How to file GSTR 3B: Less than a month to go!!

You may aware that, govt. had given some relaxation to the taxpayers regarding filling GSTR 1 up to Sept 2017. As we all are very much into the new regime & trying to address daily issues coming up under GST, we may forget that in less than a month GSTR 3B required to be filed, which will be the first GST return ever, and its special,  after all it’s the first ever return under GST right? Of course you want it to be perfect, so sit back relax & enjoy the write up to guide you how to file GSTR 3B.

GSTR -3B consists of 6 tables (with 2 more additional tables under table 3 & 6), which are to be endorsed by the “Authorised signatory”. So one by one will see which table deals with what. Author’s personal views are also expressed wherever one needs to take care or wherever some amount of confusion is there, below is the decoding of each tables:-

So let’s start with, Table 1 &2:

These tables are not bummer, it’s plain vanilla case, just feed your GSTIN, and its over!

Table 3.1: Details of Outward Supplies and inward supplies liable to reverse charge:

Firstly, it will be good to provide the glimpse of the table, which is as below:-

Though one may read the heading as “outward supplies” which are “liable to be reverse charge” as well (if you interpret in that way) but in this table, registered person needs to fill the following details:-

• Outward taxable supplies (other than zero rated, NIL rated and exempted):

It means, here you need to fill up all the supplies which attracts GST. Supply attracts Excise, Sales tax etc. or non GST supply should not come in this row. So the total value of GST taxable supplies for the month along with GST & cess as applicable should be provided in this row.Needless to say, you need not to provide invoice wise details as of now for such supplies.

• Outward taxable supplies (zero rated)

Here, one need to fill up all the taxable supplies of the month, which were supplied either for export purpose or to SEZ unit. (Refer section 16 of IGST Act). It appears, nothing is required to be given in tax & cess column as supplies under this row is “zero rated”, unless one opt out for payment of IGST at the time of supply (to export/SEZ) & try to get the refund of the same.

Author view: Though generally, in the tax columns nothing is there to fill up as supplies are zero rated, but please note, proof of export validation mechanism should happen in order to substantiate the supply as “Zero rated”. As per Rule 96A of CGST rule time limit for zero rated supply is 3 months from the invoice date. So one need to be extra cautious to fill all these details again in GSTR 1 of July, which is due on September 5, 2017. There one need to fill up all the details including shipping bill in order to get the benefit.

• Other outward supplies (Nil rated, exempted)

In this row, it is required to fill the details of Exempted supplies of the month which are notified by Govt. In addition, the entire NIL rated supplies of the month also to be provided in this row. Though total of exempted supplies may be more than “NIL rated” supplies because, as of now, Govt. had notified only one supply, which attracts NIL rate. This comes in Sl no. 24 of the notification 11/2017 – Central Tax (Rate) [under heading 9986]

• Inward supplies (liable to reverse charge)

The intention of this row is to get the details of Inward supplies on which reverse charge GST is applicable. Eg. Services supplied by an individual advocate will be coming under this row.

It means, you need to provide details of inward supplies, notified by Govt. for which reverse charge mechanism applies

In addition, one need to provide the details of inward supplies procured from unregistered person as well.

• Non-GST outward supplies

Here you are expected to provide the details of non-GST supplies or products which continue to get levied under other taxes & not under GST. Eg. of such products are petrol, ATF, alcoholic liquor for human consumption etc. will continue to get charged under Excise Duty not under GST

Author view: There may be a complexity to understand the purpose of giving a column named “Total Taxable Value” against products, which are outside the purview of GST. Ambiguity may arise about what should be given here, as there will be a “taxable value” but not a “taxable value under GST”. However, it is better to go by the intention of the return, which seeks the “taxable value of supplies” rather “taxable value of supplies under GST”

Table 3.2: Of the supplies shown in 3.1 (a) above, details of inter-State supplies made to unregistered persons, composition taxable persons and UIN holders 

Here, you need to fill summary of inter-state taxable supplies made unregistered person, composition scheme person & UIN holder along with the place of supply state/UT, which are neither zero rated, NIL rated, exempted, non-GST supplies. To make it simple, supplies met each of the conditions below, should be reflected in this table:

1. Interstate taxable supplies
2. Not being a zero rated, nil rated and exempted or non-GST supply
3. Made to unregistered person.

Table 4: Eligible ITC

Again, let’s put the table itself for your easy understanding:-

This is the most important table of the return if you ask me. Input tax credit or ITC details need to fill up here.

• Row A1 & A2 require providing the ITC of imported goods & Services respectively.
• In row A3 Credit taken on procurement from unregistered dealer & notified goods/services against which RCM applies to be provided except import of goods/services which already given in Row A1 & A2. Please note, you need to generate a self-invoice in order to take credit of the GST applied to unregistered procurement.
• Row A4 allows you to provide the details of credit received against ISD units.It means, if one have his input service registration unit on board and received ISD invoice under Rule 54 of CGST Rule for the purpose of distribution of ITC.
• In Row A5, “all other ITC” may be provided which includes ITC on indigenous suppliers.

