Filing tax returns on time is an important part of being GST-compliant.
Gstr – 1 – Details of outward supplies of taxable goods and/or services affected (That is your Sales )
Gstr -3B – Simple Return in which summary of outward supplies along with Input Tax Credit is declared and payment of tax is affected by taxpayer
GSTR -4 – Return for a taxpayer registered under the composition levy
GSTR-6 – Return for an Input Service Distributor
GSTR-7 – Return for authorities deducting tax at source.
GSTR-9 – Annual Return for a Normal Taxpayer
GSTR-9A – Annual Return for a Composition Taxpayer
Return by composition Dealer
Eligibility To Become Composition Dealer
Small traders, manufacturers and service providers can avail the composition scheme. 1% GST is leviable on turnover if the turnover of a taxpayer is up to Rs 1.5 crore. The value of turnover comes down to Rs 75 lakh for some States which comes under special category. 6% GST is leviable on turnover if the turnover of a service provider is up to Rs 50 lakh.
CMP 08 – A Move Widely Appreciated
CMP-08 is a statement cum challan which seeks information about outward supplies and inward supplies ( inward supplies under reverse charge) including the taxes paid on such outward supplies and imports along with interest payable. CMP-08 is a welcome move which was initiated in April 2019 so that it can be used from the financial year 2019-2020.
Easy Filing Procedure And Replacement of GSTR-4
CMP-08 has abridged and simplified the complete process of filing and replaced GSTR-4 which was initially mandatory to be filed every quarter.
GSTR 4 Revamped – To Be Filed Annually by 30th April
The GSTR 4 of the Central Goods and Services Tax Rules, 2017 has been revamped by the Central Board of Indirect Taxes and Customs (CBIC) and now the Composition dealers will be required to file it by 30th April for every financial year.
Another Annual Return For Composition Dealer
The GSTR 9A is another annual return that must be filed by the composition dealers once a year for an appropriate financial year. Form GSTR 9A can be used to reflect any additional tax liability which is not disclosed in Form GSTR 4.
Since the applicability of both the annual returns – GSTR-4 and GSTR-9A is incoherent, any one of them can be averted.
According to the notification, 18th July is the due date for filing quarter returns of the period from April to June by composition dealers.
The due dates for filing CMP-08 are in the wings but the API has not been updated on the GST portal till yet. So, the taxpayers are unable to file their CMP-08 which may lead to a necessity to extend thedue date for filing CMP-08(GSTR 4).
Update for Composition Dealers in 32nd GST Council Meeting:
1. The limit of the composition dealers has been increased to Rs. 1.5 Crore. This is applicable for 1st April 2019.
2. The composition rate for services sector has been fixed at 6 percent while the composition limit has been set at Rs 50 lakh.
3. The GSTR 4 return (Composition Dealers) will have to avail pay tax quarterly basis but the return will be filed only once a year.
NEW GST RETURN FROM 1/4/2020
As per the decision taken at the 37th GST Council Meeting, the new GST return system for all taxpayers and for all forms will be implemented from April 2020.
