₹ 5 crores during the previous financial year
Taxpayers having aggregate turnover up to ₹ 5 crores during the previous financial year and filing GSTR – 1
Taxpayers having aggregate turnover up to ₹ 5 crores during the previous financial year and filing returns under QRMP (Quarterly Returns Monthly Payment) Scheme
Taxpayers who are availing of the Composition Scheme benefit
The above notification is a retrospective notification and is effective from 18th April 2021
Notification No 9/2021 – Central Tax Dated 1st May 2021 – Relaxation in Late fee
Levy of the late fee has been waived for the taxpayers who are filing GSTR – 3B
Late fee has been waived off for the first 15 days for taxpayers having aggregate turnover above ₹ 5 crores during the previous financial year
Late fee has been waived off for the first 30 days for taxpayers who are filing GSTR – 3B on a monthly basis and quarterly basis having aggregate turnover up to ₹ 5 crores during the previous financial year
The above notification is a retrospective notification and is effective from 20th April 2021
Notification No 10/2021 – Central Tax Dated 1st May 2021
The due date for filing of GSTR – 4 by composition taxpayers has been extended to 31st May 2021.
The above notification is a retrospective notification and is effective from 30th April 2021
Notification No 11/2021 – Central Tax Dated 1st May 2021
The due date for furnishing the declaration in FORM GST ITC-04, in respect of goods dispatched to a job worker or received from a job worker, during the period from 1st January 2021 to 31st March 2021 has been extended from 25th April 2021 to 31st May 2021.
Notification No 12/2021 – Central Tax Dated 1st May 2021 – Extension in filing due date for filing of GSTR – 1
The due date for filing of GSTR – 1 for the month of April 2021 has been extended to 26th May 2021.
Notification No 13/2021 – Central Tax Dated 1st May 2021 – Relaxation in matching
Relaxation in matching for the availing input tax credit for April 2021 has been provided, and the taxpayers have to do matching for the months of April and May together while filing GSTR – 3B for the month of May 2021.
Taxpayers who are filing returns under QRMP Scheme can file IFF (invoice furnishing facility) by 28th May 2021.
Notification No 14/2021 – Central Tax Dated 1st May 2021 – Relaxation in compliance proceedings due date
The time limits for the completion of compliance or any action by the tax authorities or any person which are falling between 15th April 2021 to 30th May 2021 has been extended in the following cases
a) completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called; or
b) filing any appeal, reply, or application or furnishing any report, document, return, statement, or other records, by whatever name is called.
The above extension is not applicable in the following cases
Related to Time of Supply
If the turnover of the composition taxpayer has crossed the threshold during this period
Section 25 – registration procedure
Section 27 – procedure-related to casual taxable person and the non-resident taxable person
Section 31 – Tax Invoice
Section 37 – provisions related to the filing of returns for outward supplies
Section 47 – provisions related to levy of late fee
Section 50 – provisions related to ley of interest
Section 69 – provisions related to power to arrest errant taxpayers
Section 90 – provisions related to Liability of partners of firm to pay tax
Section 122 – provisions related to penalties for certain offenses
Section 129 – provisions related to detention, seizure and release of goods and conveyance under transit
Section 39 – except for provisions related to sub-section (3), (4) and (5) related to TDS deductors, ISD and not resident taxpayers
Section 68 – provisions related to e-waybill
Provided that where, any time limit for completion of any action, by any authority or by any person, specified in, or prescribed or notified under rule 9 of the Central Goods and Services Tax Rules, 2017, falls during the period from the 1st day of May 2021 to the 31st day of May 2021, and where completion of such action has not been made within such time, then, the time limit for completion of such action, shall be extended up to the 15th day of June 2021;
We are in the world of New Normal due to the ongoing pandemic globally. Pandemic has resulted in disruptions and business strategy changes based on consumer preferences and budget allocations. The organizations have started the new financial years on 1st April 2020 in the lockdown period. None of the organizations have prepared or able to scale to the dynamic & ever-changing business environment. Time Never Stops, and History Repeats are the two common phrases we hear in our discussions in business circles. Come whatever may happen, organizations have to close their books of accounts for 31st March year. Closure of books in time and properly helps the organization mitigate the risks and take timely actions for the coming year to improve the top line and bottom line. What is required for increasing the top line and bottom line is a strategy on how to achieve it, and compliance is one of the strategies meant to achieve the same. As we all know, GST is a Business Reform, not tax reform; changing few business processes in the organization here and there can ensure productivity while safeguarding the organization from hefty penalties and late fees. Following a structured process will ensure to minimize the same and at the same time be in good books of the tax authority and the suppliers. Professionals and taxpayers are required to complete the following before filing the GSTR – 1 and GSTR – 3B for March 2021 by 11th of April 2021 and 20th of April 2021 ( for few taxpayers, it will be 22nd of April or 24th of April if their turnover is less than ₹ 5 cores based on the state they are located).
