September 2020 is considered to be a significant month for any Financial Year as it includes major compliances under the Goods & Services Act. Here, I provide you with the list of activities which should be performed by a registered person under GST.

Article contains GST Action Plan for September 2020 and explains Extension of Due Date of various Returns and reduction in  Interest & Late fees due to COVID-19 Pandemic, Reconciliation of Outward Supplies made during the FY 2019-20 as per Books of Account with the Returns filed and adjusting/modifying the same, GSTR-2A Reconciliation for FY 2019-20, Reversal of ITC on account of Non-Payment of Consideration within 180 Days (Rule 37), Apportionment of ITC attributable to Exempt Supplies under Rule 42 & Rule 43  and GST Audit for the FY 2018-19.

The word GST under a magnifying glass on a light concrete background. view from above

A. Extension of Due Date of various Returns and reduction in  Interest & Late fees due to COVID -19 Pandemic

The Government of India has extended various returns on account of the pandemic through reducing the interest amount and the late fees. The list of such extended returns are as follows:

1. Form GSTR-3B: Taxpayers with Turnover more than Rs. 5 crore: Late fees has been reduced to maximum of Rs. 500 and Nil for Nil Returns, if the returns are filed till 30th September’2020.

2. Forms GSTR-3B: Taxpayers having turnover less than Rs. 5 crores in previous FY in respect of States of Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh or the Union territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands and Lakshadweep 

Month Original Due Date No Late Fees/ Interest if filed by Interest @9% for period till date 30th September, 2020 (post 30th Sep-18%) Late Fees
February, 2020 22th March, 2020 30th June,2020 w.e.f 1st July, 2020 Maximum Rs. 500 and NIL for NIL Returns if returns filed till 30th September, 2020
March, 2020 22th April, 2020 3rd July,2020 w.e.f 4th July, 2020
April, 2020 22th May,2020 6th July,2020 w.e.f 7th July, 2020
May, 2020 22th June, 2020 12th September, 2020 w.e.f 13th September, 2020
June, 2020 22th July, 2020 23rd September, 2020 w.e.f 24th September, 2020
July, 2020 22th August,2020 27th September, 2020 w.e.f 28th September, 2020
August, 2020 22th September,2020 1st October, 2020 No Relief

3. Form GSTR-3B: Taxpayers having turnover less than Rs. 5Cr in previous FY in respect of States: Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha or the Union territories of Jammu and Kashmir, Ladakh, Chandigarh and Delhi

Month Original Due Date No Late Fees/ Interest if filed by Interest @9% for period till date 30th September, 2020 Late Fees
February, 2020 24th March, 2020 30th June,2020 w.e.f 1st July, 2020 Maximum Rs. 500 and NIL for NIL Returns if returns filed till 30th September, 2020
March, 2020 24th April, 2020 5th July,2020 w.e.f 6th July, 2020
April, 2020 24th May,2020 9th July,2020 w.e.f 10th July, 2020
May, 2020 24th June, 2020 15th September, 2020 w.e.f 16th September, 2020
June, 2020 24th July, 2020 25rd September, 2020 w.e.f 26th September, 2020
July, 2020 24th August,2020 29th September, 2020 No Relief
August, 2020 24th September,2020 3rd October, 2020 No Relief

B. Reconciliation of Outward Supplies made during the FY 2019-20 as per Books of Account with the Returns filed and adjusting/modifying the same

Under GST, the last date to add any missing outward sales is the due date of filing return for the period of September’2020. Hence, the registered person shall undertake the reconciliation in order to find out any missing invoices which were left out during the period.

Also, basis the reconciliation undertaken, if any invoices reported earlier are not correct, the same has to be adjusted/modified till the filing of GSTR-1/GSTR-3B for the month of September’2020. No amendment/addition of invoices are allowed after the due date of filing GST Returns for the month of September’2020.

C. GSTR-2A Reconciliation for FY 2019-20

Under GST Act, reconciliation means recording every transaction that took place during a period while also ensuring that the data filed by the supplier matches with those of the recipients. This enables one to make sure that no sales or purchases are missing or wrongly reported in the GST returns. So, it is compulsory for every taxpayer to reconcile their Input Tax Credit (ITC) with Form GSTR-2A at the end of every month/quarter of the Financial Year and avail the missed-out credit or reverse the excess ITC claimed earlier.  Any left out ITC for the FY 2019-20 may be loss to the registered person if not claimed within the due date of filing GSTR-3B.

In the course of pandemic, the Government vide a notification has provided a condition that GSTR-2A reconciliation for the period February’2020 to September’2020 has to be undertaken cumulatively and total ITC availed in the GSTR-3B from February 2020 to September 2020 cannot exceed more than 10% of eligible credit available in GSTR-2A.

D. Reversal of ITC on account of Non-Payment of Consideration within 180 Days (Rule 37)

This rule implies that when a registered person who has availed ITC could not pay the full value of inward supply along with the tax amount to the supplier within the time period of 180 days then the ITC claimed on such inward supply needs to be reversed and if a part of invoice amount is paid then ITC will be reversed on proportionate basis.

The registered person shall do a creditor ageing as on 30th September, 2020 and ensure that there are no creditors which has not been paid for the supplies made in the year. Any amount pending to be payable to creditors for more than 180 days, the ITC on the same shall be reversed.

E. Apportionment of ITC attributable to Exempt Supplies under Rule 42 & Rule 43

Rule 42 & Rule 43 states the procedure of apportionment of ITC in respect of inputs or input services or capital goods which attract the provisions of Section 17(2), being partly used for the purposes of business and partly for other purposes, or partly used for effecting taxable supplies including zero rated supplies and partly for effecting exempt supplies.

The apportionment has to be undertaken on monthly basis while filing GSTR-3B of the relevant month. However, the apportionment shall be calculated finally for the financial year before the due date for furnishing of the return for the month of September following the end of the financial year (i.e by the due date of GSTR-3B of September,2020 for FY 2019-20)

Circumstances Procedure
If the aggregate of the amounts calculated finally for the total figures for FY exceeds the aggregate of the amounts determined under in monthly GSTR-3B for the relevant FY Excess ITC claimed shall be reversed by the registered person in FORM GSTR-3B or through FORM GST DRC-03 in the month not later than the month of September following the end of the financial year to which such credit relates and the said person shall be liable to pay interest on the said excess amount at the rate specified in sub-section (1) of section 50 for the period starting from the first day of April of the succeeding financial year till the date of payment
If the aggregate of the amounts determined under in monthly GSTR-3B for the relevant FY exceeds the aggregate of the amounts calculated finally for the total figures for FY Additional ITC shall be claimed as credit by the registered person in his return for a month not later than the month of September following the end of the financial year to which such credit relates.

F. GST Audit for the FY 2018-19

The due date of furnishing GSTR-9 & GSTR-9C is as follows:

GSTR-9
Turnover up to Rs. 2 Crore

Turnover Above 2 Crore

Optional to file

Mandatory to File by 30th September, 2020

GSTR-9C
Turnover up to Rs. 5 Crore

Turnover Above Rs. 5 Crore

Optional to file

Mandatory to file by 30th September,2020

*Filing of GSTR-9C for FY 2018-19 has been made optional for MSMEs with an aggregate turnover of less than Rs. 5 crore.

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