Guide to Return in Form GSTR- 3B

Background

First – time experience of filing returns under GST regime will be without much bothering of mistake, interest, penalty, and late fees or matching of ITC, as government has allowed initial 2 returns in summarized manner and on provisional basis, discrepancies of which can be modified in regular return, thus let’s explore first time experience with open mind.

To ensure the smooth roll out of GST, the timeline for invoice-wise return filing in Form GSTR-1 and Form GSTR-2 for the first two months has been extended, and in lieu of Form GSTR 3, summarized details of outward and inward supplies in Form GSTR-3B are required to be submitted. This arrangement is mainly for the purpose of arriving liability under GST and payment of tax thereof.

However, the invoice-wise details in regular GSTR-1 would have to be filed for the months of July and August, 2017 as per the timelines given below

Thus the governmental has given extended timeline to business to get to equip with technology, and processes of new indirect tax regime. Further, No late fees and penalty would be levied for the interim period.

Step-by-step Guide for filing FORM GSTR-3B

Form GSTR-3B consists of 6 Tables:

Following are detailed analysis of each table:

1. Details of outward supplies and inward supplies liable to reverse charge

Analysis table 3.1 of Form GSTR 3B:

1. Submission of summarized details of Total taxable value, applicable tax and cess in each category i.e. IGST, CGST, SGST/UTGST and Cess.

2. Table 3.1 (a) : Reporting of Taxable Outward Supplies only

3. Table 3.1 (b) : Reporting Zero rated supplies i.e. Export and supplies to SEZ unit

4. Table 3.1 (c) : Reporting of Outward Nil Rated and Exempted supplies

5. Table 3.1 (d): Reporting of supplies liable to tax under Reverse Charge Mechanism (RCM). Reporting is only for taxable value after taking deduction of Rs. 5000/- per day.

6. Table 3.1 (d): Non-GST Outward Supplies i.e. Petrol, diesel, etc

7. Taxable value=  Value of invoices + value of Debit Notes – value of credit notes + value of advances received for which invoices have not been issued in the same month – value of advances adjusted against invoices.

2. Details of inter-State supplies made to unregistered persons, composition dealer and UIN holders

Analysis table 3.2 of Form GSTR 3B:

1. Table no 3.2 is breakdown of 3.1, no tax is calculated on these value

2. These details need to be reported State-wise/ union-territory wise along with IGST payable for each head

3. Details of eligible Input Tax Credit

Analysis table 4 of Form GSTR 3B:

1. Table 4 is Summarized data of Input tax credit (ITC), it requires to report the details of ITC availability, ITC to be reversed, and Net ITC available. Here only value of input tax credit is required to report like ER-1 Return.

A) ITC Available

2. Table 4(A)(1): GST paid on import of goods as per bill of entry

3. Table 4(A)(2): RCM paid on import of services

4. Table 4(A)(3): RCM paid other than import of services but including URD supplies, and specified services i.e. GTA, advocate, sponsorships, etc  

5. Table 4(A)(4): ITC on account of inward supply/distribution from ISD

6. Table 4(A)(5): All other ITC i.e. regular inward supply of goods and services including capital goods

B) ITC Reversal: ITC as above need to be adjusted for reversal to arrive at eligible ITC

7. Table 4(B)(1): Reversal of ITC used exclusively for exempt supplies, common ITC including capital goods towards exempt supplies & non-business use, etc

8. Table 4(B)(2): Other reversal of ITC i.e. blocked credit u/s 17

C) Net ITC available: Balance ITC, which can be utilized towards payment of GST

9. Table 4(C): Net ITC available for adjustment towards output liability

D) Ineligible ITC

10. Table 4(D)(1): Reporting of blocked ITC i.e. Food & beverages, Rent a Cab, Free Sample, write-off, etc

11. Table 4(D)(2): Other ineligible credit

4. Details of exempt, nil-rated and non-GST inward supplies

Table 5 is for reporting of details of inward supplies from the composition dealer, nil rated items and exempt inward supplies and Non-GST inward supplies.

5. Payment of tax

Analysis table 6 of Form GSTR 3B:

1. Main purpose of GSTR 3B return is to arrive at tax liability and this section helps to self-ascertain tax liability.
2. Section 6.1 is the summary of table 3.1, table 4(C) and table 6.2.
3. Reporting of tax payable on outward liability, RCM on inward liability into separate tax category i.e. IGST, CGST and SGST/UTGST and cess.
4. Reporting of ITC utilized and balance tax payable.
5. Details of tax paid through challan.
6. RCM tax has to be paid in cash only; ITC cannot be utilized towards RCM liability, though no restriction is provided Form No GSTR-3B

6. TDS/TCS Credit

Table 6.2 is towards reporting of TDS & TCS by the government establishment and E-commerce operator, however, these provision are kept in absence, thus no reporting for the month of July 2017.

Certain Important Aspects of GSTR 3B:

1. Form GSTR 3B can filed only though ONLINE MODE, no office line utility/tool is provided to import of data
2. This return is not applicable for Composite dealer.
3. Figures reported in Form GSTR # 3B will be provisional, these figures will form basis for preparation of GSTR-3, and however, same can be rectified by paying additional tax liability and/or availing differential ITC in electronic credit ledger.
4. GSTR-3B does not provide the column for brought forward of CENVAT credit & VAT credit from earlier indirect tax regime, thus it seems adjustment towards balance of CENVAT credit and VAT credit against GST tax liability may not be available. We will have to wait and watch for further clarification on subject matter.
5. Transitional credit will only be available after submission of Form No GSTR TRNS-1.
6. Applicable Sections, rules and notifications for submission of GSTR 3B is as under

Press Release dated 18^th June 2017.

Rule: 61(5)

7. How to submit return Online: 

(i) GSTR 3B can be submitted through ONLINE MODE only, that means data has to be inserted manually using online portal “GST.GOV.IN”.

(ii) Refer below step-by-step guide: 

Conclusion

We always wonder what it would be like to do for first time….. lot of excitement, thrill  and what not, but in GST era we will have this excitement and thrill twice i.e. at the time GSTR-3B and Regular return in GSTR-1,2 & 3, so get ready for long haul under new era of GST.

What is RCM under GST?