Reconciliation of Outward Supplies
Reconciliation of Inward Supplies
Reconciliation of Related Party Transactions
Issue of Pending Debit/Credit Notes
Reversal of ITC arising out of pandemic
Reconciliation of Outward Supplies
A series of reconciliations have to be done while filing the returns for March 2021 if the reconciliations have not been done while filing monthly and quarterly returns.
Verify the following for the correctness of the data in return filing
Taxable Supplies, Exempted Supplies are reported correctly
Non-GST supplies are reported correctly
Supplies to deemed exporters are reported correctly at lower tax rates
Supplies to notified agencies at a lower rate are reported correctly
All outward supplies transactions are reported correctly in the Sales Register
Ensure that e-invoices are issued wherever required if applicable
Ensure and validate that the GSTINs of the customers are entered correctly and reported
Ensure and validate that no GST is charged for transactions within the state having the same GSTINs
Ensure that all the debit and credit notes are issued as per the provisions of GST
Ensure and verify that all the liability entries are passed in the books of accounts
Complete the following reconciliations before the filing of the March GST Returns
Reconcile between the GSTR – 1 data and the Sales Register
Reconcile between GSTR – 1 and GSTR – 3B
Reconcile between GSTR -3B and Sales Register
Reconcile the data for the HSN summary being reported in monthly GSTR – 1
Reconcile e-waybill data with GSTR – 1 data, and if there are any differences, it is worth making a reconciliation statement and preserve it for future references.
Reconcile the e-invoices reported in the GSTR – 1 with the e-invoices generated
Reconcile between the Liability Ledgers on GST portal with the
The beginning of the year started with lockdown, and it has resulted in a lot of delays and cancellations of orders. Wherever there is a commercial element missing and open, try to close all such cases by the issue of debit and credit notes. Credit Notes have to be issued before the due date of filing of GSTR returns for the month of September or filing of Annual Return, whichever is earlier.
Section 37 (3), First Proviso
Provided that no rectification of error or omission in respect of the details furnished under sub-section (1) shall be allowed after furnishing of the return under section 39 for the month of September following the end of the financial year to which such details pertain, or furnishing of the relevant annual return, whichever is earlier.
If any excess tax is paid for the said period through GSTR – 3B, then the same should be reduced from the GST liability in March 2021, reducing the cash outflows. Also, please maintain a reconciliation statement for the same for future reference.
2.Reconciliation of Inward Supplies
One of the major features and business-friendly measures in GST is the availability of seamless input tax credit. Though it is a piece of soothing music to the business’s ears, it comes with a set of stringent measures like if input tax credit has been availed wrongly or excess amounts or claiming it if the supplier has not filed returns. Given all these, availing of the input tax credit process and claiming correctly becomes crucial for the business.
One of GST rollout’s major benefits for the trade and industry is the availability of input tax credit seamlessly across the supply chain cycle. Though input tax credit is available, certain restrictions are available, and they are given in Section 16, Section 17(5), and in the corresponding rules.
