In response to outbreak of Covid-19 pandemic, the government has issued various notifications ranging from Notification No. 07/2021-Central Tax dated 27.04.2021 to Notification No. 27/2021-Central Tax dated 01.06.2021 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 measures granted by the government to the taxpayers are summarised as under:

1. For Regular Taxpayers:

(A) Waiver of Interest and Late Fees:

FORM GSTR-3B
(A) 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
Mar, 2021 20th Apr, 2021 Not extended Not Applicable 21st Apr to 05th May, 2021 06th May, 2021 05th May, 2021
Apr, 2021 20th May, 2021 Not extended Not Applicable 21st May to 04th June, 2021 05th June, 2021 04th June, 2021
May, 2021 20th June, 2021 Not extended Not Applicable 21st June, 2021 to 05th July, 2021 06th July, 2021 05th July, 2021
(B) TAXPAYERS HAVING AGGREGATE TURNOVER UPTO RS. 5 CRORES IN PRECEDING FY
(I)Taxpayers under QRMP (Quarterly Return Monthly Payment) Scheme:
(i) GROUP-I TAXPAYERS
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
Jan to Mar, 2021 22nd Apr, 2021 Not extended 07th May, 2021 08th May, 2021 to 21st June, 2021 22nd June, 2021 21st June, 2021
Apr, 2021 (Form GST PMT-06) 25th May, 2021 Not extended 09th June, 2021 10th June, 2021 to 09th July, 2021 10th July, 2021 Not Applicable
May, 2021 (Form GST PMT-06) 25th June, 2021 Not extended 10th July, 2021 11th July, 2021 to 25th July, 2021 26th July, 2021 Not Applicable
(ii) GROUP-II TAXPAYERS
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
Jan to Mar, 2021 24th Apr, 2021 Not extended 09th May, 2021 10th May, 2021 to 23rd June, 2021 24th June, 2021 23rd June, 2021
Apr, 2021 (Form GST PMT-06) 25th May, 2021 Not extended 09th June, 2021 10th June, 2021 to 09th July, 2021 10th July, 2021 Not Applicable
May, 2021 (Form GST PMT-06) 25th June, 2021 Not extended 10th July, 2021 11th July, 2021 to 25th July, 2021 26th July, 2021 Not Applicable
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
(II)Taxpayers not under QRMP (Quarterly Return Monthly Payment) Scheme:
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
Mar, 2021 20th Apr, 2021 Not extended 05th May, 2021 06th May, 2021 to 19th June, 2021 20th June, 2021 19th June, 2021
Apr, 2021 20th May, 2021 Not extended 04th June, 2021 05th June, 2021 to 04th July, 2021 05th July, 2021 04th July, 2021
May, 2021 20th June, 2021 Not extended 05th July, 2021 06th July, 2021 to 20th July, 2021 21st July, 2021 20th July, 2021

 (B) Extension in Due Dates:

Form Tax Period Due Date Extended Due Date
GSTR-1 April, 2021 11th May, 2021 26th May, 2021
May, 2021 11th June, 2021 26th June, 2021
IFF April, 2021 13th May, 2021 28th May, 2021
May, 2021 13th June, 2021 28th June, 2021
ITC-04 Jan to Mar, 2021 25th Apr, 2021 30th June, 2021

(C) GST Late Fees Amnesty Scheme (For non-filers of GSTR 3B returns for previous months):

Tax Period Period of filing the return Late Fees
July, 2017 to April, 2021 Returns to be filed between 01st June, 2021 to 31st Aug, 2021 1. If there is no tax liability for the tax period CGST Rs. 250 and SGST Rs. 250 per return
2. If there is a tax liability for the tax period CGST Rs. 500 and SGST Rs. 500 per return

2. For Composition Taxpayers:

(A) Waiver of Interest and Late Fees:

FORM GST CMP-08
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
Jan to Mar, 2021 18th April, 2021 Not extended 03rd May, 2021 04th May, 2021 to 17th June, 2021 18th June, 2021 Not Applicable

 (B) Extension in Due Dates:

Form Tax Period Due Date Extended Due Date
GSTR-4 FY 2020-21 30th Apr, 2021 31st July, 2021

# Sample Calculation of Interest:

Tax Period Type of taxpayer Rate of interest Date of filing GSTR-3B No. of days of delay Interest
March, 2021 Turnover upto Rs. 5 crores and not under QRMP scheme 21st Apr, 2021 to 05th May, 2021 – NIL

 

06th May, 2021 to 19th June, 2021 – 9% p.a.

 

20th June and thereafter – 18% p.a.

03rd May, 2021 13 Nil
15th June, 2021 56 NIL for 15 days, thereafter 9% p.a. for 41 days
31st July, 2021 102 NIL for 15 days, thereafter 9% p.a. for 45 days, thereafter 18% p.a. for 42 days

 * Condition regarding late fees:

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. 

3. For Other Taxpayers:

Extension in Due Dates:

Form To be filed by Tax Period Due Date Extended Due Date
GSTR – 5 Non Resident Taxpayers (NRTP) Mar, 2021 20th Apr, 2021 30th June, 2021
Apr, 2021 20th May, 2021 30th June, 2021
May, 2021 20th June, 2021 30th June, 2021
GSTR – 6 Input Service Distributors (ISD) Apr, 2021 13th May, 2021 30th June, 2021
May, 2021 13th June, 2021 30th June, 2021
GSTR – 7 Tax Deductors at Source (TDS Deductors) Apr, 2021 10th May, 2021 30th June, 2021
May, 2021 10th June, 2021 30th June, 2021
GSTR – 8 Tax Collectors at Source (TCS Collectors) Apr, 2021 10th May, 2021 30th June, 2021
May, 2021 10th June, 2021 30th June, 2021

4. Other relief to taxpayers:

Sr. No. Particulars Period prescribed
1.

 

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 & GSTR-1: 27th Apr, 2021 to 31st Aug, 2021

 

2. Cumulative application of Rule 36(4) for availing ITC for tax periods April, May and June, 2021 shall be done in the return for the period of June, 2021
3. 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 15th Apr, 2021 to 30th May, 2021, 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, 2021,  whichever is later

 

4. 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 15th Apr, 2021 to 29th June, 2021, 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. 14/2021-Central Tax dated 1st May, 2021, such time limit has been extended upto

30th June, 2021
5. Time limit for verification of registration application by the authorities which falls due during the period from 1st May, 2021 to 30th June, 2021 has been extended upto 15th July, 2021

(Author can be reached at [email protected])

Disclaimer: The contents of this article are for information purposes only and does not constitute an advice or a legal opinion and are personal views of the author. It is based upon relevant law and/or facts available at that point of time and prepared with due accuracy & reliability. Readers are requested to check and refer relevant provisions of statute, latest judicial pronouncements, circulars, clarifications etc. before acting on the basis of the above write up.  The possibility of other views on the subject matter cannot be ruled out. By the use of the said information, you agree that Author is not responsible or liable in any manner for the authenticity, accuracy, completeness, errors or any kind of omissions in this piece of information for any action taken thereof. This is not any kind of advertisement or solicitation of work by a professional.

(Republished with amendments on 03.06.2021)

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2 Comments

    1. CA Kushal Fofaria says:

      As per Explanation of Section 54 of CGST Act, 2017, you can make application of refund of unutilised ITC upto 2 years from end of the financial year. Thus in your case, you can make refund application upto end of FY 2021-22.

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