This article contains a detailed discussion regarding the e-mail which is being received by many taxpayers on 04th Aug,20 from the GST dept. (noreply@gstn.gov.in) in context of ‘Aggregate turnover being more than Rs. 5 Cr during FY 2019-20’ And for a better analysis the said e-mail is divided into the following three parts.

Part-1

(Dear 07AXXXX3916K1ZK,

Your aggregate turnover for the financial year 2019-20 has been computed by GST system based on the returns filed in Form GSTR-3B by all registrations on the common PAN. The same has been found to be more than Rs. 5 Cr where returns of FY 2019-20 filed upto 25th July, 2020 have been considered for the said computation.

two green one black pencil with text GST GOODS AND SERVICES TAX in the notebook on the white background

Your attention is drawn to definition of ‘Aggregate turnover’, defined under clause 6 of section 2 of the CGST Act, 2017. Accordingly, following methodology to compute aggregate turnover has been adopted:

(a) Turnover declared in Table 3.1(a), 3.1(b), 3.1(c) and 3.1(e) of GSTR-3B has been accounted for the computation.

(b) If the return of a tax period which was due to be filed but has not been filed for any of the GSTINs registered on the common PAN, the turnover of that period has been estimated by way of extrapolation as under:

[(Turnover declared/ No. of GSTR-3B filed) * No. GSTR-3B liable to be filed].

(c) The turnover (including extrapolated turnover) of GSTINs has been summed up at PAN level.)

Author’s comment:

  • GSTN has calculated aggregate turnover for F.Y. 2019-20 on the basis of GSTR-3B filed upto 25th July, 20 “by all Registrants on the common PAN” i.e., all entities having GSTIN on the same PAN. As per Sec 2(6) of CGST Act, 2017, “aggregate turnover” means the aggregate value of
  • All taxable supplies {Table 3.1 (a)}
  • Export of goods or services or both {Table 3.1 (b)}
  • Exempt Supplies {Table 3.1 (c)}
  • Supplies that are not taxable under the Act (alcoholic liquor for human consumption   and articles listed in section 9(2) and in Schedule III) {Table 3.1 (e)}
  • Inter-state supplies of persons having the same-Permanent Account Number,

to be computed on an all-India basis.

But excludes

  • Value of inward supplies on which tax is payable by a person on reverse charge basis
  • Central tax, State tax, Union territory tax, Integrated tax and cess.

Further, if return of a tax period is not filed for any GSTIN by the taxpayer then the estimated turnover of that period will be calculated as per following formula:

[(Turnover declared/ No. of GSTR-3B filed) * No. GSTR-3B liable to be filed].

Illustration: If a registered taxpayer filed the returns only for the period Apr to Nov,19 upto 25-07-2020 with total turnover of ₹4 cr then the turnover for the remaining three months will be computed as follows:

Formula 1

So, aggregate turnover for F.Y. 2019-20 will be ₹ 6 Crs.

Part-2

(Further, it is brought to your notice that the above turnover will be used for certain validations in the System such as determining due date of return filing, computation of late fee by the system. You can also use the same for reporting interest on delayed payments based on self-assessment basis.)

Author’s comment:

The above aggregate turnover will be used for determining the due date of return filing, computation of late fees for system validations by the GSTN.

Moreover, a registered taxpayer can also use this calculation of turnover for reporting interest on delayed payment in Table 5.1 of GSTR-3B or payment through Form DRC-03 in certain cases on account of late filing of return. This reporting is still based on self-assessment basis by the taxpayer as interest is not auto populated on GST common portal yet.

Part-3

(If any discrepancy is found in the turnover data based on the computation, as explained above and the actual turnover, the taxpayer may file a grievance at https://selfservice.gstsystem.in for redressal.  The taxpayers are advised to upload the information while raising complaint in following format, which will enable our team to resolve the same.)

PAN Legal name
Sr. No. GSTIN Registration grant date Tax period of last GSTR-3B filed Date of filing of last GSTR-3B STATUS (Active/ Cancelled) Turnover as per taxpayer (Rs.)
1 2 3 4 5 6 7
1
2
3

Author’s comment:

If you agree that your aggregate turnover during F.Y. 2019-20 exceeds ₹5 cr then you are not liable to take any action regarding this e-mail.

