returns and payments in gst ca jignesh kansara · slide no. 4. 10/18/2019 3 jignesh kansara ... •...

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Returns and Payments in GST(Existing and Proposed Returns)

CA Jignesh Kansara

Knowledge Sharing @Long Duration Course By BCAS

On 18th October 2019

Jignesh Kansara

DisclaimerDisclaimer

• The information in this presentation was compiled from various sourcesbelieved to be reliable and is for informational purpose only.

• While every efforts have been made to keep the information cited in thispresentation error free, we do not take the responsibility for anytypographical or clerical error which may have crept in while compiling theinformation provided in this presentation. Further, the information providedin this presentation are subject to the provisions contained under differentacts and reader is are advised to refer to those relevant act before relying onour presentation. This presentation does not purport to identify and dealwith all the issues and provisions related to subject and therefore should notbe regarded as comprehensive / sufficient for the purpose of decisionmaking. Author does not undertake any legal liability for any of the contentsof this presentation. The information provided is not, nor is it intended to bean advice on any matter and should not be relied on as such. Professionaladvise must be sought before taking any action on any of the informationcontained in it.

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Agenda

Action Item #1

Walkthrough of

Existing Returns

Action Item #2

Recent Changes

Action Item #3

Proposed

Returns

Action Item #4

Q & A

Basics

Walk through of Existing Returns

Slide No. 4

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Eco system as originally envisaged

Slide 5

GSTR‐1On 10th of next

monthDetails of outward supply furnished

by supplier

GSTR‐2ABetween 11th to 15th of the next

monthDetails of outward supply furnished by

supplier made available to recipient

GSTR‐2Between 11th to

15th ofthe month,

Recipient to add, delete, modify , confirm details in

GSTR‐2, ITC declared

If accepted, then GSTR‐1 shallstand amended to that extent

GSTR‐1ABetween 16th to

17th of the month,Changesmade by recipient to be

communicated to supplier and he can accept or reject the

changes

GSTR ‐3To be filed on or before 20th of the next month

Matching of Invoicesas per Sec 42 and 43

If matched, ITC / reduction in liability to be finally accepted If Unmatched, added to liability

Jignesh Kansara

Present Eco system of GST returns

Slide 6

GSTR‐1On 11th of next

monthDetails of outward supply furnished

by supplier

GSTR‐2ADetails of outward supply furnished by

supplier made available to recipient

GSTR‐3B20th of the next

monthSummary Return

cum challan

ITC in 3B is ITC in 3B is not flowing from GSTR‐

2A

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Sub Parts of Existing Eco system

C B Mehta and Associates

GSTR‐14. B2B

5. B2CL

6. Zero Rated

7. B2CS

8. NIL/Exempt/ Non‐GST

9. Amendments to 4‐5‐6

10. Amendment to 7

11. Advance/ Adj.

12. HSN Summary

13. Doc Summary

GSTR‐3B

3.1(a) Outward Taxable

3.1(b) Zero rated

3.1 (c) NIL/ Exempted

3.1(d) Inward RCM

3.1 (e) Non‐GST Supplies

3.2 B2C/ Composition

4A ITC availed

4B ITC reversed

4D Ineligible ITC

5. Payment of Taxes

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Specimen GSTR‐1 PDFSpecimen GSTR‐1 PDF

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FinalOutput

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4A, 4B, 4C, 6B, 6C ‐ B2B Invoices4A, 4B, 4C, 6B, 6C ‐ B2B Invoices

Table Ref

Description

4A Normal B2B Taxable Supplies Majority of Sales for any Normal business will be B2B (Excluding 4B and 4C)

4B Normal B2B Taxable Supplies subject to Reverse Charge Very Few Goods and Services are under Reverse Charge ie Recipient will pay Tax and not the borrower Reverse Charge on Goods : 04/2017‐Central Tax (Rate),dt. 28‐06‐2017Reverse Charge on Goods : 13/2017‐Central Tax (Rate),dt. 28‐06‐2017

4C Supplies made through e‐commerce operator attracting TCS (operator wise, rate wise) TCS Implications

6B Supplies made to SEZ unit or SEZ Developer If GST is charged or paid

6C Deemed exports (Only Goods)Sales to EOU / Electronic Hardware Technology Park Unit (EHTP) / SoftwareTechnology Park Unit (STP) / Bio‐Technology Park Unit (BTP)Not Zero rated but Benefit of Refund is available.

