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As we say hello to September amidst corona times, while hot summer is collapsing into fall and slowly awakening autumn, it is also the most important month of GST law. Important dates are given below for important compliance purposes:

Last date of reporting / rectification in FORM GSTR-1 for FY 19-20

Last date of rectifying details of outward supplies for FY 19-20 which was omitted or needs any amendment in GSTR-1 is till the due date for filing GSTR-1 of September 2020, which is October 11, 2020.

Due Date

Last date of Issuance of debit notes and credit notes for FY 19-20

ITC on debit notes pertaining to invoices issued in FY 19-20 can be claimed till filing of GSTR-3B for September 2020 (i.e. till October 20, 2020). Debit notes can be issued  up to September 30, 2020 to enable customer to avail ITC. Similarly, Credit notes for supplies made in FY 19-20 can be issued by September 30, 2020.

Last date of claiming ITC pertaining to FY 19-20

ITC for FY 19-20 can be claimed on before filing of GSTR-3B for September 2020 (i.e. till October 20, 2020) or filing annual return (December 31, 2020), whichever is earlier. Hence, 20 October 2020 is the last date for claiming ITC of the FY 2019-20.

Reversal of common credits used for making exempt supplies

Reversal of ITC on inputs and input services attributable to exempted supplies on provisional basis is governed by Rule 42 of the CGST Rules. This needs to be done on monthly basis. Finalisation is required to be done on yearly basis. In case any ITC is wrongly availed during the FY 2019-20 then in such case reversal of such excess ITC is to be done by September 30 of next FY.

E-invoicing of taxpayers with turnover exceeding ₹ 500 crores

E-invoicing becomes compulsory for taxpayers having aggregate turnover exceeding ₹ 500 crores with effect from October 1, 2020. Therefore, the taxpayers falling in above category will have to make their IT infrastructure ready for the above by 30 September 2020.

CAROTAR 2020 under Customs and FTP

The Government has introduced the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020 (‘CAROTAR 2020’) vide Notification No. 81/2020 – Customs (NT) dated August 21, 2020 for claiming benefits under Trade Agreements. A detailed procedural framework has for governing preferential duty claims is coming into effect from 21 September, 2020.

Miscellaneous compliances

MEIS / SEIS scrips which were issued between the period commencing from1st March 2018 to 30th June 2018 will remain valid till September 30, 2020.

Relevant compliances under EOUs schemes are to be completed on or before September 30, 2020.

[The author is also Convenor Taxation, Baddi Barotiwala Nalagarh Industrial Association, Himachal Pradesh (BBNIA). The views expressed are strictly personal.]

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