GSTR 1, 2, 3 (old filling system) was a fiasco not just because of technical glitches, or portal failure also It was failure because No taxpayer has these much time to work out “accept – reject” his Inward invoices. Imagine if it is more than even 100 invoices. Imagine the stress & wastage of time if invoices are more than 1000. Of course technology is required in return filing procedure. But let us not depend only on technology. Technology after one point is also not helping. Also, Technology should never restrict genuine claims of ITC. The same system was coming with the new Name RET 1 & 2 with ANNX -1 & 2. .but they scrapped this idea and Brought QRMP. Another fiasco. I have already shared how QRMP is the worst idea. Already I have shared in this article. https://taxguru.in/goods-and-service-tax/qrmp-headache-asked.html . Let us make GST easy. No small – medium enterprises have these much Time, skill & man-power to do these cumbersome exercises of Accept-Reject-Lock-Missing. Read my next point for getting idea of Ideal return filling system. Do comment only after reading whole dream idea about Return filling system in GST. AnAPPROACH TO MAKE GST GOOD & SIMPLE. Also I had discussed how Gujarat VAt return filing system was Best , Full-proof and smooth. Without any restrictions & hassles
An ideal return filling system – GSTR 1 & 3B and A Self declared ITC return GSTR 2
1. GSTR 1 + GSTR 3B + SELF-DECLARED ITC RETURN GSTR 2
Continue with GSTR-3B monthly for ALL and GSTR1 monthly/ quarterly depends on Turnover as per time limit stated above and OPTIONAL IFF monthly for small dealers. Also bring self declared Inward ITC details (i.e say self declared GSTR 2) Which required to be uploaded by Taxpayer along with monthly or quarterly GSTR1. So upload SALES in GSTR 1 & PURCHASE in GSTR 2 & payment of Tax in GSTR 3B. In GSTR 2 , No action required. No matching/ Accepting/ rejecting with Counter party. No time wasting on counter party action . Just upload a list of ITC availed during period. And Based on 1 & 2 , 3B is prepared.
2. Availment of ITC –
As said above, A self declared Inward ITC details to be uploaded (i.e say self declared GSTR-2) same way required to be uploaded by Taxpayer along with monthly or quarterly GSTR1. Above system must be seamlessly smooth as far as ITC is concerned. i.e Without any Restrictions on ITC in Law . No Rule 36(4) , No Section 16(2)(aa) , No GSTR 2B. First , dealers must be allowed to claim full ITC as per Books of Accounts . Seamless ITC is core of GST . Lets not kill the soul .
3. MISMATCH OF ITC –
Concept of ITC PROFILE is not new. There should be System based ITC matching. Mismatch records should be RED flagged on website in “ITC PROFILE “. (Same way Gujarat VAT website used to have ITC PROFILE). ITC PROFILE is a report showing those invoices where counter party has not uploaded his return but You have uploaded in your ITC list i.e in your GSTR 2 . Simple mismatch report automatically prepared by System.. All system based. No time-wasting for Dealers to find out who uploaded & who have not uploaded.
Time to solve the mismatched records should be maximum 6 months (considering quarterly dealers will file their return quarterly) from the due date of particular return where there is mismatch in ITC. For any ITC mismatch, both party should be informed. Auto-email. If still not uploaded by counter party within 6 Month time given then mismatch ITC claimed by the recipient should be PAID in CASH to the government with interest This must be automatic on portal i.e. Liability must be generated automatically online . Auto-reversal.
So in Nutshell , Ideal Return filling SYSTEM would be
Monthly GSTR 3B FOR ALL
+ Monthly GSTR1 (Sales) & Monthly GSTR 2 (Purchase) for 1.5 cr above
+ Quarterly GSTR1 (Sales) & Monthly GSTR 2 (Purchase) with Optional monthly upload of Invoice for 1.5 cr below IFF
+ Reco. of ITC & Reversal if ITC not REFLECTED in ITC profile within 6 months from due date of return where mismatch appearing .
Gujarat VAT RETURN filling was best and still best
Gujarat VAT portal had only 3 returns
201A for uploading sales list in Excel, 201B for uploading ITC list in Excel,
201 Summary return from data of above two .with challan details
An ITC profile on Portal to show matched-Mismatched ITC. System based screening. This was Simple, smooth, instant, System-based, Revenue leakage proof.
Full-proof & solid portal functioning 24*7*365 smoothly