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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

Revised Return Timelines
Month GSTR-3B GSTR-1 GSTR-2
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.

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

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:

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

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

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

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

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

Payment of tax GST

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

TDS TCS Credit in GST

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
Title Notification No. Date
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.

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: 

How to submit GST return Online

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?

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25 Comments

  1. RAJU SHARMA says:

    Please help: We have received bill and bill of entry document form sez vendor in case of purchase. How can i claim paid tax input credit, coz purchase bill not showing in 2a.

  2. Sunil says:

    Hi,
    This is Sunil
    Am using tally for gst
    But in 3b 3.1 (d) it’s for reverce charge column asking taxable value
    But here am apply rcm for only freight charges
    Please give me solution
    This is first time for apply rcm in tally
    Thanks

  3. Manoj Kalpvruksh says:

    I am recovery agent i have received commission from bank loan recovery and bank pays my gst in reverse charge than how i will file return in gstr 3-b and gstr-1

  4. Naresh says:

    sir,
    one doubt in gstr3b returns, i was purchased from supplier, supplier issued credit note like pos sale discount, how to show in GSTR3b returns

  5. Pankaj AGrawal says:

    Hello Sir ,

    I am grain merchant (kachha aartiya) . What is farmer in GST ? Is he an unregistered dealer ? If not why ?
    Am i suppose to show purchase with farmer in GSTR 3b ?
    In VAT system I was like a service provider .Now i do not know pls clarify it .

  6. ASHOK KUMAR KANUNGA says:

    DEALER PAYING LORRY FREIGHT (GTA)– ATTRACT 5% GST ON RCM— FOR THE MONTH OF JULY 2017—- GSTR-3B—CAN WE TAKE SAME INPUT TAX CREDIT— FIRST CREATE LIABILITY ON R.C.M— FILED NUMBER 3(1)(d) AND CAN GET CREDIT—ITC FILED NUMBER 4(A)(4) OF GSTR-3B—- HERE NET LIABILITY TO PAY PARTICULAR ON GTA — INWARD SUPPLY TO REVERSE CHARGE BECOME NIL.

  7. Mohan Jain says:

    Please let me know following amount where to be reported in Form GSTR 3B:
    1) Free sample
    2) Stock transfer to other unit of parent company which is doing business on same GSTR No. without charging tax on taxable goods.
    Thanks

  8. Ashishkumar Sharma says:

    Dear Sir,

    With Reference to VAT Excise Service Tax Credit as on 30 June 2017 can be taken or not,

    I received one Updates from well know CA that Such Credit can be taken in GSTR 3B under Head “ITC Other”, with reference to GST Government of India tweeter Dated 09.08.2017,

    Please confirm the information

  9. Mahendar Kedia says:

    Whether GST under reverse charge mechanism is applicable on Petrol, Diesel as stated above for form GSTR-3B.
    “6. Table 3.1 (d): Non-GST Outward Supplies i.e. Petrol, diesel, etc”

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