Section 16(4) A registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services or both after the due date of furnishing of the return under section 39 for the month of September following the end of financial year to which such invoice or invoice relating to such debit note pertains or furnishing of the relevant annual return, whichever is earlier.
Before doing the reconciliation, ensure to complete the following tasks
Update the purchase register for the entire year and ensure all the transactions are updated in it.
Verify that e-invoices are received from all the suppliers to whom it is applicable; else, it will not be considered a tax invoice and not eligible to claim the input tax credit.
Verify and ensure that all the original copies of the tax invoice are available
Verify and ensure that the goods and services are received before availing of the input tax credit
Verify and ensure that all the credit and debit notes are updated in the system and accounted
Verify and ensure that if any debit or credit notes are required to be issued by the supplier are issued, filed by the supplier in his returns and also accounted in the books
Verify and ensure that RCM applicability on inward supplies is identified and accounted for, and paid.
Verify and ensure that input tax credit is availed only on eligible inward supplies only
Verify and ensure that input tax utilization entries passed in the books of accounts
Section 17(5)
(b) the following supply of goods or services or both—
food and beverages, outdoor catering, beauty treatment, health services, cosmetic and plastic surgery, leasing, renting or hiring of motor vehicles, vessels or aircraft referred to in clause (a) or clause (aa) except when used for the purposes specified therein, life insurance and health insurance:
membership of a club, health and fitness centre; and
(c) works contract services when supplied for construction of an immovable property(other than plant and machinery) except where it is an input service for further supply of works contract service;
(d) goods or services or both received by a taxable person for construction of an immovable property (other than plant or machinery) on his own account including when such goods or services or both are used in the course or furtherance of business.
(h) goods lost, stolen, destroyed, written off or disposed of by way of gift or free samples; and
Apart from ensuring the steps mentioned above are completed and the do the reconciliation
Complete the following reconciliations
Reconcile between GSTR – 2A / 2B with Purchase Register
Reconcile between GSTR -2A /2B with GSTR – 3B
Reconcile between GSTR-3B with Purchase Register
Reconcile the ITC Ledger on GST portal with the various ledger accounts
Rule 69 – Matching
The following details relating to the claim of input tax credit on inward supplies including imports, provisionally allowed under section 41, shall be matched under section 42 after the due date for furnishing the return in FORM GSTR-3-
Goods and Services Tax Identification Number of the supplier;
Goods and Services Tax Identification Number of the recipient;
invoice or debit note number;
invoice or debit note date; and
tax amount:
3. Reconciliation of Related Party Transactions
In multiple instances, related parties are not accounted for properly, or returns are filed incorrectly. This results in a lot of tax litigation or reversal of input tax credits through discharge of liability. Though there is no loss to the exchequer, it is not as per the law’s provisions, and the taxpayer cannot amend the returns if they have claimed wrongly.
It is recommended to verify all such transactions if there are any related party transactions and rectify the same in the March months returns. This process will ensure no loss of input tax credit, excess payment of taxes, which impacts the organization’s bottom line. This will also eliminate litigation and save time and effort.
The above process is not required if the taxpayers reconcile their data before filing their monthly returns
4. Issue of Pending Debit/Credit Notes
In a going business concern, there will always be issues and challenges in the supply chain. The supply chain challenges could be damages or breakages in transit or delay in shipments or receipt of goods, or receipt of inferior quality or different ones from the ordered—all these results in some price negotiations or others. In GST, only the supplier of goods or services can issue a debit note, and the recipient cannot unilaterally issue a debit note or credit note on the supplier.
As the above case results in price negotiation, there will always be a delay in the process, and as it is the year-end, it is recommended to clear all such pending issues. A rigorous follow-up with the vendors is required, backed by documentation.
Another case could be on account of reconciliation, there could be some suppliers who must have missed filing their returns, or their registrations have been canceled; in all such cases where the supplier has not filed the returns, a credit note should be requested to be issued to compensate the loss of input tax credit. If the supplier does not issue a credit note and the payment is already made, then the taxpayer cannot do anything but reverse the input tax credit with interest at the rate of 24%; payment of interest will be an additional loss to the taxpayers. To avoid such cases, before the payment release, it is recommended to complete the reconciliation process or withhold the tax amount until the supplier files the GST returns. This process will ensure that there is an impact on the bottom line.
