CA Neha Somani

CA Neha SomaniInput Tax Credit

♠ To be able to claim input tax credit of an invoice, its payment must be made within 180 days as per second proviso of section 16(2) of CGST Act, 2017. If the payment is not made, the credit taken on that invoice must be reversed. And whenever such payment is made credit may be taken then. By this logic, invoices issued before 1st October, 2017 must have been paid by 31st March, 2018. If not, you’ll have to reverse the input credit claimed. This requires proper ageing analysis of outstanding debtors and creditors.

♠ Filing of TRANS 2 for July, 2017 to December, 2017 by 30th June, 2018.

♠ Opportunity to file TRAN 1 has been made available for assessee’s who had earlier submitted the TRAN -1 but could not file due to technical difficulties by 30.04.2018 [Circular 39/13/2018-GST dated 03.04.2018].

♠ In case the turnover of assessee exceeds 1.5 crores, opt for filing monthly returns, otherwise opt for quarterly returns. (At the time of filing of GSTR-3B for the month of April, 2018). However, the taxpayer shall not be allowed to amend the amount of credit in TRAN-1 during this process vis-à-vis the amount of credit which was recorded by the taxpayer in the TRAN-1, which could not be filed. The taxpayers are allowed to complete the process of filing of TRAN 1 stuck due to IT glitches, as discussed above, by 30th April 2018 and the process of completing filing of GSTR 3B which could not be filed for such TRAN 1 shall be completed by 31st May 2018.

Annual Reconciliation of Books and GST returns

For this, assessees are required to reconcile the sale ledger/ GST liability / cash ledger/ credit ledger as per books of accounts and as per GST returns. Further, in case there is any difference, then company is required to take the effect of the same in March, 2018, GSTR 3B and GSTR 1.

New Invoice Series

A registered person may develop the new series of all documents to be issued or may continue the same bill book (but however to be serially numbered) like Tax invoice. Export invoice, Bill of supply, Receipt voucher, Payment voucher, Refund voucher, Debit note, Credit note, Delivery challans for new Financial Year 2018-19.

Requirements as per Rule 46(b) of the CGST Rules, 2017:

√ A new bill book is suggested to be maintained for every new Financial Year. However, there is no restriction if the registered person continue the same bill book though to be serially numbered.

√ This bill book has to be unique (using mixture of alphabets, numbers, hyphen, etc.) and consecutively numbered. In case of electronic billing, bills are generated through system.

√ The maximum digits allowed are 16, including special characters, if any. (For e.g., 01/2018, UP/01/2018, RCPT/01/2018-19 etc.)

Application for LUT

Exporters making zero rates supplies have to furnish an LUT to the jurisdictional commissioner. An LUT is valid for one financial year. Therefore, LUT tendered in FY 2017-18 was valid until 31st March, 2018 only. Exporters who wish to continue to export under LUT need to submit a fresh LUT for FY 2018-19 to have this facility renewed.

E-way Bills

Date of Enactment : 1st April, 2018 for inter-state movement of goods.

Every registered person who causes movement of goods of consignment value exceeding fifty thousand rupees (including tax)-

in relation to supply, or

for the reasons other than supply, or

due to inward supply from unregistered person

shall require to furnish an e-way bill. No e-way bill is required if the value of the goods in an individual consignment is less than Rs. 50,000/- even if the total value of all such consignments in a single conveyance is more than Rs. 50,000/-

One can register on the portal of e-way bill namely http://ewaybillgst.gov.in by using GSTIN. If you don’t have GSTIN, then you can enroll on the portal without GSTIN too.

Following persons are liable to generate e-way bill :

  • Registered person as consignor or consignee of goods in his own or hired conveyance.
  • Registered person – for movement of goods to him caused by unregistered person
  • Transporter of goods – in the case of non generation by registered person.
  • Unregistered person – movement of goods in his own or hired conveyance
  • Transporter of unregistered person – in case unregistered person has not generated

(Author is Partner at Agarwal Sanjiv & Company, Jaipur)

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13 responses to “Immediate Compliances Under GST for Financial Year 2018-19”

  1. Refer Notification No. 66/2017 dt 15.11.17 to this effect.

  2. SUKUMAR says:

    Sir in our Advt business , the Ad Agency do not pay any bill less than 8 to 9 months . But i am sure the Ad agency will not reverse the input tax taken . how will the GST officials will know this whether the recipient has paid to the supplier within 180 days . any solution / suggestion .

  3. A.V;.DWARAGANATH says:

    TRAN 1 has been made available for assessee’s who had earlier submitted the TRAN -1 but could not file due to technical difficulties by 30.04.2018
    now i have filed Tran1 earlier submitted. my doubt is what late fee for 3B becuase I could not file from Ded 2017 onwards

  4. CA Suresh Jain says:

    very well written

  5. Amit Singh says:

    LUT is valid for 1 year from the date of issue. So if someone has got LUT on 1st July 2017 then the LUT will remain effective upto 30 June 2018. It is not related to F.Y

  6. GURSHARAN SINGH says:

    After filing of GSTR3B for the month of march 2018 on 20.4.2018,how we will adjust the following :
    1. If we recieve material after 20.4.18 supplied by the party in march 2018, when we will adjust IGST input.
    2. Can we claim GST on discount allowed to our customer against credit note issued on 31.3.2018 after filing of GSTRB for the month of march 18 on 20.4.2018.

    • Tarun Garg says:

      Dear GURSHARAN SINGH
      w.r.t. point no. 1, As per section 16 you are not eligible to book credit before receipt of material. Therefore, you will be eligible after receipt of material and then claim or adjust your credit. If you already book credit then not utilise it otherwise you have to pay penalty in future.
      w,r,t, point no. 2, please elaborate your question.

  7. S.Babu says:

    How to make ITC reversal towards second proviso of section 16(2) of CGST Act ?

  8. Shamanth says:

    thanks for refreshing

  9. Shamanth says:

    Thanks for refreshing…

  10. SRINIVAS says:

    Dear All

    We paid Rs 1 lakh towards advance for Building construction purpose.

    It may take 6 months to 12 months for completion.

    My question is for advace payment we have to pay GST

    • CA Neha Gupta says:

      Yes because :-
      The general rule for time of supply for services is earliest of the following –

      1. Date of issue of invoice

      2. Date of receipt of payment/advance*

      3. Date on which invoice should be issued

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