12 Thing to do/remember before GST Return Filing for March 2019 includes not to delay filing of  GSTR 1 or GSTR 3B pertaining to March 2019, Avail all Input Tax credit (ITC) for invoices pertaining to FY 17-18, Raise All Debit Notes pertaining to invoices of FY 17-18 & Inform the Counter party, Avail all ITC in Input Service Distributor (ISD) Registration, Avail all ITC in Input Service Distributor (ISD) Registration, Application for ‘Letter of Undertaking’ (LUT) etc.

TO DO Departments Concerned
Sl. No. Particulars
1. DO NOT DELAY GSTR 1 or GSTR 3B pertaining to March 2019 –

If amendment in invoices for 17-18 is not done up to 11th April 2019 as the GSTR 1 for March 2019 is not filed by the said due date, the assessee will not be able to amend the details in future.

If ITC of invoices of 17-18 is not availed by 20th April 2019 as GSTR 3B for March 2019 is not filed by the due date, the revenue authorities may dispute the ITC in future.

Finance/ Taxation
2. AVAIL all Input Tax credit (ITC) for invoices pertaining to FY 17-18 –

ITC for invoices/debit notes for FY 2017-18 which was not availed earlier should be availed by 31st March 2019, for which return in GSTR 3B is to be filed upto 20th April 2019. Following needs to be done –

1. Reconciliation of Purchase register with GSTR 2A.

2. Ledger Scrutiny for all expenses where ITC may have been missed.

If not availed upto 20.04.2019 then the same shall LAPSE.

Finance/ Taxation
3. Whether to AVAIL ITC not reflected in GSTR 2A but for which dealer has the invoice/ Dr Note?

There might be various reasons for an amount not appearing in GSTR 2A. Hence incase a dealer has the invoice and other conditions as per Sec 16(2) of The CGST Act 2017 have been complied with, such substantial claim of ITC cannot be denied merely on the basis of non-appearance in GSTR 2A. Hence, dealers must avail such ITC.

However the fact of missing transaction in GSTR 2A must be communicated to the supplier with clause for suitable steps which might be taken incase of litigation.

Finance/ Taxation

Purchase/ Procurement

4. Raise All Debit Notes pertaining to invoices of FY 17-18  & Inform the Counter party

Al Dr Notes under GST  pertaining to invoices of FY 17-18 must be raised before 31st March 2019. The Counter Party must mandatorily be informed so that he takes the ITC of the GST amount in his GSTR 3B of March 2019.

It is pertinent to note that while such Dr Notes  u/s 34 may still be raised at a later period, yet as per Sec 16(4), The ITC for the same cannot be availed by the counter party.

Finance/ Taxation
5. Amendment/addition for outward supply invoices and debit/credit issued in FY 2017-18

Amendment/addition for outward supply invoices and debit/credit issued in FY 2017-18 should be done by 31st March 2019 and reflected in GSTR 1 by 11.04.2019.

If the GSTR 1 for March 2019 is not filed by the said due date AND amendment is not done up to 11th April 2019, assessee will not be able to amend the details in future.

Finance/ Taxation
6. Avail all ITC in Input Service Distributor (ISD) Registration:

ISD should avail the ITC for FY 2017-18, not availed earlier, upto 31st March 2019. If not availed in the return filed by 13th April 2019, then the same shall Lapse.

Also, all the ITC availed by ISD should be distributed in the month of March 2019.

Finance/ Taxation
7. Reversal of ITC pertaining to exempted supplies or for non-business use: (Rule 42)

Reversal done in monthly GST returns to be compared with reversal for the entire year. Any shortfall should be reversed in March 2019 itself.

Sales & Marketing
8. Documentation series:

Series of documents issued should be unique for each financial year. Hence all GST documents like Invoice, Dr/Cr notes, Delivery Challans, Self Invoices, receipt vouchers, etc should be issued under new series from 1st April 2019.

It is pertinent to note that  particular document (say invoice) may have ‘n’ no: of series’

Finance & Taxation
9. Application for “Letter of Undertaking” (LUT):

Assessee is required to apply for LUT prior to making exports. Hence, LUT for FY 2019-20 should be applied online before 31st March 2019.

Finance & Taxation
10. Goods In Transit as on 31st March 2019:

Some goods may be in Transit as on 31st March 2019. In such case while the Supplier will show the supply in his GSTR 1 for March 2019, the Customer shall avail the ITC only in April 2019, i.e. FY 2019-20. The same will show as a reconciliation item in GSTR 9.

Purchase/ Procurement

Finance & Taxation

11. Can Invoices be made on or before 31st March 2019 even if delivery is known to happen on 1st April or thereafter?

As per Sec 31 of The CGST Act 2017, Invoices may be made before supply. Hence, even if delivery is known to happen on 1st April or thereafter, Invoices may be made on or before 31st March 2019.

Sales & Marketing

Finance & Taxation

12. Goods received by The Transporter on 31st March 2019 or before but delivery made to the consignee on or after 1st April 2019. When should the Purchase be booked and ITC availed?

Purchase should be booked only on RECEIPT of the materials by the consignee or person acting on behalf, i.e. on or after 1st April 2019

Purchase/ Procurement

Finance & Taxation

Author Bio

Qualification: LL.B / Advocate
Company: Tax Connect Advisory Services LLP
Location: MUMBAI, Maharashtra, IN
Member Since: 10 Jan 2019 | Total Posts: 9
Mr. Vivek Jalan is a Fellow Member of the Institute Of Chartered Accountants of India (ICAI) & a qualified LL.B. He is the member of The CII- Economic Affairs & Taxation Committee. He is the Co Chairman of The Indirect Tax Committee of The Bengal Chamber of Commerce and Industry. He is also View Full Profile

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2 Comments

  1. CA Saurabh Joshi says:

    Excellent article, carefully written covering major burning issues & confusion. It reflects practical experience in dealing with the complex cases.

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