Upcoming GST Return
All the current GST returns which are in place i.e. GSTR 1, GSTR 2, GSTR 3 and GSTR 3B will no longer be in existence. In place of these, a taxable business will need to file one or few of the following returns / annexures / declarations:
- Monthly Returns – To be filled by taxpayers whose turnover is more than INR 5 Crores i.e. Large Taxpayers (excluding Composition Dealers, ISD, NRR, TDS and TCS)
- Quarterly Returns – To be filled by taxpayers whose turnover is less than INR 5 Crores i.e. Small Taxpayers
- Sahaj – For taxpayers making only B2C outward supplies
- Sugam – For taxpayers making both B2C and B2B outward supplies
- Quarterly Returns – For taxpayers making B2C, B2B and other supplies
- Outward Supplies Annexure
- Inward Supplies Annexure
- Payment Declarations
Monthly Returns
- Monthly filing along with the payment by 20th of the subsequent month
- Outward Supplies Annexure to be submitted before filing the monthly returns
- 24 / 7 upload of invoice during the month
- Invoice uploaded by the Supplier will be auto-populated in the form of Inward Supplies Annexure
- On the basis of Outward Supplies Annexure and Inward supplies Annexure, the details will be auto-populated in the monthly return
- Real time viewing facility of invoice uploaded by the supplier
- Concept of reporting missing invoices by the recipient within next 2 tax periods – to allow recipient to follow up and get the missing invoice uploaded from the supplier
- Provision to Lock, Reject and Mark the invoice as pending
- Profile based return format based on the type of supplies
Sahaj (B2C)
- Quarterly filing along with monthly payment by 20th of the subsequent month (1st and 2nd month of quarter) via Payment Declaration Form
- Outward Supplies details required at summary level – POS and Tax Rate-wise
- Invoice uploaded by the Supplier will be auto-populated in the form of Inward Supplies Annexure and ITC will be available on the same
- No concept of reporting missing invoices
- HSN Summary at 4 digit level to be declared in a separate table
Sugam (B2C + B2B)
- Quarterly filing along with monthly payment by 20th of the subsequent month (1st and 2nd month of quarter) via Payment Declaration Form
- Outward Supplies Annexure to be submitted before filing Sugam
- On the basis of Outward Supplies Annexure, outward supplies section in Sugam will be auto-populated
- 24 / 7 upload of B2B invoices during the quarter
- Supplies other than B2B and B2C cannot be made through Annexure
- Invoice uploaded by the Supplier will be auto-populated in the form of Inward Supplies Annexure and ITC will be available on the same
- No concept of reporting missing invoices
- HSN Summary at 4 digit level to be declared in a separate table
Quarterly Returns (B2C + B2B + Quarterly)
- Quarterly filing along with monthly payment by 20th of the subsequent month (1st and 2nd month of quarter) via Payment Declaration Form
- Outward Supplies Annexure to be submitted before filing Quarterly Returns
- On the basis of Outward Supplies Annexure, outward supplies section in Quarterly Returns will be auto-populated
- 24 / 7 upload of B2B invoices during the quarter
- Invoice uploaded by the Supplier will be auto-populated in the form of Inward Supplies Annexure and ITC will be available on the same
- No concept of pending invoices or reporting missing invoices
- No requirement to declare the following (which are required only for Annual Return) –
- Supplies having no liability such as non-GST supplies, exempt supplies etc.
- ITC on Capital Goods
GST Invoice Management Options
- Missing Invoice – Can be exercised by the recipient for invoices or debit notes which have not been uploaded by the supplier on which the recipient has availed input tax credit
- Pending Invoice – Can be exercised by the recipient for invoices uploaded by the supplier
- Reject Invoice – Can be exercised by the recipient for invoices which are filed by the supplier, but containing the wrong GSTIN
- Viewing Invoice – Invoices uploaded by the supplier will be visible to the recipient. The screen where it shall be visible to the recipient is called “viewing facility”. This is also called as Inward Supplies Annexure
- Locking Invoice – To indicate handshake between the recipient and the supplier. Acceptance of entering into the transaction reported in the invoice. Once the invoice is locked, the supplier will not be able to alter the invoice
- Deemed Locking of Invoice – Invoices which are uploaded by the supplier which are either not rejected or not kept pending by the recipient are deemed to be locked on filing of return
GST Return Amendment Options
- Amendment of GST Returns – 2 amendment returns allowed for each tax period
- Amendment of GST Invoices – Only when input tax credit has not been availed and the invoice has not been reported as locked by the recipient
- Amendment of Missing Invoices – Carried out through the amendment return of the relevant tax period to which the invoice pertains
ITC Recovery Options
- Invoice uploaded but return not filed – Recovery shall be first made from the supplier
- Missing Invoice not uploaded by supplier – Recipient should ensure that the supplier uploads invoice within two tax periods, else the ITC claimed will be reversed
- Final Recovery of ITC – In all exceptional circumstances like missing taxpayer, closure of business by the supplier etc. ITC will be recovered from the recipient
Things to Remember about New & Simplified GST Returns
- Introduction of different types of returns based on turnover and type of supplies made
- Single GST Return with the concept of Annexures
- Profile based returns format based on nature of supplies
- 24/7 upload of invoices into GST Portal
- Real-time viewing facility of invoices uploaded by the suppliers
- Amendment Returns concept introduced
- ITC allowed only on the invoice uploaded by the supplier
- No automatic reversal of ITC on missing Invoice – ratification period of 2 months available
- Filing of Nil Returns through SMS
- Return Filing Status of the supplier can be viewed by the recipient in the portal