Nothing is more expensive than a missed opportunity – H. Jackson Brown, Jr.

Month of September, being tax audit season, is always an important month for many of the businessmen and also professionals from Direct taxes point of view. Now, from indirect taxes point of view too, this month is now made critical, not for annual return or audit but return for month/quarter of September is last chance to add/correct/delete/ modify any details of either outward supplies or inward supplies pertaining to previous financial year i.e. any rectifications in the details already furnished in returns of July 2017 to March 2018 may be corrected/added in the return to be filed for the month of September 2018. Details of outward supplies can be modified on or before 31.10.2018 (being due date for filing GSTR 1) and details of inward supplies on or before 20.10.2018 (being due date for filing GSTR 3B). This article focuses on most probable errors in the returns and way to correct them.

Outward Supplies:-

1. Invoice pertaining to FY 2017-18 missed in GSTR 1 – The invoice may be added in GSTR 1 along with invoices of September 2018 in Table 4 with original date. If the tax pertaining to invoice is also not paid, the same may be added to taxable value and tax of the month of September, 2018 and pay the tax along with interest from due date of payment of tax till date of actual payment. However, the Annual return format i.e. GSTR 9 does not have a facility to add these type of missing invoices but the most suitable disclosure may be in Part V, Point 10 of Form GSTR 9.

2. B2B Invoice details wrongly entered in GSTR 1 –Here is a case where the invoice details are entered in GSTR 1 but some fields are wrongly mentioned. Some of the situations are:-

  • Error in GSTIN i.e. Invoice is in name of Mr. X but GSTR 1 is filed mentioning GSTIN of Mr. Y,
  • Error in taxable value,
  • Error in tax rate, etc.,

These details may be modified in Table 9A, 9B, 9C of GSTR 1. The same may be disclosed in Part V, Point 10 or 11 in GSTR 9.

3. B2C details wrongly entered in GSTR 1–There will be again 2 types of errors in B2C details.

3A. B2B invoice entered as B2C – If an B2B invoice pertaining to month of January 2018 entered as B2C in GSTR 1 of January 2018, this error can be rectified by adding the invoice details in GSTR 1 of September 2018 along with September B2B invoices and amending the B2C supplies of January 2018 using Table 10 of GSTR 1. To correct B2C details of a month,

Step 1 – Select the financial year and month (2017-18 & January, in this case)

Step 2 – Amount of B2C supplies already disclosed in January 2018 return appears

Step 3 – Reduce the B2C amount with the taxable value as per B2B invoice.

Then, B2C details of January 2018 stand corrected.

If the invoice is already declared in GSTR 3B correctly, the liability is not affected and the same needs not be disclosed anywhere in GSTR 9.

3B. B2C Intra-state supplies entered as Inter-state – If B2C supplies of an assessee from the state of Karnataka entered as B2C supplies of Andhra Pradesh i.e. Intra state entered as inter-state, the same may be rectified using Table 10 of GSTR 1. However, if the same error is also continued in GSTR 3B too, the liability may be affected since IGST is paid instead of CGST+SGST. This can be rectified by paying CGST+SGST and claiming refund of IGST. The same needs to be disclosed in Part V, Point 10 of GSTR 9.

3C. B2C Inter-State supplies wrongly entered as different state– If B2C supplies made to Andhra Pradesh was entered as B2C supplies to Telangana by a supplier registered in Odisha; the tax liability doesn’t change but the state mentioned is wrong. This also doesn’t affect the liability but the wrong details needs to be rectified for correct disclosure.

Inward Supplies:-

1. Failed to avail ITC– Did you miss claiming ITC on any invoice pertaining to FY 2017-18. No Worries, the same can be claimed upto the month of September 2018. Include the same in GSTR 3B of September 2018 and the ITC can be availed and utilised. These details are to be declared in Point 13 of Part V of GSTR 9.

