BRIEF ANALYSIS OF NOTIFICATIONS ISSUED ON 3RD APRIL 2020

INTEREST ON DELAY PAYMENT OF TAX PERIOD FOR FEBRUARY, MARCH, APRIL 2020

Notification No- 31/2020 dated 03.04.2020

TABLE

Sl. No. Class of registered persons Rate of interest Tax period Condition
(1) (2) (3) (4) (5)
1. Taxpayers having an aggregate turnover of more than rupees 5 crores in the preceding financial year Nil for first 15 days from the due date, and 9 per cent thereafter February, 2020, March 2020, April, 2020 If return in FORM GSTR-3B is furnished on or before the 24th day of June, 2020
2 Taxpayers having an aggregate turnover of more than rupees 1.5 crores and up to rupees five crores in the preceding financial year Nil February, 2020, March, 2020 If return in FORM GSTR-3B is furnished on or before the 29th day of June, 2020
April, 2020 If return in FORM GSTR-3B is furnished on or before the 30th day of June, 2020
3. Taxpayers having an aggregate turnover of up to rupees 1.5 crores in the preceding financial year Nil February, 2020 If return in FORM GSTR-3B is furnished on or before the 30th day of June, 2020
March, 2020 If return in FORM GSTR-3B is furnished on or before the 3rd day of July, 2020
April, 2020 If return in FORM GSTR-3B is furnished on or before the 6th day of July, 2020.”.

Our Comments:

Turnover above Rs. 5 Crore

Month Time Limit without Interest Time Limit with Interest @ 9% Interest Rate @ 18%
February 2020 4th April 24.06.2020 Returns filed after 24.06.2020
March 2020 5th May 24.06.2020 Returns filed after 24.06.2020
April 2020 4th June 24.06.2020 Returns filed after 24.06.2020

LATE FEES ON FILING OF GSTR 3B

Notification No- 32/2020 dated 03.04.2020

No Late Fees shall be charged for February 2020, April 2020 and May 2020 provided the conditions as set forth has been complied

Sl. No. Class of registered persons Tax period Condition
(1) (2) (3) (4)
1. Taxpayers having an aggregate turnover of more than rupees 5 crores in the preceding financial year February, 2020, March, 2020 and April, 2020 If return in FORM GSTR-3B is furnished on or before the 24th day of June, 2020
2. Taxpayers having an aggregate turnover of more than rupees 1.5 crores and up to rupees five crores in the preceding financial year February, 2020 and March, 2020 If return in FORM GSTR-3B is furnished on or before the 29th day of June, 2020
April, 2020 If return in FORM GSTR-3B is furnished on or before the 30th day of June, 2020
3. Taxpayers having an aggregate turnover of up to rupees 1.5 crores in the preceding financial year February, 2020 If return in FORM GSTR-3B is furnished on or before the 30th day of June, 2020
March, 2020 If return in FORM GSTR-3B is furnished on or before the 3rd day of July, 2020
April, 2020 If return in FORM GSTR-3B is furnished on or before the 6th day of July, 2020.”.

DUE DATE OF FILING OF GSTR 3B FOR MAY 2020

Notification No- 36/2020 dated 03.04.2020

Turnover Limit States Due Date
More than Rs. 5 Crore All States 27.06.2020
Less Than Rs. 5 Crore Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands or Lakshadweep 12.07.2020
Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha, the Union territories of Jammu and Kashmir, Ladakh, Chandigarh or Delhi 14.07.2020

LATE FEES ON FILING OF GSTR 1

Notification No- 33/2020 dated 03.04.2020

No Late Fees on filing of GSTR 1 shall be charged for March 2020, April 2020 and May 2020 and for the quarter ending 31st March 2020 provided return in Form GSTR 1 has been furnished on or before 30.06.2020

LATE FEES ON FILING OF GSTR 4 AND CMP-08

Notification No- 34/2020 dated 03.04.2020

persons shall furnish a statement, containing the details of payment of self-assessed tax in FORM GST CMP-08 of the Central Goods and Services Tax Rules, 2017, for the quarter ending 31st March, 2020, till the 7th day of July, 2020

persons shall furnish the return in FORM GSTR-4 of the Central Goods and Services Tax Rules, 2017, for the financial year ending 31st March, 2020, till the 15th day of July, 2020

NEW APPLICATION FOR COMPOSITION SCHEME FOR FY 2020-21

Notification No- 30/2020 dated 03.04.2020

Person who opts to pay to tax under composite scheme may make application on or before 30.06.2020

Further such person shall file the declaration in ITC-03 on or before 31.07.2020

GENERAL EXTENSION OF TIME LIMIT FOR COMPLIANCE SUBJECT TO CONDITIONS

Notification No- 35/2020 dated 03.04.2020

Any time limit for completion or compliance of any action, by any authority or by any person, has been specified in, or prescribed or notified under the said Act, which falls during the period from the 20th day of March, 2020 to the 29th day of June, 2020, and where completion or compliance of such action has not been made within such time, then, the time limit for completion or compliance of such action, shall be extended up to the 30th day of June, 2020

(a) completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, by whatever name called, under the provisions of the Acts stated above; or

(b) filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called, under the provisions of the Acts stated above;

However above extensions shall not be applicable for

Compliance Provisions  
Section 10(3) Lapse of Composition Scheme on Exceeding the Turnover of specified limit
Section 25 Registration
Section 27 Registration of Casual and Non Resident Taxable Person
Section 31 Issue of Invoice
Section 37 Filing of GSTR 1
Section 47 Levy of Late Fees
Section 50 Payment of Interest
Section 69 Power to Arrest
Section 90 Liability of Partners of Firm to Pay Tax
Section 122 Imposition of Penalty
Section 129 Detention, Seizure and Release of Goods/ conveyances in Transit
Except Section 39(4), (3), (5) Filing of GSTR 6, 7, 8, 3B
Section 68 Inspection of Goods in Movement

E-way bill has been generated under rule 138 of the Central Goods and Services Tax Rules, 2017 and its period of validity expires during the period 20th day of March, 2020 to 15th day of April, 2020, the validity period of such e-way bill shall be deemed to have been extended till the 30th day of April, 2020.

CONDITIONS FOR INPUT TAX CREDIT

Notification No- 30/2020 dated 03.04.2020

The conditions prescribed in Rule 36(4) of CGST Rules 2017 for the availment of the credit of Input Tax restricting the credit upto 110% of the Invoices uploaded by the supplier has been relaxed for the tax period February, March, April, May, June, July and August, 2020.

The condition for availing the credit shall apply cumulatively instead of month to month basis

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One Comment

  1. CA Bhushan says:

    a very well presented article and it has actually simplified and presented the summary of all the relevant gst notifications very effectively! Thank u and keep sharing!!

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