GST compliance relief in view of COVID-19 outbreak

In view of the emergent situation and challenges faced by taxpayers in meeting the compliance requirements under various provisions of the GST law, our Hon’ble Finance Minister had announced various relief measures relating to statutory and regulatory compliance matters on 24.03.2020. Those relief have now been notified vide various CGST notification dated 03.04.2020, which are briefed below for your easy and quick understanding:

1. Amendment in CGST rules for relief – Central Goods and Services Tax (Fourth Amendment) Rules, 2020

(Notification 30/2020 – CT)

a. Extension in due date to opt for Composition Scheme for FY 2020-21 (Rule 3)

Form GST CMP 08 to opt for composition scheme can be filed upto 30.06.2020;

Form GST ITC 03 for ITC reversal can be filed upto 31.07.2020.

b. Extension in applicability of Rule 36(4)

Condition of Rule 36(4) in claiming ITC in GSTR 3B (i.e. 110% of ITC as per GSTR 2A) has been relaxed in filing of GSTR 3B for the month February to August 2020 and the adjustment shall applicable cumulatively in GSTR 3B to be filed for the month September 2020;

2. Delay in Filing of Form GSTR 3B

(Notification 31/2020 – CT, 32/2020 – CT & 36/2020-CT)

Interest & Late Fee waiver in delay filing of GSTR 3B for the month February, March & April 2020 which is as below:

Condition (IMPORTANT):

It is clear from the above table that there is no extension in due date for filing of Form GSTR 3B. The notification provides waiver of Interst and Late fee. However the above mentioned Waiver in interest and Late fee is Conditional with a condition that the GSTR 3B for respective period must be filed within the dates mentioned in column (4) & (5) above.

If it is not filed within that date, than the late fee and interest shall be applicable as before from the respective due dates as mentioned in column (3).

3. Delay in filing of GSTR-1  

(Notification 33/2020 – CT)

Late fee shall stand waived for delay in filing of Form GSTR 1 for the months of March 20, April 20 and May 20, and for the quarter ending 31st March, 2020, provided it is filed on or before the 30.06.2020.

4. Composition Scheme – Payment & Return

(Notification 34/2020-CT)

5. General Extension of Due dates

(Notification 35/2020 – CT)

a)There is a general extension of compliance dates where, any time limit for completion or compliance of any action, by any authority or by any person, has been specified in, or prescribed or notified under the said Act, which falls during the period from the 20.03.20 to 29.06.20, and where completion or compliance of such action has not been made within such time, then, the time limit for completion or compliance of such action, shall be extended upto 30.06.20;

The above general extension is not applicable for various provisions related to Invoicing, Registration, Return (Specific relief above), e-way bill, Penalty, Arrest, etc.

b) Where an e-way bill has been generated under rule 138 and its period of validity expires during the period 20.03.20 to 15.04.20, the validity period of such e-way bill shall be deemed to have been extended till 30.04.20.

Relevant GST Notifications