2. GSTR 2A Vs GSTR 3B – Monthly data of GSTR 2A can be downloaded in Excel format now. Many have been ignoring the reconciliation of ITC as per GSTR 3B with details available in GSTR 2A. This reconciliation exercise should be a continuous process since it is a time consuming one but major outcomes are as under:-

  • Unearthing any missed credits i.e. supplies on which ITC is available but not availed will come into light when the reconciliation is done. It is important to note that the ITC pertaining to FY 2017-18 cannot be availed after the return for the month of September 2018 is filed.
  • There may be situations where ITC has been claimed as per Invoice issued by the supplier but the supplier failed to file GSTR 1. If supplier doesn’t file GSTR 1, the invoice details doesn’t appear in GSTR 2A. This exercise helps us to follow up with the supplier and intimating/educating them to file their GSTR 1.

It is appropriate to mention here that minimum requirements for eligibility of invoice to avail ITC have been relaxed recently. The following details are minimum requirements to avail ITC.

  • Tax charged,
  • Description of goods or services,
  • Total value of supply of goods or services or both,
  • GSTIN of the supplier and
  • GSTIN of recipient and
  • Place of supply in case of inter-State supply

3. Excess ITC claimed – There may be situations where excess ITC would have been claimed due to error. For example, instead of entering only tax amount in ITC IGST column in GSTR 3B, amount of purchases may be entered which inflates IGST ITC. The same may be rectified now by reversing the excess ITC availed by entering the amount to be reversed in Table 4(B)(2) of GSTR 3B for the month of September 2018 and the same may be disclosed in Part V Point 12 of GSTR 9.

The situations discussed in the article are the most common issues which are required to be addressed in this September return. Now, one may agree that September month is made crucial even from indirect taxes point of view and hence please be cautious and re visit all the returns filed, reconcile with books of accounts and GSTR 2A and claim the missed ITC and also rectify any errors that were made while filing the returns for FY 2017-18. Happy September return in the month of October.

(Author – CA Vinay Gandhi Billapati, Email- ca.vinaygandhi@gmail.com)

Checkout difference between Form 16/16A here

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50 Comments

  1. Kamesh says:

    Sir, Some B2B Sales had been wrongly entered as B2C during 2018-19 , can I amend this in GST Portal, if so How & before when..? Kindly guide me… Thanks

    1. bvg1988 says:

      Dear Mr. Kamesh,
      You can amend GSTR 1 of FY 2017-18 upto due date of GSTR 1 of March 2019. You may use B2B amend table to amend B2B invoices and B2C Others adjustemnt in case of B2C invoices.

  2. JOHN says:

    Respected sir/madam
    Actually in the month of december 2018 i have added Details of B2c others, after entering the data i have submitted but now it shows that i zero and, it shows that GSTR-1 and GSTR-3b miss matching
    what shall i do

  3. sarika jaykar says:

    Dear Sir,
    I have wrongly entered invoice in 2017-18 GSTR 1 Return.Now I need to amend 5 invoices related to 2017-18 is there any chance to amend…

  4. Kshipra Kulkarni says:

    Dear Sir,
    we have not claim ITC of some purchase invoices for year 17-18 . I have not filed sep 18 GSTR3B return . can I claim this amount in this return now after expiry of due date of sep return

    1. bvg1988 says:

      Dear Mr. Kshipra,

      ITC pertaining to FY 2017-18 can be availed on or before due date for filing GSTR 3B of March 2019. You can add it in your next GSTR 3B you are going to file.

  5. Kshipra Kulkarni says:

    Dear Sir,
    1)we have not done entry of reverse charge under sales of GSTR3B , but done the payment so my cash ledger is showing the addlitional amount. I am now filing GSTR3B for sep 18 should I adjust it in this return or Yearly return of 17-18
    Also I have claimed excess ITC of Aug 17 which I have paid next month I do not know where to adjust.

  6. M K SINGH says:

    Dear Sir,
    We file in GSTR1 by mistake mention port code INNSAI actually port code is INNSA1 (2017-18). Pl help us how we can amendment this error in GST portal because there is no option to show for amendment for lost year (2017-18).

    1. bvg1988 says:

      Dear Mr. Prasant,

      Yes. You can rectify the details filed in GSTR 1 of FY 2017-18 till due date of March 2019 return. However, GST portal is not yet allowing to do the same. We have to wait for the update in Portal.

    1. bvg1988 says:

      Dear Mr, Santosh,

      Yes. You can rectify the details filed in GSTR 1 of FY 2017-18 till due date of March 2019 return. However, GST portal is not yet allowing to do the same. We have to wait for the update in Portal.