Similar could be the case in the case of outward supplies. Also, it is recommended to issue debit or credit notes before the 31st of March 2021.
Section 34(2) – Any registered person who issues a credit note in relation to a supply of goods or services or both shall declare the details of such credit note in the return for the month during which such credit note has been issued but not later than September following the end of the financial year in which such supply was made, or the date of furnishing of the relevant annual return, whichever is earlier, and the tax liability shall be adjusted in such manner as may be prescribed:
Though there is no time limit for the issue of Debit Note but is advised to issue the same as the same will minimize the pending issues, the issue of debit notes brings is additional cash into the system, which has become scarce due to the business disruptions on account of the pandemic.
5.Covid Impact on GST
The pandemic has impacted every business directly or indirectly. The impact is on the sales front, profits front as well on the operations and employee front. As the lockdowns have been announced to curtail the spread of the deadly virus, many manufacturers and service providers have impacted their businesses.
Manufacturers
If any spoilage/wastage of raw materials or work in progress, the same is being debited to the Profit and loss account simultaneously. If any input tax credit has been availed, the same has to be reversed and observed in the profit and loss account.
If any goods have been expired due to the lockdown, the same is being written off to the profit and loss account. Similarly, the input tax credit has to be reversed if any availed.
If the customers have returned the goods and the same could not be used, were scrapped or destroyed for not being used, the input tax credit has to be reversed on such goods.
If the scrapped goods are sold at a nominal rate, then input tax credit need not be reversed as it is sold as scrap, and GST is paid on it as per one school of thought.
The pandemic has also resulted in a delay in payments. Identify if the suppliers are paid within 180 days; if not, the input tax credit must be reversed on the amounts due from one hundred and eighty-first day onwards.
If any return of the goods by the customers or dealers or distributors, issue the credit notes immediately without further delay. It will be a challenge in financial reporting if issued after 1st April 2021.
Service Providers
If the advance is received from the customers and service is not being provided due to the lockdowns, advance received treatment becomes crucial in GST. The possible scenarios and treatment under GST
If the advance is returned in the same month, then no need to account for GST on receipt of the advance. Verify and validate all such advance receipts, and if GST is not paid, please pay interest on it if the invoice is issued in the subsequent months.
If the invoice is not issued till 31st March and service is not provided, validate and verify if GST is paid on the advance receipt along with the interest
If an amount is partially returned in the subsequent months and service is not provided, validate and verify if GST is paid on advance receipt if not account it and pay along with interest
The pandemic has also resulted in a delay in payments. Identify if the suppliers are paid within 180 days. If not, the input tax credit must be reversed on the amounts due from one hundred and eighty-first day onwards.
If any credit notes are required to be issued for the delay in service, complete the activity before filing GST Returns for March; else, reconciliation statements have to be prepared to explain to various stakeholders.
If any debit notes have to be issued for price variations, the activity must be completed before the GST Returns filing for March 2021; else, reconciliation statements must be prepared to explain to various stakeholders.
The points mentioned above are indicative and may vary from taxpayer to taxpayer. It is also recommended to address the following points before the filing of the March return
Inputs sent on job work if not returned within the stipulated period; tax invoice has to be issued
Avail of the input tax credits if any is missed out
There is an exemption for reporting input tax credit by classification for the first two years only; the taxpayers must classify and claim input tax credit accordingly. If not done, prepare a reconciliation statement and validate that the same match the input tax credit claimed in GSTR – 3B.
Verify If any employee gifts above Rs 50,000 on which tax liability has to be paid
Verify if any input tax credit has to be reversed for the goods given without any consideration
Verify if any shortages or damage to stock on which input tax credit has been claimed? If any such items are there, reverse the input tax credit
Validate the input tax credit reversed on common inputs for taxable and exempted supplies being reversed
Verify input tax credit has been reversed on a pro-rata basis on capital goods from one state to another state
Verify the financial credit notes and debit notes issued according to the l provisions; else, issue GST Credit / Debit Notes.
