From 1st October 2019, well known Forms GSTR 1 and 3B of GST Era would be replaced with new Forms in a phased manner. Form GST – RET – 01 to be filed along with annexures Anx -1 for outward supplies, RCM and import of goods/services etc., and in Anx-2 details to be validated for accepting or rejecting for Input Tax Credit.

Small tax payers can file their returns once a quarter under the Form Sahaj or Sugam. Upto 5 crore turnover in previous year shall be categorised as small taxpayers and above 5 crore as large tax payers. Large tax payers shall file monthly returns. The opportunity to select/change of Form is only once a year.

Tax payers shall pay the tax liability monthly in GST PMT 08. GST PMT 08 is a replacement for current Form GSTR 3B. GST PMT 08 to be filed even if no supplies initiated in that month. Through GST PMT 08, self-assessed liabilities will be paid for the initial two months of the quarter for quarterly filers and these amounts shall be populated to RET-1

The forms would be replaced in a phased manner.

  1. GST PMT 08 to be filed from October 2019
  2. Large tax payers to file GST – RET – 01 for Dec 2019 by 20th Jan 2020
  3. Small tax payers shall file quarterly Sahaj/Sugam for Oct to Dec 2019 by 20th Jan 2020

Trial version of these Forms are available on the portal and tax payers can file the trail version from July to September 2019 to familiarise with the Forms.

Input Credit shall be matched based on 7 parameters of GSTIN, Document Type, Document Number, Document Date, Taxable Value, Tax Amount (Total), Tax amount head wise

Merits of the new Form:

  1. Only supplier to update outward supply/RCM & import details, recipient only to accept or reject the documents
  1. Continuous upload of documents is possible and on a real time basis details are available for viewing
  1. Upto 2 Amendment Returns can be filed for correcting the errors for each return filed
  1. Net of Debit/Credit note can be reported even with negative value
  1. HSN code compulsory only for Large tax payers
  1. Upto 5 crore considered as Small tax payers (this limit is 1.5 crore currently)
  1. No automatic reversal of credit if tax not paid by supplier

Drawback under the new Form:

  1. If documents uploaded by supplier is neither accepted nor rejected, pending then documents will be treated as deemed accepted by recipient for availing ITC. Though this is a benefit but it may through reconciliation issues and may lead to interest liability.
  1. RCM liability to be uploaded only by recipient. It was a double check earlier when both supplier and recipient would update RCM details and chances of missing liability was reduced.
  1. As the credit is available based on the documents uploaded by supplier, having 2 due dates for return filing which is monthly (Large tax payers) and quarterly (Small tax payers) may through mismatches.

Author Bio

Name: Uma H N
Qualification: CA in Practice
Company: Uma & Associates
Location: Bangalore, Karnataka, IN
Member Since: 04 Jul 2019 | Total Posts: 3

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