  7. P SURESH KUMAR says:

    I have forgotten to pay GST cess payable amount in the month of August’17. Invoice details are there in GSTR1. I have GST cess credit available. Can I pay the same amount in 3B of November’18 or is there any chance to amend the invoice s.

  8. SANJAY JOSHI says:

    Dear Sir,

    If I put wrongl invoice number and date while filling GSTR-1, whether the purchasing party can get credit of Input Tax credit? Please reply.

    Regards,
    Sanjay Joshi.

    1. bvg1988 says:

      Dear Mr. Sanjay,

      Though you enter wrong invoice number in GSTR 1, the recipient is not deprived of his ITC. However, you have been given an opportunity to rectify the mistake upto due date of March 2019 return. BUt we have to wait for GST portal to allow the rectification.

  9. Pawan Mundada says:

    Dear Sir,

    In November 2018 GSTR2A, I see few bills of a supplier pertaining to FY2017-18 which he didn’t filed in his earlier GSTR1. After raising query by me, he filed now in his November 18 GSTR1. will my claim of ITC be accepted despite late filing by supplier. If not why government allowed November GSTR1 to accept B2B transactions of previous year? Please guide me. Thanks.

    1. bvg1988 says:

      Dear Mr. Pawan,
      You are eligible for ITC. No problem even of the supplier files his GSTR 1 late. Your ITC is safe as far as you have valid invoice, you have received goods/Services, you file your GSTR 3B and supplier pays tax by filing his GSTR 3B.

  10. Uday says:

    Dear sir
    I had filed gstr1 for the month of September… Now I need to amend 2 invoices related to 2017-18 is there any chance to amend… Pls guide me

    1. bvg1988 says:

      Dear Mr. Uday,

      Since you have already filed GSTR 1 of September 2018, there is no option to amend any details pertaining to FY 2017-18. However, there is no clarity on type of error. If it affects your liability, pay tax using GST DRC 03.

      Regards
      CA Vinay Gandhi

  11. krishnakumar says:

    We have by oversight uploaded invoices in B2C instead of B2B in GSTR1 for the FY 2017-2018
    We have already filed September 2018 GSTR1
    Now the amendment last date is over
    Please advise

  12. krishnakumar says:

    Failed to file GSTR 1 on October 31. What are the After effects for the GSTR1 filing after the due date now it does’t show 2017-18 now what we have do any solution we are entered b2b invoices in b2c for last year 2017-2018

    1. bvg1988 says:

      Dear Mr. Sanjeev,

      Late fee of Rs. 50 per day is leviable for each day of delay in filing GSTR 1.

      Also any modifications for FY 2017-18 cannot be made.

  13. sourav sharma says:

    we will reduce the amount in table 10 and the same added in b2b details , now there is difference is b2b + b2c with hsn total,can we have to add the hsn of 2b added invoice.

  14. CA HARSH AGARWAL says:

    SIR, IF TAXABLE VALUE IS NIL IN THE MONTH OF SEPTEMBER 2018 ( AT THE TIME OF CORRECTING THE MISTAKES) AND IN FY 2017-2018 GST AMOUNT HAD BEEN PAID LESS ALTHOUGH THE TAXABLE VALUE HAD BEEN SHOWN CORRECTLY THEN EVEN IF I PAY THE TAX AMOUNT ALONG WITH INTEREST THEN HOW TO SHOW THE TAX AMOUNT AT THE TIME OF FILING THE GSTR3B RETURN AS TAXABLE VALUE IS NIL AND IT WILL NOT ALLOW ME TO PUT ANY FIGURE UNDER TAX AMOUNT IF TAXABLE VALUE IS 0 UNDER GSTR 3B. KINDLY SUGGEST