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Only B2B Supplies

Jignesh Kansara

5A,5B & 7 ‐ B2C – Invoices 5A,5B & 7 ‐ B2C – Invoices

Table Ref

Description Remark

5A Outward supplies (other than supplies made through e‐commerce operator, rate wise)

B2CL

5B Supplies made through e‐commerce operator attracting TCS(operator wise, rate wise)

B2CL‐Eco

7 B2C (Others) – Consolidated figures B2CS

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B2CL: • Inter State B2C supplies &• Invoice value more than 2,50,000

B2CS : • All Intra State B2C Supplies (without limit of Invoice Value) & • Inter State B2C supplies having Invoice value up to 2,50,000

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9B – Credit Notes (Registered) – B2B9B – Credit Notes (Registered) – B2B

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B2B Dr / Cr Notes

B2C Dr / Cr Notes

Credit note of a FY to beissued by 30th September ofNext Financial year and todisclosed in GSTR‐1 of Sep

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Export with IGST or without IGSTExport with IGST or without IGST

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Export Without IGST

Export with IGST

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8 ‐ Nil rated, exempted and non GST outward supplies8 ‐ Nil rated, exempted and non GST outward supplies

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Supply on which GST is not payable

Excluding Sch III Items

Section 17(2) – may Involve ITC Reversal

Net Reporting

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11A(1), 11A(2) – Tax Liability Advance Received 11A(1), 11A(2) – Tax Liability Advance Received

Time of Supply Services : GST payable earliest of raising of Invoice/ Rendering ofService/ Receipt of Advance

NN 66/2017‐CT dated 15th Nov 2017: No GST on Advance received againstsupply of Goods (Irrespective of Turnover of Supplier)

Time of Supply Goods : Raising of Invoice / Transfer of ownership in Goods.

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11B(1),11B(2) – Adjustment of Advances 11B(1),11B(2) – Adjustment of Advances

• Time gap within which Advance is settled either by way of raising of Invoice orrepayment of Advance

• Tracking of Opening Advance, Advance received and Advance adjusted duringthe year = year end advances

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12 ‐ HSN‐wise summary of outward supplies12 ‐ HSN‐wise summary of outward supplies

What is HSN code?

Harmonized System of Nomenclature which was developed by the World CustomsOrganization (WCO) with the vision of classifying goods all over the World in asystematic manner. This type of classification is used for identifying the GST rateapplicable to a product / services.

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13 – Documents Issued 13 – Documents Issued

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Details of various type of Documents issued by Tax payer during the relevant PeriodPrescribed GST documents are • Tax Invoice • Debit Note • Credit Note• Delivery Challan • Reverse Charge Invoice • Receipt Voucher – Advance Receipt • Refund Voucher – Advance is returned

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Amendments Table Amendments Table

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• Why Amendment Table?• Amendment of earlier period details • Amendment – Facility given to rectify data feeding error occurred while filing GSTR‐1 in

earlier period.• Amendment can be done only once. • Details of Supply made in a FY can be amended till September GSTR‐1 of next FY (For 1718

– deadline was extended till March 19 Return)• Originally filed return does not automatically get amended

Amendment of 4A, 4B, 4C, 6B, 6C ‐ B2B Invoices

Amendment 5A, 5B, ‐ B2CL Invoices

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Amendment of 9B‐Credit / Debit Notes (Registered)

Amendment of 9B‐Credit / Debit Notes (Unregistered)

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Amendment of Invoices reported in 6A Table

Amendment of Invoices reported in 7 Table

Amendment of Advance reported in 11A(1) & 11A(2) Table

Amendment of Advance adjusted in 11B(1) & 11B(2) Table

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Basics of GSTR‐3BBasics of GSTR‐3B

• Consolidated summary cum Payment challan

• Gujrat HC judgment in AAP & Co, GSTR‐3B is not in lieu of GSTR‐3

• As per NN 49/2019‐CT dated 9th Oct, 2019, 3B is in lieu of 3 w.e.f 1st July 2017(Retrospective effect)

• Without making Payment GSTR‐3B can’t be filed

• Only consolidated Details, Invoice level detailed are not called for

• Supplies are reflected Net of Debit/Credit Notes, Net of Advance received /Advance adjusted, Net of Amendments.

