Extension in GST Due Dates and Relief Measures for taxpayers under GST due to COVID-19 pandemic
In response to outbreak of Covid-19 pandemic, the government has issued various notifications extending certain due dates under GST and granting relief to taxpayers in terms of waiver of interest cost on delayed payment of tax and late fees on late filing of returns. The analysis of all such relief granted by the government to the taxpayers in a summarised manner is as under:
1. For Normal Taxpayers:
| GSTR-3B | ||||||
| TAXPAYERS HAVING AGGREGATE TURNOVER > RS. 5 CRORES IN PRECEDING FY | ||||||
| Tax Period | Due date | Extended Due Date | Interest | Late fees waived if return filed on or before*# | ||
| No interest payable till | Interest payable @ 9% p.a. from & till | Interest payable @ 18% p.a. from | ||||
| Feb, 2020 | 20th Mar, 2020 | Not extended | 4th Apr, 2020 | 5th Apr to 24th June, 2020 | 25th June, 2020 | 24th June, 2020 |
| Mar, 2020 | 20th Apr, 2020 | Not extended | 5th May, 2020 | 6th May to 24th June, 2020 | 25th June, 2020 | 24th June, 2020 |
| Apr, 2020 | 20th May, 2020 | Not extended | 4th June, 2020 | 5th June to 24th June, 2020 | 25th June, 2020 | 24th June, 2020 |
| May, 2020 | 20th June, 2020 | 27th June, 2020 | 27th June, 2020 | NA | 28th June, 2020 | NA |
| June, 2020 | 20th July, 2020 | Not extended | 20th July, 2020 | NA | 21st July, 2020 | NA |
| July, 2020 | 20th Aug, 2020 | Not extended | 20th Aug, 2020 | NA | 21st Aug, 2020 | NA |
| Aug, 2020 | 20th Sep, 2020 | Not extended | 20th Sep, 2020 | NA | 21st Sep, 2020 | NA |
| TAXPAYERS HAVING AGGREGATE TURNOVER UPTO RS. 5 CRORES IN PRECEDING FY (GROUP I) | ||||||
| Tax Period | Due date | Extended Due Date | Interest | Late fees waived if return filed on or before*# | ||
| No interest payable till | Interest payable @ 9% p.a. from & till | Interest payable @ 18% p.a. from | ||||
| Feb, 2020 | 22nd Mar, 2020 | Not extended | 30th June, 2020 | 1st July to 30th Sep, 2020 | 1st Oct, 2020 | 30th June, 2020 |
| Mar, 2020 | 22nd Apr, 2020 | Not extended | 3rd July, 2020 | 4th July to 30th Sep, 2020 | 1st Oct, 2020 | 03rd July, 2020 |
| Apr, 2020 | 22nd May, 2020 | Not extended | 6th July, 2020 | 7th July to 30th Sep, 2020 | 1st Oct, 2020 | 06th July, 2020 |
| May, 2020 | 22nd June, 2020 | 12th July, 2020 | 12th Sep, 2020 | 13th Sep to 30th Sep, 2020 | 1st Oct, 2020 | 12th Sep, 2020 |
| June, 2020 | 22nd July, 2020 | Not extended | 23rd Sep, 2020 | 24th Sep to 30th Sep, 2020 | 1st Oct, 2020 | 23rd Sep, 2020 |
| July, 2020 | 22nd Aug, 2020 | Not extended | 27th Sep, 2020 | 28th Sep to 30th Sep, 2020 | 1st Oct, 2020 | 27th Sep, 2020 |
| Aug, 2020 | 24th Sep, 2020 | 1st Oct, 2020 | 1st Oct, 2020 | NA | 2nd Oct, 2020 | NA |
| TAXPAYERS HAVING AGGREGATE TURNOVER UPTO RS. 5 CRORES IN PRECEDING FY (GROUP II) | ||||||
| Tax Period | Due date | Extended Due Date | Interest | Late fees waived if return filed on or before*# | ||
| No interest payable till | Interest payable @ 9% p.a. from & till | Interest payable @ 18% p.a. from | ||||
| Feb, 2020 | 24th Mar, 2020 | Not extended | 30th June, 2020 | 1st July to 30th Sep, 2020 | 1st Oct, 2020 | 30th June, 2020 |
| Mar, 2020 | 24th Apr, 2020 | Not extended | 5th July, 2020 | 6th July to 30th Sep, 2020 | 1st Oct, 2020 | 05th July, 2020 |
| Apr, 2020 | 24th May, 2020 | Not extended | 9th July, 2020 | 10th July to 30th Sep, 2020 | 1st Oct, 2020 | 09th July, 2020 |
| May, 2020 | 24th June, 2020 | 14th July, 2020 | 15th Sep, 2020 | 16th Sep to 30th Sep, 2020 | 1st Oct, 2020 | 15th Sep, 2020 |
| June, 2020 | 24th July, 2020 | Not extended | 25th Sep, 2020 | 26th Sep to 30th Sep, 2020 | 1st Oct, 2020 | 25th Sep, 2020 |
| July, 2020 | 24th Aug, 2020 | Not extended | 29th Sep, 2020 | 30th Sep, 2020 to 30th Sept, 2020 | 1st Oct, 2020 | 29th Sep, 2020 |
| Aug, 2020 | 26th Sep, 2020 | 3rd Oct, 2020 | 4th Oct, 2020 | NA | 4th Oct, 2020 | NA |
| Group I– Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, Daman & Diu and Dadra & Nagar Haveli, Puducherry, Andaman and Nicobar Islands, Lakshadweep | ||||||
| Group II– Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, Jammu and Kashmir, Ladakh, Chandigarh, Delhi | ||||||
* If the GSTR-3B is filed after the dates prescribed for waiver of late fees but on or before 30th Sep, 2020, then the late fees will be levied as under:
