Contents

Article discusses What is GSTR-6, Who, where and when needs to file GSTR-6 and is it mandatory to file it, Is it mandatory to take action on all invoices auto populated in GSTR-6, What actions can I take on invoice data auto populated in GSTR-6, What happens if GSTR 6 is filed before GSTR-1 and then GSTR-1 and GSTR-5 are filed etc.

1. What is GSTR-6?

GSTR-6 is a monthly return to be filed by all the Input Service Distributor’s (ISD) for distribution of credit (ITC) amongst its units.

2. Who needs to file GSTR-6 and is it mandatory to file it?

Only those taxpayers who are registered as Input Service Distributor (ISD) need to file GSTR-6. It is a mandatory return, to be filed monthly. A Nil return must be filed in case of no business activity.

3. By when do I need to file the GSTR-6?

ISD Returns for month M can only be filed on or after the 11th of month M+1 and on or before the 13th of month M+1. This is subject to changes in due date done by Government if any.

4. From where can I file GSTR-6?

GSTR-6 can be accessed on the GST Portal, post login in the Returns Dashboard by the taxpayer.

The path is Services > Returns > Returns Dashboard

5. Is it mandatory to take action on all invoices auto populated in GSTR-6?

Yes, it is mandatory to take action against all invoices auto populated in your GSTR-6, failing which you will be unable to file GSTR-6.

6. What actions can I take on invoice data auto populated in GSTR-6?

For invoice data received in GSTR-6, you can take following actions (identical to that of GSTR-2):

  1. Accept
  2. Reject
  3. Modify
  4. Keep Pending
  5. Add Missing Invoice

7. Can I file my ISD return if my counterparties have not filed GSTR-1/GSTR-5?

Yes, you can file your GSTR-6 return even if your counterparties have not filed their respective GSTR-1 and GSTR-5. You can do this by uploading the missing invoices using the ADD MISSING INVOICE functionality and filing the return within the prescribed timeline.

8. What happens if GSTR 6 is filed before GSTR-1 and then GSTR-1 and GSTR-5 are filed?

In case GSTR-1 and GSTR-5 are not submitted by the counterparties till 10th of the month succeeding the tax period, there will be no auto-population of B2B details in GSTR-6A and GSTR-6 for that tax period. In such an event, ISD has to add missing invoices using the ADD MISSING INVOICE functionality. He can use B2B details uploaded by supplier (if any), that were visible to ISD on near real time basis to prepare its GSTR-6.

Also, these uploaded B2B details will flow directly to the GSTR-1/GSTR-5 of the suppliers.

9. Is there any Offline Tool for GSTR-6?

No, there is no offline tool for GSTR-6.

10. Is there any late fee in case of delayed filing of GSTR-6?

Yes, there is a late fee of INR 200 per day (INR 100 for CGST Act and INR 100 for SGST Act) subject to a maximum of INR 10000 (INR 5000 per Act).

11. Is there an Electronic Credit Ledger available for ISD Registrations?

No, there is no Electronic Credit Ledger maintained for ISD Registrations. However, there is an ISD Ledger maintained to keep a record of all transactions.

12. When and where are the auto populated invoices reflected in the GSTR 6?

The auto populated invoices can be viewed in GSTR-6A (Table 3 and 4) and GSTR 6 (Tables 3, 6A, 6B, and 6C) simultaneously once GSTR-1/GSTR-5 is successfully saved by the supplier taxpayer. Action can be taken on the invoices if the GSTR 1 have been submitted by the supplier taxpayer.

13. Am I supposed the mark the eligibility of ITC at an invoice-level?

Yes, similar to GSTR-2, you are expected to mark ITC eligibility at an invoice-level.

14. As an ISD, am I liable to pay tax on a reverse charge basis? OR Is reverse charge applicable to ISDs?

Reverse charge liability is not applicable for an ISD taxpayer.

15. How do I allocate credit to my other units in the GSTR 6?

Using Table 5 and Table 8 of the GSTR-6, both eligible and ineligible ITC can be distributed to the other units.

16. Can I reverse the credit allocated to the units in GSTR 6 of earlier tax periods? If yes, how?

Yes, you can redistribute the credit allocated to a unit in a previous tax period using Table 9 of the GSTR-6.

17. Can the date of filing of Form GSTR-6 be extended?

Yes, date of filing of Form GSTR-6 can be extended by the Board/Commissioner by notification.

18.  What are the pre-conditions for filing GSTR-6?

Pre-conditions for filing of GSTR-6 are:

  • The receiver taxpayer should be a Registered ISD and should have an active GSTIN.
  • Receiver taxpayer should have valid login credentials (i.e., User ID and password).
  • Receiver taxpayer should have valid and non-expired/ unrevoked Digital Signature Certificate (DSC which is mandatory for companies, LLPs and FLLPs).
  • Receiver taxpayer should have a valid Aadhaar number with mobile number, in case they want to use the E-Sign option.
  • A receiver taxpayer should have with him an active mobile number which is indicated in his registration details furnished to GST Portal at the time of enrolment/ registration or amendment to registration details for signing through EVC.
  • A receiver taxpayer will have an option to file Form GSTR-6 for cancelled GSTINs for the period in which it was active.
  • Due date for filing of Form GSTR-1 and GSTR 5 of the same tax period should have lapsed.

19.  What happens after Form GSTR-2 is filed?

After Form GSTR-6 is filed:

  • ARN is generated on successful submission of the Form GSTR-6 Return.
  • An SMS and an email are sent to the taxpayer on his registered mobile and email id
  • on successful submission of Form GSTR-6.
  • Once the Form is submitted after affixing DSC or E-sign or EVC as the case may be,
  • the Form is passed on to:

i. The CBEC (Central Board of Excise and Customs – the central tax authority)

ii. Tax authority of jurisdictional State or UT

  • In case of modifications or additions in Form GSTR-6, such details are auto-populated
  • in Form GSTR-1/1A/5 of counterparty supplier taxpayers.
  • ISD Ledger is updated.

20. What are the modes of signing GSTR-6?

You can file GSTR-2 using DSC, E-Sign or EVC.

Digital Signature Certificate (DSC)

Digital Signature Certificates (DSC) are the digital equivalent (that is electronic format) of physical or paper certificates. A digital certificate can be presented electronically to prove one’s identity, to access information or services on the Internet or to sign certain documents digitally. In India, DSC are issued by authorized Certifying Authorities.

The GST Portal accepts only PAN based Class II and III DSC.

To obtain a DSC, please contact any one of the authorised DSC-issuing Certifying Authorities: http://www.cca.gov.in/cca/?q=licensed_ca.html

Electronic Signature (E-Sign)

Electronic Signature (E-Sign) is an online electronic signature service in India to facilitate an Aadhar holder to digitally sign a document.

A One Time Password (OTP) will be sent to mobile phone number that is registered with Aadhar at the time of digitally signing documents at the GST Portal.

Electronic Verification Code (EVC)

The Electronic Verification Code (EVC) authenticates the identity of the user at the GST Portal by generating a OTP. The OTP will be sent to the mobile phone number of the registered mobile phone of Authorized Signatory filled in part A of the Registration Application.

21. Can I preview the Form GSTR-6 before submitting?

Yes, you can preview the Form GSTR-6 before submitting on the GST Portal.

22. What information can be modified and cannot be modified by a taxpayer in an invoice in GSTR-6?

A taxpayer can modify the invoice value and tax values in an invoice in GSTR-6.

Invoice Number cannot be modified by the taxpayer in an invoice in GSTR-6.

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