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GSTR‐3B – Outward Supply GSTR‐3B – Outward Supply

SN Description What to include?

3.1(a) Outward TAXABLE supplies (other than zero rated, nil rated and exempted)

• All taxable Inter state and Intra State Outward supply of Goods and Services

• B2B + B2C• Net of Advance received + Adjusted

3.1(b) Outward TAXABLE Supplies (Zero Rated):

• Export of Goods as well as Services withoutcharging IGST.

• Export of Goods as well as Services on which IGST ischarged.

• Outward Supplies made to SEZ (with or without IST

3.1(c) Other Outward Supplies (NIL Rated, Exempted)

Supplies of any goods / services on which rate of GST is NIL or on which GST is exempted by way of Notification

3.1(d) Inward Supplies (LIABLE to Reverse Charge):

E..g GTA Services, Legal Fees, Import of Services.

3.1(e) NON GST outward supplies Alcohol, Crude oil, petroleum product etc

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What if details mentioned in wrong Table ?

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Long and Short of ITC in GSTR‐3BLong and Short of ITC in GSTR‐3B

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Rule 37, 39 etc

Blocked CreditsOther ITC not at available

Forward Charge ITC

9(3) / 5(3) / 9(4) / 5(4) excl 1 & 2

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Flow of data from GSTR‐1 to GSTR‐3BFlow of data from GSTR‐1 to GSTR‐3B

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4A

3.1(a) of GSTR‐3B

GSTR‐1

5A

4C5B

7

6C

9B Debit / Credit Note

11A

11B

Amendments

Amendments

6B

If IGST is charged on SEZ sale

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6A

3.1(b) of GSTR‐3B

GSTR‐1

Amendments

Amendments6B

If IGST is not

charged on SEZ sale

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3.1(c) of GSTR‐3B

GSTR‐1

3.1(e) of GSTR‐3B

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NN 49/2019‐CT dt. 9th Oct 2019 – Restrictions on availing ITC NN 49/2019‐CT dt. 9th Oct 2019 – Restrictions on availing ITC

Rule 36(4) inserted

Input tax credit to be availed by a registered person in respect of invoices ordebit notes, the details of which have not been uploaded by the suppliers undersub‐section (1) of section 37, shall not exceed 20 per cent. of the eligible creditavailable in respect of invoices or debit notes the details of which have beenuploaded by the suppliers under sub‐section (1) of section 37.”

Provisional credit can now be only 20% of confirmed credit

2 earlier Press release by CBIC – GSTR‐2A is just Trade facilitation measures,whether change in stand?

To Curb – Hawala Billing – Fictitious ITC – Mop up Tax collection

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NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers Is it applicable for September 19 GSTR‐3B?

Is it practically feasible in absence of GSTR‐2?

Whether portal is equipped to implement this change?

Whether amendment is with reference to Proposed Returns (Section 43A)or existing one also?

Is it qua each GSTR‐3B or in relation to Annual Return?

Any Mechanism to claim credit of earlier period reflected subsequently.Whether cumulative calculation every month

What is supplier subsequently amend / delete details of supply? No lockingof Invoice like GSTR‐2

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NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers

Whether Invoice level matching is required to weed out ineligible ITC?

What if majority of vendors are in Quarterly mode? Should we request them toupload Invoice details at least on monthly basis.

20% of only forward charge credit or total credit including Rcm? – Only forwardcharge credit

What about past adjustments of 1819 and 1920?

What if disclosed belatedly by supplier? Will there be interest consequence?Whether present system can identify such belated disclosure. Is it worth the efforts?

ITC in respect of Goods in Transit – may appear in GSTR‐2A in previous month and in3B in next month on receipt of goods.

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NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers NN 49/2019‐CT dt. 9th Oct 2019 – Brain Teasers

Whether Provisional Credit needs to reverse with interest if not appearing insubsequent GSTR‐2A?

What if credit reversed and re availed due to non payment within 180 days ?