Tax Period |
Taxpayer |
Tax liability for the month | Late Fees for the month |
| Feb, 2020 to July, 2020 | All taxpayers | NIL | NIL |
| Other than NIL | Rs. 50 per day (Rs. 25 CGST and Rs. 25 SGST) subject to maximum Rs. 500 (Rs. 250 CGST and Rs. 250 SGST) |
Sample Calculation of Interest:
The calculation of interest for delayed filing of return for the month of March, 2020 for a taxpayer whose aggregate turnover for the preceding financial year was upto Rs. 5 crores and for whom the due date of filing was 22nd Apr, 2020 is as under:
| Tax period | Rate of interest | Date of filing GSTR-3B | No. of days of delay | Interest |
| March, 2020
|
Nil till the 3rd day of July, 2020, and 9% p.a. thereafter till the 30th day of September, 2020 and 18% p.a. thereafter
|
24.06.2020
|
63
|
NIL
|
| 22.09.2020
|
153
|
NIL for 72 days, thereafter interest rate @9% p.a. for 81 days | ||
| 30.10.2020
|
191
|
NIL for 72 days, thereafter interest rate @9% p.a. for 89 days and interest rate @18% p.a. for 30 days |
–
| GSTR-1 | |||
| Tax Period (M=Monthly Filers, Q=Quarterly Filers) |
Due Date | Extended due date | Late fees waived if return filed on or before# |
| Feb, 2020 (M) | 11th Mar, 2020 | Not extended | NA |
| Mar, 2020 (M) | 11th Apr, 2020 | Not extended | 10th July, 2020 |
| Jan to Mar, 2020 (Q) | 30th Apr, 2020 | Not extended | 17th July, 2020 |
| Apr, 2020 (M) | 11th May, 2020 | Not extended | 24th July, 2020 |
| May, 2020 (M) | 11th June, 2020 | Not extended | 28th July, 2020 |
| June, 2020 (M) | 11th July, 2020 | Not extended | 5th Aug, 2020 |
| Apr to June, 2020 (Q) | 31st July, 2020 | Not extended | 3rd Aug, 2020 |
| July, 2020 (M) | 11th Aug, 2020 | Not extended | NA |
| Aug, 2020 (M) | 11th Sep, 2020 | Not extended | NA |
# Please note that late fees will not be levied only if the returns are filed on or before the dates prescribed as above. If the returns are filed after the dates prescribed, late fees will be levied and that too from the due date/extended due date of the filing of the return.
| ANNUAL RETURN AND GST AUDIT | ||||
| Form | Purpose | Tax Period | Due Date | Extended Due Date |
| GSTR-9 | Annual Return | FY 2018-19 | 31st Dec, 2019 | 30th Sep, 2020 |
| GSTR-9C | GST Audit | FY 2018-19 | 31st Dec, 2019 | 30th Sep, 2020 |
2. For Composition Taxpayers:
(a) Regarding returns:
| Form | Purpose | Tax period | Due Date | Extended Due Date |
| GST CMP-08 | Quarterly statement for payment of self assessed tax | Jan to Mar, 2020 | 18th Apr, 2020 | 7th July, 2020 |
| GSTR-4 | Annual return | FY 2019-20 | 30th Apr, 2020 | 31st Oct, 2020 |
(b) Regarding registration:
| Form | Purpose | Tax period | Due Date | Extended Due Date |
| GST CMP-02 | Intimation to pay tax under section 10 (composition levy) | FY 2020-21 | Prior to commencement of FY | 30th June, 2020 |
| GST ITC-03 | Declaration for intimation of ITC reversal/payment of tax on inputs held in stock, inputs contained in semi-finished and finished goods held in stock and capital goods under Section 18(4) of CGST Act, 2017 (i.e. on opting for composition levy) | As on 31st Mar, 2020 | 30th May, 2020 | 31st July, 2020 |
3. For Other Taxpayers:
| Form | To be filed by | Tax Period | Due Date | Extended Due Date |
| GSTR-5 | Non Resident Taxpayers | Mar, 2020 | 20th Apr, 2020 | 30th June, 2020 |
| Apr, 2020 | 20th May, 2020 | 30th June, 2020 | ||
| May, 2020 | 20th June, 2020 | 30th June, 2020 | ||
| GSTR-6 | Input Service Distributors | Mar, 2020 | 13th Apr, 2020 | 30th June, 2020 |
| Apr, 2020 | 13th May, 2020 | 30th June, 2020 | ||
| May, 2020 | 13th June, 2020 | 30th June, 2020 | ||
| GSTR-7 | Tax Deductors at Source (TDS deductors) | Mar, 2020 | 10th Apr, 2020 | 30th June, 2020 |
| Apr, 2020 | 10th May, 2020 | 30th June, 2020 | ||
| May, 2020 | 10th June, 2020 | 30th June, 2020 | ||
| GSTR-8 | Tax Collectors at Source (TCS collectors) | Mar, 2020 | 10th Apr, 2020 | 30th June, 2020 |
| Apr, 2020 | 10th May, 2020 | 30th June, 2020 | ||
| May, 2020 | 10th June, 2020 | 30th June, 2020 |
4. Relief to non filers of GSTR 3B of previous months:
| Tax Period | Period of filing the return | Interest | Late Fees | |
| July, 2017 to Jan, 2020 |
Returns to be filed between 1st July, 2020 to 30th Sep, 2020 |
18% p.a. applicable on net liability |