Author’s view:The heading “ITC Available (whether in full or part)” raising a doubt that, is it even possible to take partial credit under GST. Because, any changes in respect to ITC to be accounted by credit note, debit note etc. Putting the term “whether in full or part” may lead to a situation where one can take credit of the partial quantity of any invoice in case, rejected materials are there & credit note not issued for the same.

• Row B(1) deals with ITC reversal which is required to be made under section 17 (1) & (2) of CGST act. It means, where the goods or services or both are used by the registered person partly for the purpose of his business and partly for other purposes, the amount of credit attributable to other purposes should be reversed. Also, the similar reversal should be made where the goods or services or both are used by the registered person partly for effecting taxable supplies including zero-rated supplies and partly for effecting exempt supplies, the amount of credit attributable to exempted supplies should be reversed.

• B(2) row is very interesting as it only mentioned “others”. Please read carefully, “credits taken (if any) but disallowed” under section 17(5) of CGST Act may come here. Interpretation might be like, many of the credits u/s 17(5) is actually for the purpose of business, so it can not fit in Row B(1). However, It is disallowed by virtue of specific provision. Eg. Motor vehicle can be used for business purpose but credit is not allowed under GST [except for making supplies as mentioned in 17(5) (a) (i) & (ii)]. Other interpretation may also figure in this row.

• D(1) row is asking the details of ineligible credit u/s 17(5), like motor vehicles and other conveyances except certain cases, food and beverages, outdoor catering, membership of a club, health and fitness centre, travel benefits extended to employees on vacation such as leave or home travel concession. Even the credits against works contract services in general or ITC against goods or services or both received by a taxable person for construction of an immovable property etc.

• D2 row is again like a residuary provision “others”. Though looks simple, but remember all other ineligible credits except u/s 17(5) should come here. Interpretation might be like, one need to mention the ITC amount charged on a tax invoice but misses out any of the mandatory fields as per Rule 46 of CGST Rule 2017(as amended up to 01.07.2017). Because, the tax charged on the said tax invoice is actually an “Input Tax credit” u/s 2(63) read with 2(62). However the ITC so mentioned on the tax invoice is “ineligible” as the tax invoice is not meeting the criteria as per Rule 46 of CGST Rule 2017(as amended up to 01.07.2017)

Author’s view: One may get confused about the content against B(2) above & D(2). But, please read it carefully, content of B(2) is dealing with ITC which is already “availed” liable to be “reversed”u/s 17(5) ; However, D(1) is the row which required to show the ineligible credit, means credit which is not taken. It is the reason why Row C is dealing with Net ITC. So, even if you show some figure in column D2 your net ITC remains unchanged. But if the reversal not made as per the content of B(2), there will a part of credit which should not be a part of “ITC available”.

Table 5: Values of exempt, Nil-rated and Non-GST inward supplies: 

Table 5 deals with exempted, Nil rated & Non GST supplies which one received. This table seeks to provide “value” not the tax, of course there is no tax for the categories of supplies mentioned in heading. The very same thing which is analysed under 3.1. (b) para. Coming back to this table, you need to provide the details of intra state & intra state inward supplies received from composite scheme dealer, goods/services which attract NIL rated or which are exempted under the relevant notification.

You also need to provide in same break up (intra & inter state) for Non GST supplies, like petrol diesel etc.

Table 6: Payment of Tax:

After providing all the details of Outward & Inward supplies, It’s the time to provide the details of tax payment. Table 6 requires to provide the said details. At the end of the month, one will have following GST liability to be discharged off & this is how you can utilise the Input tax credit:

So, you will have total tax payable in column 2 against each heads against which utilisation to be reflected in column 3, 4, 5 & 6 as the case may be. In column 7 one needs to provide total TDS/TCS liability which needs to be paid through your electronic cash ledger & more details of TDS/TCS needs to be provided in table 6.2 showing a break-up of the TDS/TCS liability IGST, CGST & SGST/UTGST  wise. Hope the last two columns(column 9 & 10) you never really need to fill up as these two columns deal with, interest & late fee details which requires to be paid during the month.

Author’s view: It’s very interesting to see that one does not require to provide the challan details of the cash paid which in earlier regime was there. Though one way its good, but again the downside of it is, tha you will never find out the reference for the cash you have paid, unless those details kept handy for future communications. So it is recommended that you keep those details in your monthly file.

That’s it gentlemen, you are done with your GSTR 3B, simply file it! 

Author Pralay Chakraborty is a GST Professional & can be reached at 9705941371, cp171185@gmail.com . Feedbacks are welcome!

Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or a formal recommendation. While due care has been taken in preparing the document, the existence of mistakes & omissions herein are not ruled out. The author does not accept any liabilities for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon. No part of this document should be distributed or copied without express written permission of the author.  

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