File all the relevant returns as per applicability and complete the reconciliations
Verify if all the customers who have to file GSTR – 7 & 8 have filed their returns and accepted the same, this will save on the cash outflows.
Wherever possible, if any ITC has to be reversed or tax has to be paid, account for it and discharge it through GSTR – 3B.
Verification of the above tasks is a time-consuming process, and it is recommended to start the process ASAP and ensure that no input tax credit benefit lapses. No removal of difficulties order has been issued for availing input tax credit for an extra period on account of a pandemic-like situation.
During the first three years after the rollout of GST, there was an option for corrections using the GSTR – 9 for liability. The same is being withdrawn based on the Finance Bill 2021, yet to be notified; if this is the case, there is no room left for the taxpayers for rectification. The wrongdoings can be seen only during the audit or scrutiny by the department officers over a period of time. By that time, the penalty amount along with interest also is going to be increased multi-fold. To avoid such challenges, it is highly recommended to follow the above steps before filing the returns for March 2021.
To avoid all the challenges, the return filing data should be captured in the accounting or ERP system accordingly. Wherever possible, automation should be introduced to minimize human efforts and automate the process of data entry and reconciliations. Let’s not forget that GST is a business reform and not tax reform.
Any views or opinions represented above are personal and belong solely to the author and do not represent those of people, institutions, or organizations that the author may or may not be associated with within a professional or personal capacity unless explicitly stated. Any views or opinions are not intended to malign any religion, ethnic group, club, organization, company, or individual.
The 38th meeting of the GST Council met under the Chairmanship of the Union Minister for Finance & Corporate Affairs Smt. Nirmala Sitharaman here today. The meeting was also attended by the Union Minister of State for Finance & Corporate Affairs Shri Anurag Thakur besides Finance Ministers of States & UTs and senior officers of Ministry of Finance. The GSTCouncil recommended the following:
Grievance Redressal Committees (GRC) will be constituted at Zonal/State level with both CGST and SGST officers and including representatives of trade and industry and other GST stakeholders (GST practitioners and GSTN etc.). These committees will address grievances of specific/ general nature of taxpayers at the Zonal/ State level.
Due date for annual return in FORM GSTR-9 and reconciliation statement in FORM GSTR-9C for FY 2017-18 to be extended to 31.01.2020.
Following measures would be taken to improve filing of FORM GSTR-1:
waiver of late fee to be given to all taxpayers in respect of all pending FORM GSTR-1from July 2017 to November 2019, if the same are filed by 10.01.2020.
E-way Bill for taxpayers who have not filed their FORM GSTR-1 for two tax periods shall be blocked.
Input tax credit to the recipient in respect of invoices or debit notes that are not reflected in his FORM GSTR-2A shall be restricted to 10 per cent of the eligible credit available in respect of invoices or debit notes reflected in his FORM GSTR-2A.
To check the menace of fake invoices, suitable action to be taken for blocking of fraudulently availed input tax credit in certain situations.
A Standard Operating Procedure for tax officers would be issued in respect of action to be taken in cases of non-filing of FORM GSTR 3B returns.
Due date of filing GST returns for the month of November, 2019 to be extended in respect of a few North Eastern States.
The Council also approved various law amendments which will be introduced in Budget 2020.
[This note presents the decision of the GST Council in simple language for easy understanding which would be given effect through Gazette notifications/ circulars which alone shall have force of law. The same will be made effective from the date as specified in such notifications / circulars.]
