Background:
In the recent past, multiple initiatives are taken by the Government in consultation with the GSTN to streamline the GST return filing. The auto-population of details in GSTR-3B which is earlier loaded in GSTR-1 is one such classic example. As on date, the auto-populated figures in the GSTR-3B are editable by the taxpayers. This flexibility allows the taxpayers to file GSTR-3B with the tax liability different from what has been already declared in the GSTR-1. Lately for the differences between GSTR-1 and 3B, the GST Department has started issuing automatic notices in FORM GST DRC-01B, when certain parameters like specified amount or percentage of difference exist.
There were instances, where the taxpayers have committed mistakes while filing the GSTR-1 or even missed to report certain invoices while filing the GSTR-1 for a particular tax period, in the absence of the concept of “Revision of returns’ under the GST realm, the taxpayers need to wait all the way till furnishing the GSTR-1 for the next tax period, which attracts interest liability @18% in some cases.
It appears by insertion of new FORM GSTR-1A, the Government is providing the option to the taxpayers to make good of the mistakes done while filing the GSTR-1 for a particular tax period, before filing the GSTR-3B. This also gives us a hint that the Government is not happy with the manual intervention of the taxpayers with the details already auto-populated in the GSTR-3B for a particular tax period, creating differences between GSTR-1 and 3B and ambiguity. It would be no surprise, if the Government chooses to disable the manual intervention of the taxpayer in FORM GSTR-3B, by insisting the taxpayer to perform all corrections through this new FORM GSTR-1A.
History of FORM GSTR-1A:
- 22nd June 2024: GST Council in its 53rd GST Council meeting held at New Delhi recommended providing a new optional facility by way of FORM GSTR-1A.
- 10th July 2024: Amendment of CGST Rules 2017 to enable the insertion of new FORM GSTR-1A at multiple places via Notification No 12/2024 – Central Tax dated 10th July 2024, [CGST (Amendment) Rules, 2024]
- 26th July 2024: Advisory for FORM GSTR-1A released by Team GSTN on GST portal.
- 01st August 2024: Detailed Manual and FAQ’s on filing of GSTR-1A made available on the GST portal by Team GSTN.
Salient features of the new FORM GSTR-1A:
- FORM GSTR-1A is an optional facility. This can be filed only once for a particular tax period.
- The corresponding effect of the changes made through FORM GSTR-1A on the liability of the taxpayer shall be reflected in FORM GSTR-3B for the same tax period.
- At the recipient end, the ITC for the supplies declared or amended by the suppliers through FORM GSTR-1A will be available to the recipient in FORM GSTR-2B generated for the next tax period.
- From the liability perspective, the net impact of particulars declared or amended through FORM GSTR-1A, along with the particulars declared in FORM GSTR-1, shall be auto-populated in FORM GSTR-3B for the same tax period as that of FORM GSTR-1.
- For the QRMP Taxpayers, there will be no separate amendment facility available for details furnished through IFF for the months M1 and M2, during the month M1 and M2.
- In case where change is required to be made in GSTIN of a recipient for a supply reported in FORM GSTR-1 of a tax period, the same can be rectified through FORM GSTR-1 for the subsequent tax period only.
Let’s dive into the nitty-gritties of the new FORM GSTR-1A and decode the same in the following paragraphs!!!
From which tax period FORM GSTR-1A is made available in the GST Portal?
FORM GSTR-1A is made available to all the taxpayers from August 2024, through which details furnished in FORM GSTR-01 for the month of July 2024 can be amended.
What is Form GSTR-1A? Who is required to file Form GSTR-1A?
A taxpayer who needs to amend any supply details furnished in GSTR 1 or need to add any supply details of same tax period, the same can be done through GSTR 1A in the same month after filing of GSTR-1 and before filing of GSTR-3B.
Example:
E.g. GSTR 1 for the month of July 2024 has been furnished by the taxpayer on 10th of August 2024. Taxpayer committed a mistake in 2 records (wrong details are loaded in GSTR-1) and missed to report one record (Say Tax Invoice details) in its GSTR 1. Now GSTR 1A shall be opened for him/her on 10th of August or due date of GSTR 1 (i.e. 11th of August) whichever is later. The Taxpayer will be able to amend the incorrect record (i.e., wrong details furnished before) and shall also be able to add the missed record (i.e., new Invoice which was missed to include before) in Form GSTR 1A. The correct value shall be auto populated in its GSTR 3B.
