GSTN has released the Prototype of Simplified GST Return Filing System. Highlights of the proposed system are as follows:
√ Three Forms: Suppliers making B2B Supplies only: GST RET-1 (Normal) Suppliers making B2C Supplies only: GST RET-2 (Sahaj) Suppliers making B2C & B2B Supplies both: GST RET-3 (Sugam)
√ Annexure of supplies (GST ANX-1) and Annexure of Inward Supplies (GST ANX-2) will be part of these returns.
√ All the outward supplies will be detailed in GST ANX-1
√ GST ANX-2 will contain details of inward supplies auto-populated mainly from the suppliers’ GST ANX-1. The new return filing format would replace the current requirement of filing final sales return GSTR-1; and summary sales return GSTR-3B.
Let us discuss & understand the revised GST Return Mechanism in details.
Any invoice uploaded by the supplier on the portal is “Uploaded Invoice”. For the recipient the uploaded invoice is a valid document to avail input tax credit. Under the new return mechanism supplier can continuously upload invoices and respective recipient can check the uploaded invoice through new ‘Viewing Facility’ provided on the portal; this would help both suppliers & recipients to have better control on invoice uploading, tracking & validation of invoices.
Once the supplier uploads the invoices, the recipient can mark the invoices as “accepted” which means that the recipients confirm the contents & accuracy of the invoices. Once after viewing are called “Accepted” or “Locked” Invoices.
Though if the recipient does not explicitly “accept/Lock” the invoice but at the same time does not mark as “Rejected” or “Pending”, the same invoice shall be treated as “Accepted” by default. Once the recipient explicitly “Accept /Lock” the invoice or file the return for the relevant tax period, the supplier cannot “Amend” the same unless the recipient reverse the ITC and unlock the invoice.
If for any reason the suppler uploads any invoice & the recipient for any reason refuses to accept the invoice e.g. wrong GSTIN mentioned by the supplier is incorrect or invoice doesn’t pertain to that recipient and the recipient “View” the invoice in their account, he can “Reject” the invoice. Every recipient is advised to reject incorrect/irrelevant invoices on real time basis to help the supplier correct uploading of invoices which would help the recipient too.
There may be invoices which have been received by the recipient & ITC is claimed but the supplier doesn’t upload the same either by omission or otherwise, such invoices are “Missing Invoices”. The supplier can report such missing invoices in the return for any subsequent tax period but with applicable interest or penalty.
Any uploaded invoices the suppler if marked “Pending” by the recipient is a pending invoice. A recipient can do this if of the content is to be rectified by the supplier, if material is still under transit, or for some reason is undecided about the ITC for the same.
If the supplier has uploaded any invoice but for any reason wants to rectify/amend the same, he can do it. The supplier can amend any invoice only if neither the recipient has claimed ITC on it nor he has accepted/locked it.
Any invoice, once locked cannot be amended. Any changes to such locked invoices would be made through a Debit Note or Credit Note only.
If any taxpayer has made some mistake in the regular return, he can file an “Amendment Return”, two (2) amendment returns are allowed for each tax period.
Any Amendment Return is allowed till the due date for furnishing return of September of the subsequent financial year or date of filing of the annual return for the relevant financial year, whichever is earlier.
All Taxpayers having annual turnover of more than Rs. 5 Crores (excluding Composition Dealers, ISD, NRR, TDS and TCS) in the last Financial Year have to file Monthly Return. The Due Date to file monthly return would be 20th day of the subsequent month.
Following taxpayers would have to file monthly GST Return:
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