As per the decision of the GST Council, e-Way Bill system for inter-State movement of goods has been rolled out from 1 April, 2018. As on 23 May, 2018, e-Way Bill system for intra-State movement of goods has been rolled out in the States of Andhra Pradesh, Arunachal Pradesh, Assam, Bihar, Gujarat, Haryana, Himachal Pradesh, Jharkhand, Karnataka, Kerala, Madhya Pradesh, Meghalaya, Nagaland, Rajasthan, Sikkim, Telangana, Tripura, Uttarakhand, Uttar Pradesh and Union Territory of Puducherry. E-Way Bills are getting generated successfully and till 23 May, 2018 more than five crore and thirty lakh e-Way Bills have been successfully generated which includes more than one crore and sixty lakh e-Way Bills for intra-State movement of goods.
It is informed that e-Way Bill system for intra-State movement of goods would be
implemented from 25 May, 2018 in the following States / Union Territories :-
i. Maharashtra
ii. Manipur
iii. Andaman & Nicobar Islands
iv. Chandigarh
v. Dadra & Nagar Haveli
vi. Daman & Diu
vii. Lakshadweep
Twenty seven States / Union Territories would have implemented the e-Way Bill system for intra-State movement of goods with the roll-out of the same on 25 May, 2018. Registration/enrolment on e-Way Bill portal namely https://www.ewaybillgst.gov.in may be taken at earliest in the remaining States as well since the same would soon be rolled out in these States also. The system is working smoothly and without any glitches. On an average twelve lakh e-way bills are being generated every day. Trade and industry may approach their respective tax authority for any guidance in this matter. Further, it is informed that trade should get well versed with respect to the provisions of the e-Way Bill rules in order to avoid any difficulty. The provisions of rule 138D of Central / State GST Rules, 2017 may be referred to for any grievance redressal.
Recommendations regarding E-way Bill made during meeting of the GST Council
Posted On: 10 MAR 2018 4:47PM by PIB Delhi
In the 26th meeting held here today , the GST Council has recommended the introduction of e-way bill for inter-State movement of goods across the country from 01st April 2018. For intra-State movement of goods, e-way bill system will be introduced w.e.f. a date to be announced in a phased manner but not later than 01st June, 2018.
Major improvements over the last set of rules, as approved by the Council now, are as follows:
E-way bill is required to be generated only where the value of the consignment exceeds Rs. 50000/-. For smaller value consignments, no e-way bill is required.
The provisions of sub-rule (7) of Rule 138 will be notified from a later date. Therefore, at present there is no requirement to generate e-way bill where an individual consignment value is less than Rs. 50,000/-, even if the transporter is carrying goods of more than Rs. 50,000/- in a single conveyance.
Value of exempted goods has been excluded from value of the consignment, for the purpose of e-way bill generation.
Public conveyance has also been included as a mode of transport and the responsibility of generating e-way bill in case of movement of goods by public transport would be that of the consignor or consignee.
Railways has been exempted from generation and carrying of e-way bill with the condition that without the production of e-way bill, railways will not deliver the goods to the recipient. But railways are required to carry invoice or delivery challan etc.
Time period for the recipient to communicate his acceptance or rejection of the consignment would be the validity period of the concerned e-way bill or 72 hours,whichever is earlier.
In case of movement of goods on account of job-work, the registered job worker can also generate e-way bill.
Consignor can authorize the transporter, courier agency and e-commerce operator to fill PART-A of e-way bill on his behalf.
Movement of goods from the place of consignor to the place of transporter up to a distance of 50 Km [increased from 10 km] does not require filling of PART-B of e-way bill.They have to generate PART-A of e-way bill.
Extra validity period has been provided for Over Dimensional Cargo (ODC).
If the goods cannot be transported within the validity period of the e-way bill, the transporter may extend the validity period in case of transhipment or in case of circumstances of an exceptional nature.
Validity of one day will expire at midnight of the day immediately following the date of generation of e-way bill.
Once verified by any tax officer, the same conveyance will not be subject to a second check in any State or Union territory, unless and until, specific information for the same is received.
In case of movement of goods by railways, airways and waterways, the e-way bill can be generated even after commencement of movement of goods.
Movement of goods on account of Bill-To-Ship-To supply will be handled through the capturing of place of despatch in PART-A of e-way bill.
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