  15. CA HARSH AGARWAL says:

    HELLO SIR, IF TAXABLE VALUE HAS BEEN SHOWN IN EXCESS IN GSTR3B AUG 2017 AND NOW AT THE TIME OF CORRECTING THE SAME IN GSTR3B FOR THE MONTH OF SEPTEMBER 2018 I CANNOT REDUCE THE TAXABLE AMOUNT WHICH HAD BEEN SHOWN IN EXCESS WITH THE TAXABLE VALUE IN THE MONTH OF SEPTEMBER 2018 AS THERE IS NO TURNOVER IN THE MONTH OF SEPTEMBER AND THUS IT WILL LEAD TO NEGATIVE VALUE. PLEASE SUGGEST ME HOW TO RECTIFY IT IN GSTR 3B ALTHOUGH TAX HAS BEEN PAID CORRECTLY AND ALSO SHOWN CORRECTLY UNDER GSTR1

  16. pinky jain says:

    Sir can you please give me notification or clarification of government in this regarding because someone ask that this is a fake news

      1. Nanichaitanya says:

        respected sir,
        if the any authority of gst ask reliable source of evidence regarding the above adjustment ( as you mentioned ). then above refereed section 16(4) of CGST Act 2017 wrt ITC and Proviso to section 37(3) of CGST Act 2017 can be given as evidence to the authority?
        please convey your opinion.

  17. Rahul says:

    Sir,the above issue regarding selection of financial period in gstr1 b2c amendment details have been aolved,it was a browser related issue,please ignore my above post regarding the same.Sorry for bothering!. Nice information sir, it was very helpful. Keep your good work!

  18. Rahul R says:

    Sir I cannot select previous financial year (2017-18) in September 2018 gstr 1 return I need to amend Dec 2018 b2c where a typo error has occurred. Please guide me

  19. Rahul R says:

    Sir while trying to correct B2c for December 2018 in September month gstr10 I cannot select previous financial year i.e 2017-18, it is shiwing 2018-19 August only

  20. kundan kumar Jha says:

    As far as i know about your issue,if you have paid tax less or more than actual tax in previous year from July 2017 to 31st March 2018 so in this regard you have the last chance to make amendment till 20th Oct in case of GSTR-3B and 31st Oct in case of GSTR-1. In simple language, you can do amendment when you file GSTR of sep in next month Oct. And that will be final chance to make rectify.

    Simple answer to your isuue is just reduce excess tax paid by you from tax liability which will you paid in next month at the time of filing GSTR-3B.if i will be wrong then please ignore this comment.This comment will not hold any kind of legality.

  21. Madanmohan says:

    I have shown B2C invoices as Nongst supplies in 3 months in previous year and gst collected is not shown in GSTR 3B. However sales are declared correctly in GSTR 1. To that extent there will be mismatch on tax collected with GSTR 1 and GSTR 3b. How to rectify in September gst return.

    1. bvg1988 says:

      In September GSTR 3B, include the B2C supplies which are omitted to be included with outward supplies for month of September 2018 and pay the relevant tax. If there are any Non GST supplies during September 2018, reduce the supplies with the amount wrongly declared in previous year return. Please maintain the reconciliation for the September 2018 return which will help you in your audit and annual return.

  22. Ratan Kumar says:

    Sir,
    I have wrongly shown a purchase return as outward supply in jan, 18. Now i have to reduce the outward supply and reduce input tax to reconcile the outward supply but i dont have any outward supply in the current month and not enough input to adjust the same. Please suggest what can i do??

  23. M V NAMBIAR says:

    declared sales amount Rs.108500/- as 1008500/- in GSTRB but paid tax according to Rs,108500/- . In GSTR1 declared 108500/- How can GSTR3B corrected. Please clarify.

    1. bvg1988 says:

      GSTR 3B cannot be corrected but the turnover to be declared in September may be reduced by the excess amount already declared in previous returns so that taxable value as per GSTR 3B for the full year matches with GSTR 1 and also books when full year is considered. However, GSTR 9 is considering GSTR 1 turnover for matching of outward supplies. Since, your GSTR 1 is showing correct value, there will be no problem for GSTR 9. However, it is suggestible to rectify the error so that there will be no mismatch of turnover

  24. ASHWINI SHARMA says:

    Dear Sir,
    I paid excess GST during FY 2017-18. How do I recover it ? Which Returns under which columns are need to be filed. ?
    Regards
    ashwini sharma

    1. bvg1988 says:

      More clarity/facts on the reason to pay excess tax is required to answer your query. You may contact me on my mail id mentioned in the article for more information.

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