But if not satisfied with the calculation of aggregate turnover by the GSTN, then you may lodge a grievance at the link given above and are advised to upload the PAN-wise information in the above format which will enable the GSTN to resolve the issue.

Further, A hypothetical example is shown below for better understanding.

PAN ALKCX1796C Legal name XYZ LTD.
Sr. No. GSTIN Registra-tion grant date Tax period of last GSTR-3B filed Date of filing of last GSTR-3B STATUS (Active/ Cance-lled) Turno-ver as per taxpayer (Rs.)
1 2 3 5 6 7
1 07ALKCX1796C1ZJ 01-07-2017 June,20 19-07-2020 Active 1.50cr
2 06ALKCX1796C1Z6 01-07-2017 June,20 18-07-2020 Active 1.90 cr
3 36ALKCX1796C1ZN 05-08-2018 June,20 20-07-2020 Active 1.10 cr

Disclaimer: The views presented are in personal and generic form and not as a legal advice. Users of this information are expected to refer to the relevant existing provisions of the applicable laws.

The author may be reached at tax.bkansalco@gmail.com.

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16 Comments

  1. anuragchopra11 says:

    Hi Bhawna,
    We am yet to file GST return w.e.f FY 2018-19 (i.e. before FY 2019-20) and despite of waiver of late fee by the CBIC, common GST portal is reflecting the late fee to be paid and is not letting us file without paying that. Can you suggest the way-through this??

  2. Dhara says:

    Dear Sir,
    If any registrered person has 3 GSTIN No. on the common PAN and they have not filed the GSTR 3B for Jan 2020 to March, 2020 in respect of 2 GSTIN out of 3 GSTIN then how to calculate the extrapolated turnover for Common PAN?

    1. CA Bhawna Kansal says:

      Hi Dhara Ji,

      In this case, you have to calculate estimated aggregate turnover for your 2 GSTINs, out of 3 GSTINs on the common PAN, for which you have not filed GSTR-3B for Jan to Mar,20 as per following formula:

      [(Turnover declared/ No. of GSTR-3B filed) * No. GSTR-3B liable to be filed].

      Then calculate the total aggregate turnover for all GSTINs to determine whether it exceeds Rs.5cr or not.

  3. Ashish says:

    Dear Sir,
    While filing GSTR-3B bymistaken my accountant put extra number in sales taxable column which was 8492257/- whereas the actual figure was 849257/-. So bcoz of this my turnover goes up by 80 lacs whereas as per books it’s 4.25 cr, hence bcoz of this 80 lacs I recd mail from dept for turnover crossed 5 cr. What should I do? Please suggest

  4. Ashok Doshi says:

    If we opted for Quarterly Return and filed GSTR 1 for June 2020 Quarter and we want to changed it to monthly what is the procedure .

    1. CA Bhawna Kansal says:

      Dear Ashok Doshi Ji, as you already submitted June,20 GSTR-1 so an option to change the frequency of filing GSTR-1 is not allowed on portal now.

      Edit option (from quarterly to monthly) is available until you don’t file a single GSTR-1 for a financial year.

  5. jyothsna says:

    Dear sir/ma’am, Whether GST is applicable if we manufacture machinery which is used for agricultural purposes which is driven by animals,there is no use of electricity in running the machine

  6. Krishna says:

    Dear Sir,

    We already filed the GSTR 3B Returns related to FY 2019-20 on 30th May Itself.

    The Turnover for FY 2019-20 (Both Export & Local) Rs. 7.5 Cr.

    What action we need to take this email.

    Please guide us.

    1. CA Bhawna Kansal says:

      Krishna Ji, if your aggregate turnover exceeds ₹5cr in F.Y. 2019-20 then you are not liable to take any action against this email.

    1. CA Bhawna Kansal says:

      Please refer the comment given after Part-3.

      If your aggregate turnover exceeds ₹5cr. during F.Y. 2019-20 then you are not liable to take any action for this email but if not so then may raise a grievance at https://selfservice.gstsystem.in for redressal along with the details in the above mentioned format.

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