As per Notification No. 60/2017 – Central Tax, the last date for filing of Form GSTR – 5 by a non-resident taxable person for the periods July 2017, August 2017, September 2017, October 2017 by 11th Dec 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.