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
|Revised Return Timelines|
|July, 2017||20th August, 2017||1st -5th September, 2017||6th-10th September, 2017|
|August, 2017||20th September, 2017||16th-20th September, 2017||21st-25th September, 2017|
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.
Form GSTR-3B consists of 6 Tables:
|Sr No||GSTR 3B Table No||Particulars|
|1||1||GSTIN number of Registered Person|
|2||2||Legal name of Registered Person|
|3||3.1||Summary of Outward Supply & Inward Supply under Reverse Charge|
|4||3.2||Bifurcation of Inter-state outward supplies as follows:
a) To unregistered Person
b) To Composite taxable Person
c) To UIN Holders
|5||4||Summary of eligible ITC claim bifurcated into IGST, CGST & SGST/UTSGT and Cess|
|6||5||Summary of Exempted, Nil rated and Non GST inward supplies|
|7||6.1||Details of payment of tax, which includes Category wise tax payable, ITC availed , TDS credit and Tax paid in cash along with interest and late fees (Though it is not applicable for initial 2 return)|
|8||6.2||Summary of tax category wise TDS/TCS credit|
Following are detailed analysis of each table:
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.
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
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
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.
Analysis table 6 of Form GSTR 3B:
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:
|CBEC notifies date for filing of GSTR-3B for July & August 2017||Notification No. 21/2017-Central Tax||08/08/2017|
|CBEC extends time for filing of Form GSTR-3 for July & August 2017||Notification No. 20/2017-Central Tax||08/08/2017|
|CBEC extends time for filing of Form GSTR-2 for July & August 2017||Notification No. 19/2017-Central Tax||08/08/2017|
|CBEC extends time for filing of Form GSTR-1 for July & August 2017||Notification No. 18/2017-Central Tax||08/08/2017|
Press Release dated 18th June 2017.
(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:
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.