Indirect tax returns under Proposed GST regime – Key Takeaways

· Every registered dealer required to file the return even if turnover is NIL.

· UN Agencies need to file the return only in the month of Purchases.

· Govt. agencies, PSU, others etc exclusively dealing in NIL/Non GST Goods/Exempted goods or services would neither required to take registration and nor required to file the returns.

· 8 forms are proposed in GST regime, (GSTR 1 to GSTR 8). Separate forms are prescribed for different assesses depending upon the nature of registration of the dealer e.g. normal dealer, compounding dealer, casual dealer, non-resident dealer etc.

· B2B transactions and B2C transactions, required to be shown separately in outward supply return (Form GSTR 1).

· For B2B transactions, Invoice wise specified details require will be uploaded in the return. Whereas, in case of B2C supplies, invoice wise specified details are required to be submit for every invoice having value > Rs. 250k, and for invoice below 250K consolidated state wise summary is proposed to submit.

· HSN codes and service accounting codes will be used for providing the description of goods or services.

· Outward details (GSTR 1) of supplier will get auto populate in the inward details (GSTR 2) of purchaser. Both GSTR 1 and GSTR 2 will auto populate in the consolidate sales and purchase return (GSTR 3).

· Return can be file either directly on GSTN portal or through offline utility. If filed from portal tax payable will automatically debited from the balance available in the ITC ledger or cash ledger maintain at dealer login on the portal and acknowledgment is generated instantly. If filed through offline utility acknowledgment will be generated after some days after cross checking the tax payment and ITC utilization.

· GSTN will also facilitate periodic (may be daily, weekly etc.) upload of information to avoid last minute load on portal.

· Separate column to provide the details of credit note and debit note. It is mandatory to mention the original invoice number and date against which such CN/DN is issued.

· There is no provision of revising the return. Error can be rectified in the future returns. Liability, if raised due correction of error shall auto populate along with the interest and penalty if any in the return in which such error is rectified.

· Return can be submitted without paying applicable taxes, but such return shall be a defective return and purchaser will not get the credit till the time supplier get deposit the taxes.

· All the Normal taxpayers would be required to submit Annual Return. A separate reconciliation statement, duly certified by a Chartered Accountant, will have to be filed by those taxpayers who are required to get their accounts audited under Section 44AB of Income Tax Act, 1961 (i.e. Tax Audit).

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