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NN 49/2019‐CT dt. 9th Oct 2019 – Restrictions on availing ITC NN 49/2019‐CT dt. 9th Oct 2019 – Restrictions on availing ITC

Steps to be followed, if RTP desires to comply

a) Ascertain forward charge ITC as per books

b) Ascertain reverse charge ITC as per books

c) Ascertain ITC appearing as per GSTR‐2A

d) Remove ineligible ITC from 2A

e) Ascertain eligible ITC appearing as per GSTR‐2A (c‐d)

f) If (e) > (a) – New Rule does not apply

g) If (e) < (a) – Credit to be claimed in 4A(5) of 3B ie Any other ITC = (e) + 20% of (e)

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Highlights of Major Changes

Glimpse of New GST Returns

Slide No. 32

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New Returns in lieu of GSTR 1 & 3BNew Returns in lieu of GSTR 1 & 3B

Slide 33

IANX 2

RET 1

IANX !

ANX 1

ANX‐1A

RET‐1A

PMT‐08

Sort of GSTR‐1

Sort of GSTR‐2

Sort of GSTR‐3

Not for GSTR‐4, 5,6

etc

Postponed to 1st

April 2019

Other functionalities

Jignesh Kansara

Return Periodicity (RET 1)Return Periodicity (RET 1)

Returns

Big Tax Payer

Previous Year TO > 5CR

Monthly (Normal)

RET‐1

Small Tax Payer

Previous Year TO <= 5 CR

Monthly (Normal)

Quarterly

Sahaj –RET‐2

Sugam RET‐3

Quarterly (Normal)

RET‐1

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OR OR

OR

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Time Lines of New GST ReturnsTime Lines of New GST Returns

For Monthly Filers

ANX 1ANX 1

ANX 2ANX 2

RET 1RET 1

10th of Subsequent month



For Quarterly Filers • RET‐1 Quarterly : 25th of day of Subsequent Quarter• RET‐2 Sahaj : 25th of day of Subsequent Quarter• RET‐3 Sugam : 25th of day of Subsequent Quarter• For Quarterly filers Monthly Payment in PMT‐08

Jignesh Kansara

Important Points – GST ANX 1Important Points – GST ANX 1

• Documents flow to be uni‐directional. Only Vendors can make amendment.

• Recipient will have only 3 options, Accept, Reject, Pending. Recipient can’tmodify.

• For Small Tax payers (Turnover up to 5 Crore) HSN reporting is not mandatory.For others including exporters at least 6‐digit HSN to be reported for goods andservices.

• B2B Invoice to be uploaded HSN wise. If a invoice has 10 different items having6 HSN, 6 line items to be reported.

• If a B2B invoice has 10 different items having 6 HSN and 1 HSN has 2 differentGST rates (e.g. Readymade garments), 7 line items to be reported.

• B2C Invoices HSN Reporting not required

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• RCM details to be reported in ANX‐1 by 10th of subsequent month

• Tax amount shall be computed by the system (PORTAL) based on the taxablevalue and tax rate. However cess will be reported by the taxpayer himself.

• Place of supply shall have to be reportedmandatorily for all supplies

• Tax rate applicable on IGST supplies to selected from the drop down menu forall Supplies (Intra + Inter). Cess, if applicable, shall be reported under the cesscolumn

• PAN may be reported in Table 3H if supplies attracting reverse charge arereceived from un‐registered persons not having GSTIN

• Negative values are allowed in ANX‐ 1. Omitted Supply of earlier period can be added

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• Tax payer can upload the details of invoices in ANX‐1 on real‐time basis.

• Tax payer (Recipient) can also view details of documents uploaded by suppliers on near real time basis.

• Advances received on account of supply of services shall not be reported in GSTANX‐1., to be reported in table 3C(4) of FORM GST RET‐1.

• Supplies attracting reverse charge will be reported only by the recipient and not by the supplier in this annexure

• Broad Contents of ANX‐1

Details of Outward Supplies (Except Advances)

Details of Supply on which RCM liability arise

Details of Import to Goods and Services.

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Important Points – Return Frequency & PaymentImportant Points – Return Frequency & Payment

• Filing frequency of New return system will be monthly for all GST payers unless GST payers opt for quarterly GST returns (Based on Turnover criteria). Periodicity can be changed only once that too at the beginning.

• GST payment will be ‘monthly’ for every GST payer (including Quarterly filers). Other than Large tax payer will use PMT‐08 for monthly payment.

• Large Tax payer will have to file GST ANX‐1 and GST ANX‐2 on monthly basis.

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Important Points – ITC

• If Vendor has not uploaded Invoice, Provisional ITC can be claimed, howeverdepartment is likely to put some restrictions on % of provisional ITC that can beclaimed. Section 43A provisional ITC can’t exceed 20% of confirmed credits.