1. If there is no tax liability for the month | NIL |
| 2. If there is a tax liability for the month |
CGST Rs. 250/- & SGST Rs. 250/- for that month |
|||
5. Other relief to taxpayers:
| Sr. No. | Particulars | Period prescribed |
| 1. | Any e-way bill generated on or before 24th Mar, 2020 and whose validity has expired on or after 20th Mar, 2020, the validity period of such e-way bill shall be deemed to be extended till | 30th June, 2020 |
| 2. | Time limit for filing of LUT for the year 2020-21 | 30th June, 2020 |
| 3. | In all cases where GST registrations have been cancelled till 12th June, 2020 and taxpayers could not get their registrations restored in time, taxpayers can file an application for revocation of cancellation of registration up to | 30th Sep, 2020 |
| 4.
|
The corporate taxpayers where it is mandatory to furnish the returns through Digital Signature Certificate (DSC) are allowed to furnish their returns (GSTR 3B and GSTR 1) through Electronic Verification Code (EVC) during the period from | GSTR-3B: 21st Apr, 2020 to 30th Sep, 2020
GSTR-1: 27th May, 2020 to 30th Sep, 2020 |
| 5. | The time limit of two years u/s. 54(1) of CGST Act, 2017 for making the refund application falling during 20th Mar, 2020 to 30th Aug, 2020 has been extended till | 31st Aug, 2020 |
| 6. | In cases where a notice has been issued for rejection of refund claim in full or in part and where the time limit of sixty days for passing the order in terms of Sec. 54(5) read with Section 54(7) of the CGST Act, 2017 falls during 20th Mar, 2020 to 29th June, 2020, then time limit for passing such order has been extended to | 15 days from the receipt of the reply to such notice or 30th June, 2020, whichever is later
|
| 7. | Where, any time limit for completion or compliance of any action, by any authority or by any person, including for the purposes of:
(a) completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, by whatever name called; (b) filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called falls during the period from the 20th Mar, 2020 to 30th Aug, 2020, and where completion or compliance of such action has not been made within such time, then except for certain compliances as mentioned under Notification No. 35/2020-Central Tax dated 3rd Apr, 2020, such time limit has been extended upto |
31st Aug, 2020 |
| 8. | A special procedure was prescribed for corporate debtors under Insolvency and Bankruptcy Code, 2016 undergoing corporate insolvency resolution process and the management of whose affairs are being undertaken by interim resolution professionals (IRP) or resolution professionals (RP), wherein there was an obligation on corporate debtor under insolvency to take a new registration as a distinct person of the corporate debtor within a period of 30 days of appointment of IRP/ RP in each of states and Union Territories where corporate debtor was registered earlier. Now such criteria has been changed to | Within a period of 30 days of the appointment of IRP/RP or by 30th June, 2020, whichever is later |
| 9. | Where the import validity period and the export obligation period for the existing Advance Authorizations (AAs)/DFIA expires from Feb to July 2020, such period has been extended by | Six months from the date of expiry |
| 10. | Current Merchandise Exports from India Scheme (MEIS) has been extended beyond 31st Mar, 2020 till Provided that prior to the said prescribed date, if certain item/tariff line/HS code gets notified under the new Scheme for Remission of Duties and Taxes on Exported Products (RoDTEP) (yet to be notified), it would naturally get excluded from the MEIS. | 31st Mar, 2021 |
(Author can be reached at [email protected])
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(Republished with amendments)
Author Bio
Good Job!!
Nicely compiled all the info at one place.
Respected Sir/ Madam please extend the penalty waiver date as the number of patient of COVID 19 is increasing day by day as well as local train is also closed in maharashtra. So, humble request to extend the date. However their is lot of shortage of money
Please check the below link for the same:
https://taxguru.in/goods-and-service-tax/gst-return-due-date-extension-relief-measures-2-0.html
good
appreciable task done