What are the parameters and points which is required to consider before filing a GST return to reduce the chances of GST notice from the department?
An indicative list of parameters for GST scrutiny as per SOP provided by the GSTIN in Annexure B
1. Difference of Output Tax supply in GSTR 3B and GSTR1:
1. Tax liability on account of “Outward Tax Supplies” as declared in Form GSTR-3B may be verified with corresponding tax liability in respect of outward taxable supplies declared in Form GSTR1 and GSTR3B.
2. Tax liability in respect of supplies declared in FORM GSTR-1 exceeds the liability declared in FORM GSTR-3B, it may indicate short payment of Tax.
2. Tax liability on account of RCM as declared in FORM GSTR-3B may be verified with the following;
1. ITC availment in excess of the liability discharged on account of reverse charge supplies or short payment of tax liability on account of RCM Supplies.
2. ITC in respect of inward supplies attracting a reverse charge of FORM GSTR-2A.
3. ITC availed in respect of “Inward Supply from ISD” In FORM GSTR-3B may be verified with ITC of FORM GSTR-2A
4. ITC availed in respect of “All other ITC” In FORM GSTR-3B may be verified with ITC of FORM GSTR-2A
5. If your outward supply is from an online platform (Like Flipkart, Amazon etc.) then your “Outward taxable supplies” is not less than the net amount liable for TCS and TDS credit as per FORM GSTR-2A.
6. Liability on account of outward supplies in FORM GSTR-3B should be verified with the tax liability as declared in e-way bills.
7. A claim of ITC in respect of supplies from taxpayers whose registration has been canceled retrospectively.
8. Ineligible ITC availed where FORM GSTR-2A “GSTR-3B filling status” is “NO”
1. The supplier has furnished invoice details in his FORM GSTR-1 but has not furnished the return in FORM GSTR-3B
2. Ineligible ITC availed in respect of Invoices and debit notes issued by the suppliers who have not filed their GSTR-3B returns for the relevant tax period.
9. Whether GSTR-3B of a tax period is filed after the last date of availment of ITC as per Section 16(4).
1. Subsection 4 of Section 16 of CGST Act provides availment of ITC only till the due date of furnishing of FORM GSTR-3B for the month of September following the end of FY to which such ITC pertains.
2. No ITC shall be availed in respect of any invoice where the supplier has furnished his FORM GSTR-3B after the end of September of the end of the relevant FY.
10. ITC availed in respect of “Import of goods” in FORM GSTR-3B may be verified with corresponding FORM GSTR-2A.
11. Whether the registered person has made reversals of ITC in accordance with provisions of rule 42 and rule 43 of the CGST Rules.
12. Whether the registered person has paid interest liability if payment of tax after the due date in terms of section 50.
13. Whether the registered person has paid late fee in filling of GST return terms of section 47 of CGST Act.
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