• Provisional ITC on missing Invoice (Subject to restriction) can be claimed by Taxpayer opting to file RET 1 (Monthly or Quarterly) however, Sahaj and Sugamfilers cannot avail ITC on missing invoices.

• In respect of Provisional ITC, Vendor should report missing ITC in T+2 (In next 2months), if vendor is monthly filer. If vendor is quarterly filer, vendor shouldreport missing ITC in T+1 (Next Quarter). If not reported recipient to add backsuch provisional ITC in ANX 1 , table 3L and pay with interest

• ITC to be credited only to Electronic credit ledger on filing of ANX 2 includingDeemed filing.

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Credit Mechanism in New Return

• Recipient will get credit during a tax period on the basis of the details ofdocuments uploaded by the supplier up to the 10th of the month following themonth for which the return is being filed for.

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ITC in

New

form

sRecipient Monthly Filer

Docs uploaded by supplier up to 10th of Next month

For rest. Provisional Credit

(Not for Sahaj & Sugam)

Recipient Quarterly Filer

Docs uploaded by supplier up to 10th of Next Quarter

For rest provisional credit

(Not for Sahaj & Sugam)

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Who can file Sahaj?

• Tax payer opted to file Sahaj is allowed to declare outward supply under B2C categoryand inward supplies attracting reverse charge only

• Can’t make supply through e‐commerce (TCS – Section 52)

• No Credit on Missing Invoice.

• Can make Nil rated, exempted or Non‐GST supplies

• Can’t make any other type of inward or outward supplies

• Nil rated, exempted or Non‐GST supplies need not be declared in Sahaj.

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Who can file Sugam?

• Tax payer opted to file Sugam is allowed to declare outward supply under B2B & B2Ccategory and inward supplies attracting reverse charge only

• Can’t make supply through e‐commerce (TCS – Section 52)

• No Credit on Missing Invoice

• Can make Nil rated, exempted or Non‐GST supplies

• Can’t make any other type of inward or outward supplies

• Nil rated, exempted or Non‐GST supplies need not be declared in Sahaj.

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Who can File Normal Return?

• Residue Category

• Periodicity Quarterly for small tax payer

• For Big Tax payer, monthly

• Can declare all types of outward supplies, inward supplies

• Credit Can be taken on missing invoices Subject to Restrictions, Reversal and Interest

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Switch over Normal / Sahaj / Sugam

• Newly registered taxpayers will also have the option to file monthly, Sahaj, Sugam orQuarterly (Normal) return.

• Change in periodicity of the return filing ‐ allowed only once at the time of filing the firstreturn by a taxpayer

• The periodicity of next FY will remain unchanged unless changed before filing the firstreturn of that year

• Quarterly Return filer can choose between– Sahaj, Sugam or Quarterly (Normal).

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• Quarterly filer

Switchover

• Sugam

• Sahaj

Switchover• Sahaj

Once a year

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Switch over Normal / Sahaj / Sugam

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• Sahaj

Switchover

• Sugam

• Quarterly Normal

Switchover• Quarterly Normal

More than once

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What if filing of ANX‐1 is delayed?

47

• Details will be reflected in ANX-2of Recipient in next month.

• Recipient will have to claimprovisional credit (Not possible inSugam and Sahaj)

• Adjustment to be made nextmonth by recipient when credit isreflected.

• See Separate slides for hassles ofprovisional credit.

Jignesh Kansara

FORM GSTR‐1 Vs ANX‐1FORM GSTR‐1 Vs ANX‐1

• Major area of difference

Advance & Adjustment details tobe disclosed

Inward supplies attractingreverse charge/ Import of

services/ goods/from SEZ etc. notto be disclosed here but in GSTR‐3B

Document details & HSNrequired

B2CL/B2CS bifurcation

GSTR‐1

Advance & Adjustment detailsnot to be disclosed here but inRET‐1

Inward supplies attractingreverse charge, Import ofservices/ goods/from SEZ tobe disclosed

Document details not required.HSN part of main Tables

B2CL /B2CS bifurcation doneaway with

ANX ‐1

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FORM GSTR‐1 Vs ANX‐1FORM GSTR‐1 Vs ANX‐1

• Major area of difference

Separate table for B2B Debit / Credit Note / Amendments

Nil rated, exempted, No supply and non GST outward supplies to be disclosed in GSTR‐1

