September is very crucial month from Annual GST compliance Perspective, as September’s 3B filing date is the last chance to rectify the Input Tax Credit & Output GST Liability pertaining to financial year 2020-21. In this article an attempt has been made to elaborate “Must do Things” before filing 3B of September 2021 to be GST complied.
Reconciliation of 2A/2B with ITC Availed :- There may be three possible scenario in this regard (i) eligible ITC pertaining to FY 2020-21 appearing in GSTR 2A/2B already accounted for in books of accounts but ITC not claimed till now in 3B, then Input needs to be taken in 3B (ii) ITC appearing in GSTR 2A/2B but not booked in books of account, then it is required to be booked & avail Input in 3B Return (iii) Input credit availed in books of accounts but not appearing in GSTR-2A/2B, then necessary follow up needs to be done with supplier/service provider so that it gets appear in September GSTR-2A/2B. All these things need to be done before filing the GSTR-3B for the month of September 21, else ITC will be lapsed or additional interest liability may arise as the case may be.
Don’t Forgot to ensue compliance with respect to limit specified U/s 36(4) of CGST Rule 2017 for claiming Input Tax Credit is done.
Availment of ITC for the FY 2020-21: – If you missed out to claim any ITC pertaining to financial Year 2020-21 then it is last chance to claim it while filing your GSTR 3B for the month of September 2021, afterwards it can’t be availed.
Rule 42 & 43- Reversal of ITC on common Credit: – If you are providing both taxable & exempt supply then ITC needs to be reversed on monthly basis proportionately as per Rule 42-43 (exempt supply to total turnover ratio). Such reversal exercise needs to be done again on annual basis before the due date of filing of return for the month of September following the end of the financial year to which such credit relates. Based on revised annual calculation, the excess/short ITC needs to be claimed or reversed as the case may be on or before the due date of filing the GSTR-3B for the month of September 2021, interest needs to be paid if applicable.
Amendment in GSTR-1:- If any amendment is to be done in relation to outward supply for FY 2020-21 then such amendment can be done in September 2021 only. For example, in case inadvertently B2B supply has been reported as B2C then the same can be amended in GSTR-1 of September 2021.
Section 34(2)-Issuance of Credit Notes: – As per Section 34(2) A supplier shall raise a credit note pertaining to a supply of a particular financial year, not later than the (i) the month of September following the end of the financial year in which such supply was made, (ii) date of furnishing the relevant annual return whichever is earlier. So due date of filing GSTR-3B for the month of September 2021 is the last chance to issue credit note pertaining to financial Year 2020-21. Once the said deadline is over Tax credit note can’t be issued and only commercial credit note (without GST) can be issued.
Rule 37 ITC Reversal: – Verify the books of accounts to ensure that the payment in respect of all the inputs, input services and capital goods for FY 2020-21 has been made to the supplier within 180 days from the date of invoice. If payment is not made fully or partially, then input tax credit availed proportionate to amount unpaid needs to be reversed along with interest. The input can be re-claimed whenever payment is made.
Outwards & RCM Reco :-It is further advised to reconcile the Outwards liability appearing in books & 3B and any shortfall/excess reporting needs to be rectified/amended in GSTR-3B for the month of September 2021. Similarly, RCM reconciliation (books V/s 3B) required to be done before filing September 21 GSTR-3B filing and any excess/short reporting w.r.t. RCM needs to be rectified in GSTR-3B for the month of September 2021 and credit on RCM can be availed.
Disclaimer: The above article is prepared for understanding & study purpose. We recommend you to consult your CA or tax consultant before taking any decision & author will not be responsible for any lose due to decision take based on above article.
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