Your aggregate turnover for the financial year 2019-20 has been computed by GST system based on the returns filed in Form GSTR-3B by all registrations on the common PAN. The same has been found to be more than Rs. 5 Cr where returns of FY 2019-20 filed upto 25th July, 2020 have been considered for the said computation.

Your attention is drawn to definition of ‘Aggregate turnover’, defined under clause 6 of section 2 of the CGST Act, 2017. Accordingly, following methodology to compute aggregate turnover has been adopted

(a) Turnover declared in Table 3.1(a), 3.1(b), 3.1(c) and 3.1(e) of GSTR-3B has been accounted for the computation.

(b) If the return of a tax period which was due to be filed but has not been filed for any of the GSTINs registered on the common PAN, the turnover of that period has been estimated by way of extrapolation as under:

[(Turnover declared/ No. of GSTR-3B filed) * No. GSTR-3B liable to be filed].

(c) The turnover (including extrapolated turnover) of GSTINs has been summed up at PAN level.

Further, it is brought to your notice that the above turnover will be used for certain validations in the System such as determining due date of return filing, computation of late fee by the system. You can also use the same for reporting interest on delayed payments based on self-assessment basis.

If any discrepancy is found in the turnover data based on the computation, as explained above and the actual turnover, the taxpayer may file a grievance at https://selfservice.gstsystem.in for redressal.  The taxpayers are advised to upload the information while raising complaint in following format, which will enable our team to resolve the same:

Comments:

This seems to be a mass communication from the GST portal to taxpayers, not specifically seeking any information/ docs-may not require any action from your side now if no discrepancies

Suggested to reply only when there is any specific communication/notice or seeking any information

(i) if received from Central officers – The DIN would be required to be mentioned mandatory for search authorization, summons, arrest memo, inspection notices and letters issued in the course of any enquiry. This would enable the assessee to check the correctness of authority. – Where it is not mentioned then it would deemed such communication was never issued to the taxpayer – ref Circular 122/41/2019-GST dt. 05th November 2019

DIN could be verified on the website https://www.cbicddm.gov.in/MIS/Home/DINSearch

(ii) if issued by State officers – DIN is not applicable – Then in such case, if specific notices issued then it is always suggested to reply to notice through RPAD along with acknowledgment.

The above aggregate turnover will be used for determining the due date of return filing, computation of late fees for system validations by the GSTN for the preceding FY 2019-20 as it the taxpayers are segregated between large and small taxpayers on basis of turnover more than 5 crs of preceding FY

The turnover would be taken from the system from the following table

3.1 (a) Outward taxable supplies (other than zero rated, nil rated and exempted) – Local sales, Inter state sales, deemed export sales, deemed supply such employee recoveries etc

3.1 (b) Outward taxable supplies (zero rated ) – Export of goods & services and Supplies to SEZ [only when for Authorised operations]

3.1 (c) Other outward supplies (Nil rated, exempted)

3.1 (e) Non-GST outward supplies

The GST Portal would calculate aggregate turnover based on the above formula where returns are not filed and the department may send the notice for estimation of interest for delayed payment of taxes

Illustration:

If the client has filed GST returns for period April 2019 to December 2019 up to 25.07.2020 with a turnover of 4.5 crs cumulatively and thereafter have not filed returns

Then System would calculate aggregate turnover based on a formula as

[(Turnover declared/ No. of GSTR-3B filed) * No. GSTR-3B liable to be filed].

4.5crs * 12 GSTR-3Bs to be filed in FY = 6crs

9 GSTR-3Bs filed [April to December 2019]

Therefore Aggregate turnover would be 6crs for purpose of due dates, interest, etc.

Where the client does not agree with the calculation of aggregate turnover by the GSTN, then the client may lodge a grievance at the link given above and are advised to upload the PAN-wise information in the above format which will enable the GSTN to resolve the issue.

Note:

1. Where the client turnover is more than 5 crs then it would not be required to take any action – This would only impact the client whos turnover are expected to cross a turnover of 5crs.

2. The above communication would not impact where the client have filed all GSTR-3Bs for FY 2019-20 and is filing returns regularly within due date.

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