In GSTR – 3 if there is a difference between the tax amounts filed in GSTR – 3B and with GSTR – 1 and GSTR – 2, the same can be adjusted in Part – B of GSTR – 3. If the tax liability is more, then the same has to be paid/discharged in case of excess credit, the same will be updated in the electronic credit ledger.
The last date for filing of Returns for the month of July 2017 has been extended wide Notification No. 54 /2017 – Central Tax. In case of GSTR – 2 the last date is 30th Nov 2017 and in case of GSTR – 3 it is 11th Dec 2017.
In GSTR – 3B, the tax implications on the credit notes, debit notes & purchases from unregistered dealers which are falling under RCM have to be reported and paid, in case of f the taxpayer has missed all these documents, they can upload the same in GSTR – 1 and GSTR – 2 and this will automatically get updated in the GSTR – 3 and the tax liability can be settled and be GST compliant.
If a taxpayer has missed any outward supplies or inward supplies invoices amounts while filing GSTR – 3B, those invoices can be included in the GSTR – 1 and GSTR – 2 and the output liability and input tax credit will be considered in the GSTR – 3 and if any amount is payable the same can be paid. As there is no edit option available for GSTR – 3B, this approach can be taken and be tax compliant.
The due dates for the return of GSTR have bee extended and now there are few Do’s and Dont’s issued by the Department. Please follow them.
Notification # 29 of CGST issued for Extension of due dates for furnishing details/Returns for the months of July, 2017 and August, 2017. http://india-gst.in/wp-content/uploads/2017/09/notfctn-29-central-tax-english.pdf
The due dates for the filing of GST Returns for the month of July and August 2017 have been extended.
July 2017 Returns
GSTR – 1 : 10th Sep 2017
GSTR – 2 : 25th of Sep 2017
GSTR – 3 : 30th Sep 2017
August 2017 Returns
GSTR – 1 : 5th Oct 2017
GSTR – 2 : 10th Oct 2017
GSTR – 3 : 15th Oct 2017
GST is rolled out from 1st of July 2017 and the trade and industry is able to adapt to the same with some teething troubles. Though all the issues are not resolved some of them are still and it takes some time to get resolved. One month has passed after the rollout of GST and now it is the time for filing of returns. The same is updated through a press release by CBEC on 18th June 2017 – http://www.cbec.gov.in/resources//htdocs-cbec/press-release/press-note-on-return-filing.pdf
As there is a delay in filing of the returns, a new form is known as GSTR – 3B has been introduced and it has to be filed by 20th of Aug 2017. The format is released by the Government. It is basically a summary of the return for the month of July 2017 for determining the net tax liability to be paid. This statement looks simple but the challenge is on a careful review of the format it is clear that there is no provision for the opening balance of the input tax credit as of 30th June 2017. The reason is the GST Tran-1 form has to be filed within 90 days from the appointed date i.e 1st of July 2017. As a result of the closing balance of the Input Tax Credit will not be available for the taxpayers to use the same for payment of taxes for the month of July 2017.
This will have a huge impact on the cash flows as the tax payers have to pay in cash without using the available input tax credit and it is going to impact the MSME sector a lot especially for taxpayers who were not eligible to take registration under Central Excise in the erstwhile regime now they have to pay CGST.
The portal for the GST i.e GST.gov.in is not having the option of filing of the GSTR – 3B as on date, that means the taxpayers have to wait for some more time for filing of the return. This time lag should be utilized by the taxpayers for renegotiating with their customer to receive the payments or at least for the tax amount. Alternatively, they have to look out for additional cash flow either through additional funding or increase their CC limits or another means. The same is likely to continue for the next month also.
Managing of the working capital is one area and another is ensuring that the data required for the return filing is also in place. GSTR – 3B is an interim return and the actual returns for GST have to be filed by 10th of September i.e, GSTR – 1 by 5th September 2017 and GSTR – 2 by 10th September 2017.
Part B of the GSTR – 3 will be auto-populated for Tax, Interest, late fee, penalty from Cash Ledger and Input Tax Credit Ledger in GSTR – 3.
GSTR – 3 is a monthly return to be filed on basis of the finalized data of outward supplies i.e GSTR – 1 and inward supplies i.e GSTR – 2 along with the amount of tax, interest, late fees and penalty paid for the month.