As we know that the September 2020 returns are the most crucial returns. Because these are the last returns to rectify the error made in the FY 19-20 returns.

September 2020 returns has to be filed before time to make the changes as as the last date for rectifying the mistakes or availing the ITC is the Due Date of September’s Month Return (As per Section 16(4) of the CGST Act 2017).

In this Article I have tried to figure out few important points in the form of checklist which needs to be checked before filing September 2020 returns

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Checklist before filing September 2020 return

♠ W.r.t Outward supplies

  • Check whether any difference is there in the outward supplies between the books and the GST Returns for FY 19-20.
  • If for the above the answer is Yes, than rectify the same by adjusting the difference in the September return. For example, the Differences may be as follows
    • Under Reported Sales in GSTR 1 or  GSTR 3B or Both for FY 19-20 – Report the same in GSTR 1 (by adding invoice or Debit Note) , GSTR 3B (by increasing the taxable value & the Taxes).
    • Over Reported Sales in GSTR 1 or GSTR 3B or Both for FY 19-20 – Report the same in GSTR 1 (by reducing the b2c sales or by issuing credit note) , GSTR 3B ( by reducing the taxable value and taxes)
    • Zero Rated Sales treated as regular sales and vise versa in GSTR 3B – Reduce from the Table (3.1.b) of GSTR 3B incorrectly reported and report in the correct table (3.1.a) of GSTR 3B

(Compliance w.r.t Section 34(2), 37(3), Proviso to Sec 39(9) of the CGST Act 2017)

♠ W.r.t Reverse Charge

  • Check whether the registered person has paid Reverse Charge on the appropriate item and at the appropriate rate and claimed the input for the same for FY 19-20.
  • If for the above the answer is No – Than ask the registered person to pay Reverse Charge and take the credit of the same in the September 2020.

♠ W.r.t Input Tax Credit

  • Cross check with the books whether the registered person have availed all the credit for which we are eligible for the FY 19-20 (as September is the last return to claim for the same) Cross Check the same with GSTR 2A for FY 19-20.(Compliance w.r.t Sec 16(4))
  • Check whether the registered person has reversed the proportionate ITC (on inputs , input services & capital goods) which was used for the making both taxable and exempt supplies or used for both business and non- business purpose. (Compliance w.r.t Rule 42,43 of the CGST Rules)
  • Check whether the ITC claimed (as per GSTR 3B) for the period from Feb 2020 to September 2020 is not more than 110% of the ITC appearing in GSTR 2A.(Compliance w.r.t Rule 36(4) of the CGST Rules r.w Notification No. 30/2012 dated 03.04.2020)

To Conclude, be very careful while filing September 2020 return as being the last date to claim ITC and rectify the errors and save interest.

(For Any Further Information, Please Feel free to Contact CA Ajay Kumar Mundada- Email id. jaymundada1998@gmail.com)

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