Supplies made through e‐commerce operator attractingTCS to be reported only once

GSTR‐1

No Separate table for B2BDebit / Credit Note/Amendment, same table inwhich original supply to bereported

Nil rated, exempted, No supplyand non GST outward suppliesto be disclosed in RET‐1

Supplies made through ECOattracting TCS to be reportedonly in 2 tables (Respectivetable + Table4)

ANX ‐1

Jignesh Kansara

ANX 2 –Imp Points

• Details of auto‐ drafted inward supplies

• Source : GST ANX ‐1, GSTR‐5 & GSTR‐6

• will be auto‐populated in this annexure on near real time basis and can be accepted or rejected by the recipient

• Recipient can Accept, Reject or to keep pending on continuous basis

• Accepts implies that supplies reported in such document have been received before filing of return by the recipient and the details given in the documents reported in FORM GST ANX‐1 are correct.

• Accepted documents would not be available for amendment at thecorresponding supplier’s end.

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ANX 2 –Imp Points

• Any invoice with an error that cannot be corrected through a financial debit / credit note shall be rejected. E.g. details such as HSN Code, tax rate, value, GSTIN of recipient etc.

• Supplier can make corrections in the rejected documents in subsequent FORM GST ANX‐1

• Pending action will mean that the recipient has deferred the decision ofaccepting or rejecting the details of the invoices E.g. supplies are yet to bereceived or the recipient

• Pending invoices would be rolled over to FORM GST ANX‐2 of the next taxperiod.

• The input tax credit in respect of pending & rejected invoices shall not beaccounted in tax period.

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ANX 2 –Imp Points

• Any document, on which an affirmative action of either accepting the documentor keeping the document pending or rejecting the document is not taken by therecipient in his FORM GST ANX‐2, shall be deemed to be accepted upon filing ofthe return by him. On deemed acceptance input tax credit in respect of allInvoices shall be accounted.

• Separate functionality would be provided to search and reject an accepteddocument on which credit has already been availed. such reversal of credit forthe recipient will be with interest.

• FORM GST ANX‐2 will be treated as deemed filed upon filing of the mainreturn (FORM GST RET‐1) relating to the tax period.

• Status of return filing (not filed, filed) by the supplier will also be made known to the recipient in ANX‐2 of the tax period after the due date of return filing is over

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Accept / Reject / Pending – ANX 2

Details uploaded by supplier (irrespective of frequency & type)

Say May 2020

Up to 10th of following month in

which details uploaded

10th of June 2020

By 18th June 2020

Accept

Reject

Pending

Modification

Slide 53

Else deemed Acceptance

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Invoice Rejection by Recipient

Slide 54

AA

BB

CC

DD

Will be conveyed to the supplier only after filing of the return by the recipient

Supplier can edit before filing subsequent Return

Credit will appear only in next open GST ANX‐2

Liability of the period in which uploaded

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RET‐1 – Imp Points

• Nil return can be filed if RTP has not uploaded FORM GST ANX‐1 and no inwardsupplies (purchases) have been auto‐populated in FORM GST ANX‐2 and noother information is required to be reported in the main return i.e. FORM GSTRET‐1.

• Facility to file Nil return through SMS will also be available if no supplies havebeen made or received

• After uploading details of supplies in FORM GST ANX‐1 and taking action on the documents auto‐populated in FORM GST ANX‐2 (Even Deemed Filing), the taxpayer shall file the main return in FORM GST RET‐1

• Information declared through FORM GST ANX‐1 and FORM GST ANX‐2 shall be auto‐populated in the main return (FORM GST RET – 1).

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RET‐1 – Imp Points

• Interest and late fee to the extent of late filing of return, making late paymentof taxes, uploading preceding tax periods’ invoices shall be computed by thesystem

• Other interest due to reversals etc. shall be entered by the taxpayer on self‐assessment basis

• Suggested utilisation of ITC will be made available in the payment table.However, taxpayer can make changes in the suggested ITC utilization

• Adjustment of negative liability of the previous tax period shall be allowed to bemade along with the current tax period’s liability

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What if Return (RET 1/2/3 is not filed) two consecutive months?

