GST returns Due date, interest and late fee amendment as per various Notifications issued on 03.04.2020
Note : As per CGST Circular No. 136/06/2020-GST 3rd April, 2020 para 3 Sr. No. 2 “The due dates for furnishing FORM GSTR-3B for the months of February, March and April, 2020 & GSTR 1 Mar, April and May 2020 has not been extended through any of the notifications, but there is reduction/waiver of interest and late fee if filed before the notified date specified in below notification.
GST returns Due date, interest and late fee amendment as per various Notifications issued on 03/04/2020
- Form 3B Due date, interest and late fee – Turnover above 5 crores in preceding Financial Year
| Sr. No | Notification No. | Year | Month | Form 3B due date & Int – Turnover above 5 crores in preceding Financial
Year |
Late fee waiver – 3B | Late fee Notifn | ||
| NO Interest | Interest @ 9% | Interest @ 18% | ||||||
| 1 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Feb | Upto 04 Apr 2020 | From 05 Apr 2020 to 24
Jun 2020 |
If filed after 24 Jun
2020** |
on or before 24 june 2020
no late fee |
No. 32/2020–Central Tax 3rd April, 2020 |
| 2 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Mar | Upto 05 May 2020 | From 06 May 2020 to
24 Jun 2020 |
If filed after 24 Jun
2020** |
on or before 24 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 3 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Apr* | Upto 04 Jun 2020 | From 05 Jun 2020 to 24
Jun 2020 |
If filed after 24 Jun
2020** |
on or before 24 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 4 | No. 36/2020–Central Tax 3rd April, 2020 | 2020 | May* | on or before 27 June
2020 |
– | If filed after 27 Jun 2020 | – | – |
* For April 2020 & May 2020 turnover of preceding financial year means F.Y. 2019-2020
** If 3B is filed after 24th June, then interest @ 18% will be calculated from original due date of return filing. In addition, regular late fee shall also be leviable for such delay along with liability for penalty. Eg. Mar 2020 due date is 20th April, so if GSTR 3B for Mar 2020 is filed after 24th June 2020 say on 30th June then Interest @ 18%, late fee and penalty (if any) will be levied from 21st April 2020 to the date of filing i.e. 30th June 2020.
B. Form 3B Due date, interest and late fee – Turnover above 1.5 crores & upto 5 crores in preceding Financial Year
| Sr. No | Notification No. | Year | Month | Form 3B due date & Int – Turnover above 1.5 crores & upto 5 crores in preceding Financial Year | Late fee waiver – 3B | Late fee Notifn | ||
| NO Interest | Interest @ 9% | Interest @ 18% | ||||||
| 1 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Feb | Upto 29 Jun 2020 | – | If filed after 29 Jun
2020** |
on or before 29 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 2 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Mar | Upto 29 Jun 2020 | – | If filed after 29 Jun
2020** |
on or before 29 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 3 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Apr* | Upto 30 Jun 2020 | – | If filed after 30 Jun
2020** |
on or before 30 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
* For April 2020 turnover of preceding financial year means F.Y. 2019-2020
** If 3B is filed after 29th June or 30th June as the case may be, then interest @ 18% will be calculated from original due date of return filing. In addition, regular late fee shall also be leviable for such delay along with liability for penalty. Eg. Mar 2020 due date is 20th April, so if GSTR 3B for Mar 2020 is filed after 29th June 2020 say on 05th July 2020 then Interest @ 18%, late fee and penalty (if any) will be levied from 21st April 2020 to the date of filing i.e. 05th July 2020.
C. Form 3B Due date, interest and late fee – Turnover upto 1.5 crores in preceding Financial Year
| Sr. No | Notification No. | Year | Month | Form 3B due date & Int – Turnover upto 1.5 crores in preceding Financial Year | Late fee waiver – 3B | Late fee Notifn | ||
| NO Interest | Interest @ 9% | Interest @ 18% | ||||||
| 1 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Feb | Upto 30 June 2020 | – | If filed after 30 Jun
2020** |
on or before 30 june 2020
no late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 2 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Mar | Upto 03 July 2020 | – | If filed after 03 July
2020** |
on or before 03 jul 2020 no
late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
| 3 | No. 31/2020–Central Tax 3rd April, 2020 | 2020 | Apr* | Upto 06 July 2020 | – | If filed after 06 July
2020** |
on or before 06 jul 2020 no
late fee |
No. 32/2020–Central Tax
3rd April, 2020 |
* For April 2020 turnover of preceding financial year means F.Y. 2019-2020
** If 3B is filed after 30th June or 03rd July or 06th July 2020 as the case may be, then interest @ 18% will be calculated from original due date of return filing. In addition, regular late fee shall also be leviable for such delay along with liability for penalty. Eg. Mar 2020 due date is 20th April, so if GSTR 3B for Mar 2020 is filed after 03rd July 2020 say on 05th July 2020 then Interest @ 18%, late fee and penalty (if any) will be levied from 21st April 2020 to the date of filing i.e. 05th July 2020.
