The Hon’ble Finance Minister of India today announced several relief measures on statutory and regulatory compliance matters to mitigate large-scale economic distress caused by COVID 19 across the globe. In majority of the cases, the due dates falling in March 2020 have been extended till 30th June 2020. Key highlights for each compliance are summarized below:
I. Income tax
| Particulars | Existing | Revised |
| Due date to file ITR for F.Y. 2018-19 | 31st March 2020 | 30th June 2020 |
| Due date for Aadhaar-PAN linking | 31st March 2020 | 30th June 2020 |
| Vivad se Vishwas scheme | No additional 10% amount, if payment made by June 30, 2020 | |
| Investment by Taxpayers to avail tax benefits for F.Y. 2019-20 | 31st March 2020 | 30th June 2020 |
| Interest on delayed payment of advanced tax, self-assessment tax, regular tax, TDS, TCS, equalization levy, STT, CTT made between 20th March 2020 and 30th June 2020 | 12 %/18 % per annum
( i.e. 0.75% per month instead of 1/1.5 percent per month) |
9% per annum
(Reduction in interest upto 50%) |
| Due dates for various filings * | Falling between 20th March 2020 to 29th June 2020 | 30th June 2020 |
(*) Filings include issue of notice, intimation, notification, approval order, sanction order, filing of appeal, furnishing of return, statements, applications, reports, any other documents and time limit for completion of proceedings by the authority and any compliance by the taxpayer including investment in saving instruments or investments for roll over benefit of capital gains under Income Tax Act, Wealth Tax Act, Prohibition of Benami Property Transaction Act, Black Money Act, STT law, CTT Law, Equalization Levy law, Vivad Se Vishwas law
II. Indirect tax/GST
A. Taxpayers having aggregate annual turnover less than Rs. 5 Crore
| Month | Due date for GSTR-3B | Interest | Late fee | Penalty |
| February 2020 | Existing due date falling on 20th/22nd/24th of next month extended till last week of June 2020 | Waived | Waived | Waived |
| March 2020 | ||||
| April 2020 |
B. Taxpayers having aggregate annual turnover equal to more than Rs. 5 Crore
The GSTR-3B for the period February 2020, March 2020 and April 2020 can be filed by last week of June 2020 subject to payment of interest beyond 15 days from current due dates @reduced rate of 18% p.a. The different timelines are explained below:
| Particulars | February 2020 | March 2020 | April 2020 |
| Existing due date GSTR-3B | 20th March 2020 | 20th April 2020 | 20th May 2020 |
| Revised due date-GSTR-3B without Interest | Within 15 days from existing due date i.e. 4th April 2020 | Within 15 days from existing due date i.e. 5th May 2020 | Within 15 days from existing due date i.e. 4th June 2020 |
| Revised due date-GSTR-3B with Interest @9% p.a. | 30th June 2020 | 30th June 2020 | 30th June 2020 |
| Late fee | No late fee if GSTR-3B filed till 30th June 2020 | ||
| Penalty | No penalty if GSTR-3B filed till 30th June 2020 | ||
C. GST returns for Composition Taxpayers
| Particulars | Existing | Revised |
| Date for opting for composition scheme for F.Y. 2020-21 | 31st March 2020 | By last week of June 2020
|
| Due date for making GST payment for quarter ending March 2020 in Form CMP-08 | 18th April 2020 | By last week of June 2020 |
| Filing of Annual Return GSTR-4 for F.Y. 2019-20 | 30th April 2020 | By last week of June 2020 |
D. Sabka Vishwas Scheme
| Particulars | Existing | Revised |
| Due date of payment under Sabka Vishwas Scheme | Within 30 days from date of issue of SVLDRS-03 | 30th June 2020 (without any interest) |
E. Others
| Particulars | Existing | Revised |
| Due dates for various filings * | Falling between 20th March 2020 to 29th June 2020 | 30th June 2020 |
(*) Filings include issue of notice, notification, approval order, sanction order, filing of appeal, furnishing of return, statements, applications, reports, any other documents, time limit for any compliance under the GST laws
F. Customs
- 24X7 Custom clearance till end of 30th June, 2020
- Due date for issue of notice, notification, approval order, sanction order, filing of appeal, furnishing applications, reports, any other documents etc., time limit for any compliance under the Customs Act and other allied Laws where the time limit is expiring between 20th March 2020 to 29th June 2020 shall be extended to 30th June 2020
III. MCA-Corporate affairs
| Particulars | Existing | Revised |
| Filing of any document, return, statement etc., required to be filed in the MCA-21 Registry by Companies/LLPs, irrespective of its due date during 01st April to 30th September 2020 | Substantial additional fee is charged for delay in non-compliances | Waiver of additional fees |
| Holding quarterly board meetings | In every 120 days i.e. a quarter | Shall be extended by a further period of 60 days |
| Applicability of Companies (Auditor’s Report) Order, 2020 | Applicable from F.Y. 2019-20 | Now applicable from F.Y 2020-2021 |
| Declaration for Commencement of Business | Within 6 months of date of incorporation | An additional time of 6 more months shall be allowed |
| Threshold of default under section 4 of the IBC 2016 | INR 1 lac | INR 1 crore |
IV. Financial Services
Relaxations for 3 months
- Debit cardholders to withdraw cash for free from any other banks’ ATM for 3 months
- Waiver of minimum balance fee
- Reduced bank charges for digital trade transactions for all trade finance consumers
V. Department of Commerce
- Extension of timelines for various compliance and procedures will be given. Detailed notifications will be issued by Ministry of Commerce.
(CA Nikhil M. Jhanwar)
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