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Fraud

• The documents uploaded in FORM GST ANX‐1 for month ‘M’ by a supplier (June 2020)

• Previous two consecutive tax periods (M‐1 and M‐2 months) RET‐1 not filed. (April and May 2020)

No ITC

• Such Invoices will be visible to the recipient in ANX‐2

• However Recipient cannot claim ITC on such inward supplies for June 2020

Till

• Recipient can reject or keep such documents pending until filing of return by the supplier

• For Supplier filing return on quarterly basis, this period will be one quarter instead of 2 months.

• Grace period : Monthly filer ‐2 months. Quarterly filer – 1 Quarter

Jignesh Kansara

Rigmarole/Hassles of Provisional credits

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Provisional Credits

Claim credit in RET1 4A.10

If shown by supplier subsequently

Reverse in 4B.2

(No Interest impact)

If Not shown by Supplier. Who is monthly filer

Reverse ITC with Interest if not reported in next 2 month ANX 1 Table 3L

If Not shown by Supplier. Who is Quarterly filer

Reverse ITC with Interest if not reported in next

Quarter ANX 1 Table 3L

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ANX‐1A – Important Points

• ANX‐1A : to Amend originally filed ANX‐1

• Missing documents of prior period(s) shall not be reported in thisannexure but can be reported in FORM GST ANX‐1 itself.

• The amendment to FORM GST ANX‐1 can be filed as many times asprovided in the Act read with the rules made thereunder

• Filing process will be similar to the process of filing of the originalFORM GST ANX‐1. The annexure will be deemed to have been filedupon filing of return in FORM GST RET‐1A.

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ANX‐1A – Important Points

• RTP opting to file amendment will also have to file Amended Return (RET‐1A) to give effect of such amendment.

• Providing original document details will be mandatory foramending the same except in case of B2C supplies in table 3A, table3H and table 3I of FORM GST ANX‐1.

• The invoices /documents on which refund has already been claimed by the supplier/recipient shall not be open for amendment

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FORM GST ANX‐1A vs ANX‐1FORM GST ANX‐1A vs ANX‐1

ANX‐1A to amendment to details of previously filed GST ANX‐1

Amendment of invoice, debit /credit notes shall be carried outthrough ANX‐1 A in relation totable• 3A(B2C),• 3C (Export with Tax),• 3D (Export without payment

of tax) ,• 3H (RCM),• 3I (Import of Services),• 3J (Import of Goods) and• 3K (SEZ Import)of FORM GST ANX‐1. [GSTIN ofsupplier not available]

ANX‐1A (Amendment)

Amendment in relation to table• 3B (B2B),• 3E (SEZ Supply with tax),• 3F (SEZ Supply without tax)

and 3G (Deemed Export)shall be carried out in FORMGST ANX‐1 of the main return(FORM GST RET‐1) itself.[GSTIN of supplier available]

ANX ‐1 (Main Annexure)

Jignesh Kansara

FORM GST RET‐1A

• Amendment to Monthly / Quarterly (Normal) Return

• Entries made by the taxpayer in the main return (FORM GST RET‐1) which were not auto‐populated shall be editable in this return.

• Payment can be made if liability arises due to filing of amendment return.

• If Excess payment / credit situation arise (liability becomesnegative), the negative liability will be carried forward to the mainreturn (FORM GST RET – 1) of next tax period where adjustmentcan be made.

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FORM GST RET‐1A

When to file RET‐1A?

• If Changes are made in ANX‐1 by way of ANX‐1A

• If RTP want to edit user input fields (Non Auto Populated fields)

When not to file RET‐1A?

• If RTP want to edit Auto Populated fields of RET‐1

• Amendment in ITC (upward or downward) – to be reported in RET‐1itself.

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FORM GST PMT‐08 – Mini Return Payment Challan

• Taxpayers opting to file the return on quarterly basis have to make payment on monthly basis on the supplies made during the month

• Simple form like 3B. Payment cum Challan. Declare value of Outward Supply, ITC

• Payment can be in cash as well as Credit.

• Payment of self‐assessed liabilities shall be made for the first two months of the quarter. Simply disclose Liability to pay tax on forward charge, reverse charge ,and eligible ITC. Pay difference, if any

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THANKS !

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You can find me at

Jignesh KansaraCharteredAccountantsB-1208, Wall Street , ChakalaJunction, Near Holy Family Church, Andheri East, Mumbai 93Cell:+919987199329Email:[email protected]:www.jkaca.in