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 |
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(Republished with amendments on 03.06.2021)
Author Bio
Is there any extension of due dates for GST Refund of unutilized ITC OF FY 19-20.
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.