COVID pandemic subsiding and GST Department Stepping up the Heat on the Assesses
With COVID pandemic subsiding, the activities of GST department with regard to the scrutiny of the data filed for the year 2017-18 have increased.
The GST assessees are getting communications from the GST department along with system generated excel files showing various variances in different documents like differences in
a) GSTR 1 Vs GSTR 3B
b) GSTR 3b Vs 2A
c) GSTR1/3B Vs GSTR 9
The communication reads as under
“GST scrutiny issues communicated by EIU for the period 2017-18 is forwarded herewith (find attachment) for your information”
Best part of the communication is that neither any section is mentioned in the communication from the department nor what is required is mentioned in the communication. Really hope that the proper communications will be sent by the department in future.
As the communication has been sent by the concerned jurisdictional officers of GST, the assesses have to respond to that. Normally all the responses to notices etc. should be filed online through login however this type of communications are sent through the mail and the response will be sent through the mail only as per our understanding.
Caution: The assesses must analyse the data before submission to the authorities as the respone may become the basis for raising demands by the department and the GST auditor/consultant must be apprised about the same. This has brought to the fore the need for the “Internal GST Audits” to avoid any such adverse communications from the department later.
Some of the summarized reasons for the communications from GST department after analysis by Economic Intelligence units are given below
|Analysis Parameters||Issues in GST Data filed by GST Assessees|
|PARAMETER-0069||In-eligible ITC claimed from non-genuine taxpayers (NGTPs) whose RC is cancelled ab-initio|
|PARAMETER-0070||Excess outward tax in GSTR 1 compared to GSTR 9/GSTR 3B|
|PARAMETER-0072||In-eligible ITC claimed from GSTR 3B Non-filers|
|PARAMETER-0073||Excess ITC claimed in GSTR 3B/9 which is not confirmed in GSTR 2A or 8A of GSTR 9|
|PARAMETER-0074||In-eligible ITC claimed from RC is cancelled suppliers|
|PARAMETER-0077||Less RCM Liability disclosed in GSTR 9/3B/4 than shown by suppliers in GSTR-1|
|PARAMETER-0078||ITC claims after the last date of availment of ITC as per section 16(4)- GSTR 3B|
|PARAMETER-0079||ITC on purchase invoices uploaded by supplier in GSTR 1 filed after last date of availment -section 16(4)|
|PARAMETER-0080||Interest on delayed payments made with GSTR 3B|
|PARAMETER-0081||Excess IGST on Imports shown in GSTR9_6E Vs. ICEGATE data|
|PARAMETER-0082||Excess ISD ITC availed in GSTR9_6G Vs GSTR 2A_ISD|
|PARAMETER-0083||Excess RCM ITC in GSTR9_6CDF than liability shown in GSTR 9 _4G|
The assessess must put in internal teams to ensure that these type of issues do not crop up in future as any lapses may cost the organisations a lot.
Disclaimer: The views expressed are personal and based on our understanding of the provisons/communications of GST. Readers are requested to refer to the specific GST provisions.
Please feel free to contact author CMA Navneet Kumar Jain in case any clarifications are required at firstname.lastname@example.org)