D. Form 3B May month Due date, interest and late fee – Turnover upto 5 crores in preceding Financial Year i.e. F.Y. 2019-2020
| Sr. No | Notification No. | Year | Month | Form 3B May month due date & Int – Turnover upto 5 crores in preceding Financial Year i.e. F.Y. 2019-2020 | State wise |
| 1 | No. 36/2020–Central Tax 3rd April, 2020 | 2020 | May | on or before 12 July 2020 | principal place of business is in the States of Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union territories of Daman and Diu and |
| 2 | No. 36/2020–Central Tax 3rd April, 2020 | 2020 | May | on or before 14 July 2020 | principal place of business is in the States of Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram,Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha, the Union territories of Jammu and Kashmir, Ladakh, Chandigarh or Delhi |
E – Note ITC 110% limit relaxation: – As per Notification No. 30/2020–Central Tax 3rd April, 2020 – amendment has been made to Rule 36(4) of CGST Rules which restricts the claim of ITC in GSTR 3B for each month at 110% of the ITC as reflected in GSTR 2A. The provisions of Rule 36(4) have been amended considering the lockdown, therefore now 110% condition will apply cumulatively for GSTR 3B for the Months from February 2020 to August 2020, and the cumulative adjustment effect of 110% to ITC for Feb 2020 to Aug 2020 shall be given in return for the month of Sep 2020. It means we can take ITC as per books in GSTR 3B for Feb 2020 to Aug 2020 and the 110% working of ITC for this period shall be cumulatively considered in GSTR 3B of Sep 2020. (As explained in Circular No. 136/06/2020-GST Para 3 Sr. No. 7)
F. GSTR 1
| Sr.
No |
Notification No. | No late fee if filed before the below period | Return type and period | Note |
| 1 | No. 33/2020–Central Tax 3rd
April, 2020 |
No late fee if file on or before 30 June 2020 | GSTR 1 monthly Mar 2020, Apr 2020, May 2020 | Due date is not changed but late fee is waived |
| 2 | No. 33/2020–Central Tax 3rd April, 2020 | No late fee if file on or before 30 June 2020 | GSTR 1 Qtly Jan to Mar 2020 | Due date is not changed but late fee is waived |
G. GST CMP-08 & GSTR 4
| Sr.
No |
Notification No. | Due date extended | Return type and period | Note |
| 1 | No. 34/2020–Central Tax 3rd April, 2020 | Due date on or before 07 July 2020 | GST CMP-08 Qtly Jan to
Mar 2020 |
Due date is changed |
| 2 | No. 34/2020–Central Tax 3rd April, 2020 | Due date on or before 15 July 2020 | GSTR 4 for F.Y. 2019-20 | Due date is changed |
H. GST CMP-02 & GST ITC-03
| Sr.
No |
Notification No. | CMP-02
due date |
ITC-03 due
date |
|
| 1 | No. 30/2020–Central Tax 3rd April, 2020 | 30-Jun-20 | 31-Jul-20 | Intimation of Opting for Comp scheme for the
F.Y. 2020 – 21 |
I. Clarification in respect of various measures announced by the Govt for providing relief to the taxpayers in view of spread of Novel Corona Virus (COVID-19)
| Sr.
No. |
Circular No. | Issues clarified in circular – Question | Issues clarified in circular – Answer |
| 1 | Circular No. 136/06/2020- GST Dated 03rd April 2020 Para 3 Sr. No. 8 | What will be the status of e-way bills which have expired during the lockdown period? | In terms of notification No. 35/2020- Central Tax, dated 03.04.2020,Issued under the provisions of 168A of the CGST Act, where the validity of an e-way bill generated under rule 138 of the CGST Rules expires during the period 20th day of March, 2020 to 15th day of April, 2020, the validity period of such e-way bill has been extended till the 30th day of April, 2020. |
| 2 | Circular No. 136/06/2020- GST Dated 03rd April 2020 Para 3 Sr. No. 9 | What are the measures that have been specifically taken for taxpayers who are required to deduct tax at source under section 51, Input Service Distributors and Non-resident Taxable persons? | Under the provisions of section 168A of the CGST Act, in terms of notification No. 35/2020- Central Tax, dated 03.04.2020, the said class of taxpayers have been allowed to furnish the respective returns specified in sub-sections (3), (4) and (5) of section 39 of the said Act, for the months of March, 2020 to May, 2020 on or before the 30th day of June,2020. |
| 3 | Circular No. 136/06/2020- GST Dated 03rd April 2020 Para 3 Sr. No. 10 | What are the measures that have been specifically taken for taxpayers who are required to collect tax at source under section 52? | Under the provisions of section 168A of the CGST Act, in terms of notification No. 35/2020- Central Tax, dated 03.04.2020, the said class of taxpayers have been allowed to furnish the statement specified in section 52, for the months of March, 2020 to May, 2020 on or before the 30th day of June, 2020. |
R R Tiwari & Associates – Chartered Accountants – CA Rajesh R. Tiwari
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