The 31st GST Council meeting had settled on introducing a new GST return filing model on a trial basis. So as to ease the progress to the new GST return filing system, a transition plan has been worked out.

Presently, there’s a major trial for the taxpayers having GST registration, and that is to migrate to the newly introduced GST return filing system. Hence, the government has now presented a transition plan to the new GST return filing system.

First of all, we must understand in depth about the new GST return filing system.

1. How will the new GST return filing format look like?

The new GST return filing format was already updated on the GST portal in the month of May 2019 for all the general taxpayers who have GST registration. In this new GST return filing format, there would be 3 crucial returns to be filed:

  • The normal return i.e. FORM GST RET-1 along with these 2 annexures:
  • Structure GST ANX-1
  • Structure GST ANX-2.

2. What is the purpose of  GST ANX-1?

The GST ANX-1 is the annexure which is to be filed for the 3 month trial period, i.e. from July to September 2019.

  • From July 2019 onwards, the users will be required to submit GST invoice through the GST ANX-1 offline tool on the GST portal. This will be done t make them familiar to the new GST return filing format.
  • Importantly, from October 2019 onwards, FORM GST ANX-1 shall replace FORM GSTR-1.

The large taxpayers whose yearly turnover in the previous year was exceeding Rs. 5 Crores would have to furnish GST ANX-1 on a month to month basis.

New GST Return Filing System

3. What is the purpose behind GST ANX-2?

The GST ANX-2 is another annexure with FORM GST RET-1.

  • The purpose behind FORM GST ANX-2 is to view and download, the GST invoices related to inward supply (purchases) of the period from July to September 2019, i.e. the trial period.
  • The outline of purchase invoices would be made available on the GST portal.

Importantly, from October 2019 onwards, FORM GST ANX-2 shall replace FORM GSTR-3B.

4. What is the date for new GST return filing model to be rolled out?

Till the transitional period, which is from July to September 2019, the new GST return filing system (FORM GST RET-1 with Form GST ANX-1 and ANX-2) would be implemented only on a trial basis. This is just to make the taxpayers habitual to the new GST return filing system.

However, after October 2019 the new GST return filing model shall be made mandatory throughout India wherein-

  • Form GST ANX-1 will swap FORM GSTR-1
  • Form GST ANX-2 will swap FORM GSTR-3B.

5. Will this pilot project affect the current GST return filing?

No. This pilot project of GST return filing at the back end won’t really have a much bigger impact on the GST tax liability or the GST ITC of the taxpayers having GST registration.

To sum up, during this transition period,

  • The taxpayers are required to continue fulfilling all their GST compliances by filing FORM GSTR-1 & FORM GSTR-3B.
  • Taxpayers shall continue disclosing their outward supply details in FORM GSTR-1 on a monthly/quarterly basis and the tax return in FORM GSTR-3B on a month to month basis. Non-filing of these 2 basic returns shall still draw in the penalty as under the GST Act.

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9 Comments

  1. Y.S.BAKSHI says:

    as per my opinion there should be a one return instead of (GSTR-1 & GSTR-3B) on the Qtr. basis all over India, and GST can be deposit on the month wise basis as per books of accounts.

  2. Mihir says:

    Several changes law only create confusion and loopholes to avoid tax.. it is happening because law making has been given to some tech person without knowing the consequence and haressment to business who already suffering due to slaggish market condition. It is now extra burden to them for 3 months

    1. E-Startup says:

      Bipin Sir,
      There’s no need to worry at all…..
      All your previous GST returns and other details will be there in the records even after the new GST return filing format becomes effective.

  3. JITENDER RANKA says:

    Further I believe the GST RET1 is not complete return mechanism yet. They have to still come up for where to fill details for RCM in cases of services from unregistered persons and all that. Where would full return summary format will get generated.

    Government should give complete solutions after fully thought out all aspects. Once again government is giving half cooked provisions in GST. I would once again request let current system continue and when government is sure that it has covered all aspects then they should talk of any new system.

    They are talking of new online invoicing system. This is really dreadful as one invoice has lot of data. Comparison of eway bill with invoice is ill placed. One invoice will have 100 times bigger than one eway bill. As per me online invoicing is fraught with following:

    1. Invoicing has to be done by taxpayers from their own systems and redoing on govt systems would be double work.
    2. Invoice data on every day would be humongous and it is impossible to handle it on government portals. We have seen simple returns are not possible to handle on GSTN portal.

    Government should drop this idea or online billing on government portal.

  4. JITENDER RANKA says:

    You mentioned Anx 2 shall replace GSTR3B.
    How is that possible? I think you are not correct here.
    Anx2 as I have read is just like GSTR2A which also give details of invoices of ITC. Anx2 is also going to give the same.

    GSTR3B is a summary return of collating data from various sources. Here we give details of RCM(services where dealer is unregistered) also. Where is any mention that Anx2 will create summary?

    1. E-Startup says:

      Jitender Sir,
      There is an error…..
      After October onwards, Form GSTR3B shall be replaced by Form GST PMT8, As notified by govt recently. Kindly make a note.

  5. E-Startup says:

    Sir,
    All your previous GST returns will be there in the records even after the introduction of the new GST return filing format.
    And as discussed above, the trial period will not hamper the usual GST compliance of the taxpayers. So, you need not worry at all.
    However, if you have any further doubts on GST, please follow us on Quora-
    https://www.quora.com/profile/Pulkit-Gupta-323

  6. h iyer says:

    whether they will remove all the returns filed from the site ? should i take print outs and keep ? or whether the filed returns will be available later also ?
    please elaborate

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