When GSTR 1A will be available for filing?
For Regular Taxpayers:
GSTR -1A will be open for monthly filer from the later of the following two dates, till the actual filing of GSTR-3B of the same tax period:
- Due date of filing of GSTR1 i.e., 11th of the following month or
- Date of actual filing of GSTR-1
For Quarterly Return and Monthly Payment (QRMP) Scheme Taxpayers:
GSTR -1A will be open for quarterly filer from the later of the following two dates, till the filing of GSTR-3B of the same tax period (Quarter):
- Due date of filing the GSTR1 i.e., 13th of the month following the end of quarter.
- Date of actual filing of GSTR-1 (Quarterly).
What is the due date for filing Form GSTR-1A?
There is no due date for filing of GSTR-1A. It can be filled till the filing of GSTR-3B of the same tax period.
Can Form GSTR 1A be filed after filing Form GSTR 3B?
No, taxpayer cannot file GSTR-1A once GSTR-3B is filed for the same tax period. However, the functionality of amending records/details reported in previously filed GSTR-1 in subsequent GSTR 1 will be continued as it is.
Is it compulsory to file Form GSTR 1A?
No, GSTR 1A is optional. Taxpayer can file GSTR-1A in following scenario:
- To add new records/details which taxpayer missed out while filing in form GSTR-1, and/or
- To amend records/details which were already reported in same period in form GSTR-1.
What are the available modes of preparing Form GSTR-1A?
GSTR 1A can be filed only through online mode and through GSP.
Can Nil Form GSTR-1A be filed?
No, filing of Nil GSTR 1A is not available.
Can I amend the records/details reported in earlier GSTR 1 in current GSTR-1A?
No, GSTR 1A allows to amend the records/details filed in the GSTR 1 of current tax period only. The records/details reported in earlier GSTR 1, can be amended in any subsequent GSTR 1 subject to the time limit specified in the law.
Can I file Form GSTR 3B if I save some records/details in Form GSTR-1A but did not file Form GSTR1A?
In case a taxpayer saved any record in Form GSTR-1A but did not file the same before filing the GSTR-3B then he would face error at the time of filing of GSTR 3B, system will not allow to file GSTR 3B. Therefore, he would require to either delete the saved record in GSTR 1A or reset Form GSTR 1A or file GSTR 1A before filing GSTR 3B.
Can I add the details of a Debit Note / Credit Note in Form GSTR-1A?
Yes. A debit note / credit note can be added in the corresponding tables of GSTR 1A.
Can Recipient’s GSTIN be amended in GSTR-1A?
No, GSTIN of the recipient cannot be amended through GSTR1A. Same can be done only through GSTR 1 of the following tax periods.
I have opted for Quarterly filing of Form GSTR-1. Can I add or amend details of any record furnished through IFF for the Month M1 or M2 in GSTR-1A?
Yes. Any record furnished for the month of M1 or M2 through IFF can be amended in GSTR 1A of the same tax period which will be available to the taxpayer after filling of GSTR 1 for the quarter.
Can the filed GSTR 1A amended again if the GSTR 3B is not filed?
GSTR 1A can be filed only once for a particular tax period even if GSTR 3B is not filed.
The detailed manual on ‘How to file GSTR-1A’ can be accessed from the following link; https://tutorial.gst.gov.in/userguide/returns/index.htm#t=Creation_of_Outward_Supplies_Return_in_GSTR-1.htm
Conclusion:
In the author’s view, the insertion of new FORM GSTR-1A is a good move from the Government of India in consultation with GSTN to streamline the filing of GST returns without any discrepancies between GSTR-1 and 3B. However, if there would have been a facility to amend all the details furnished in GSTR-1 for a particular tax period including the GSTIN details it would have been a cherry on the cake. In simple, by inserting the new FORM GSTR-1A, the Government wishes to bring in the concept of ‘Revision of returns’ restricting to a specific tax period’s GSTR-1. The taxpayers must take the benefit of the said return, as it is not an additional compliance, but a tool to revise certain aspects in the GSTR-1 already filed.
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The author extends special thanks to CA Roopa Nayak [[email protected]] for vetting this article.
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