Key GST Compliances for Year-End: Deadlines & Requirements

As the financial year ends, businesses must ensure GST compliance across various aspects. Those opting for the Composition Scheme must file CMP-02 by March 31. GST registration details, including business locations and directors, should be updated. Invoice-related tasks include verifying e-invoicing for B2B transactions and ensuring proper documentation for reverse charge mechanism (RCM) supplies. Reconciliation of sales turnover, credit notes, and input tax credit (ITC) with GST returns is crucial. ITC must match GSTR-2B, with any unclaimed credits adjusted before November 30 of the following year. Businesses should also verify reverse charge liabilities, payments to vendors within 180 days, and GST dues on other income and asset sales. Exporters need to renew their Letter of Undertaking (LUT) for tax-free exports, while businesses eligible for GST refunds should apply within two years. ITC-04 must be filed half-yearly or annually based on turnover. Critical deadlines include filing GSTR-9C for past financial years by March 31, 2025, and availing interest and penalty waivers for notices related to 2017-20 tax periods by the same date. From April 1, 2025, separate ISD registration is mandatory for distributing ITC across multiple GST registrations. The hotel industry must declare specified premises by March 31, 2025, to maintain a fixed tax rate. Businesses should ensure proper documentation, compliance with notices, and adherence to statutory deadlines to avoid penalties.

THINGS TO KEEP IN MIND UNDER GST FOR YEAR END

A. Registration

• If the Registered person / eligible taxpayer wishes to opt for Composition Scheme under GST, then it can be done online in common portal by filing Form CMP-02 before 31^st March of the financial year.
• Review that all the new place of business (if any) or closed business place (if any) have been incorporated in the GST Registration Certificate or not. If not, amend the GST registration certificate on an immediate basis.
• Review Director details and other details in the registration, if amendment required, then do the amendment.

B. Invoice Related

• Whether E-invoicing / IRN has been generated [E-invoicing applicable for turnover more than 5 crores] for all the B to B invoices, export invoices, Debit Note [DN] & Credit Note [CN].
• Whether all the amendments have been made in the invoices by way of CN / DN.
• Documentation required for supplies received from unregistered persons(RCM):

a) Self-invoice to be made; if not done, then ITC claimed on the RCM may be questioned in the assessments / audit by the department.

b) Payment voucher to be made for all the payments made to the RCM vendors whether registered or not.

C. GST Returns and Books of Accounts

• It is being advised to reconcile Sales Turnover, Credit Notes, Output tax as per Books of Accounts with GST Returns filed (GSTR-1 & GSTR-3B) for the current year till date.
• Reconcile any difference between GSTR-1 & GSTR-3B filed as well as with turnover in the books of accounts and reason of such differences should be known to the registered taxable person (RTP) so that they can present their case at the time of audit / assessment.
• It is being advised to reconcile Input tax credit (ITC) as per Books of Accounts with ITC claimed in GSTR-3B subject to matching of ITC with GSTR-2B downloaded from the GST portal.
• Reconcile GSTR-2B with ITC claimed in GSTR-3B as well as ITC in Books of Accounts within 30^th November of following year so that any missed ITC / excess claim of ITC be considered in the GSTR-3B till 30^th November of the following year.
• If any ITC is not claimed in GST returns while reconciling GSTR-2B, the registered person is eligible to avail such ITC within 30^th November of the following year or the due date of filing of Annual Return, whichever is earlier.
• Review ineligible and blocked ITC in the books of accounts and check whether any ineligible / blocked ITC have been inadvertently claimed in the GST returns. If yes, reverse the same.
• Review any liability under reverse charge as per books of accounts that whether such reverse charge liability have been shown in the GSTR-3B or not and whether their payment have been made or not. If any RCM liability is pending, then pay the same along with the appropriate interest.
• After payment of the reverse charge liability, review whether it has been claimed in the GSTR-3B or not.
• Any output tax liability missed or any credit notes missed in regard to the other income in GSTR-1 & GSTR-3B may be taken in the coming months’ GST return or till November of the following year;
• It is being advised to review the payment to the vendor within 180 days from the date of invoice, if not, then ITC needs to be reversed. Once, the payment is made to the vendor, then ITC can be reclaimed without any time limit as per the GST laws.
• Ensure whether GST has been paid on the other income (leviable to GST) and on sale of assets (if any). If not, pay GST along with the interest.

D. Other Important Points

• Every registered exporter who wishes to export goods or services without payment of IGST shall apply for renewal of LUT (Letter of Undertaking) at the end of financial year, for the next F.Y. 2023-24 in order to continue their export of goods or services.
• Ensure to file the GST refund application (if any) within 2 years as specified in GST laws.
• File ITC-04 on Half-yearly basis for the registered persons whose aggregate turnover is more than Rs. 5 crores and on yearly basis for those whose aggregate turnover is upto Rs. 5 crores.
• Check whether the accounts as well as documents / records have been kept as required under the GST laws.

E. MOST IMPORTANT POINTS

• Check whether GSTR-9C [Reconciliation Statement- required for turnover more than 5 crores] for the period from F.Y. 2017-18 to F.Y. 2022-23 has been filed or not. If not filed, then file before 31^st March, 2025 without any late fees. Thereafter, late fees shall be applicable.
• Check if there is any notice or order from the GST department for the case related to period Y. 2017-18 to 2019-20, pay tax before 31^st March, 2025 to avail the benefit of waiver of interest and penalty if notice or order issued u/s 73. Last date to file waiver form i.e. SPL-01/ SPL-02 is 30^th June, 2025. Therefore, please pay tax first to avail the waiver scheme benefit i.e. within 31.03.2025.
• e.f. 01.04.2025, separate ISD registration is mandatory for distributing common ITC across multiple GST registrations.
• For the Hotel Industry, the taxpayer has the option to declare the specified premises under the new compliance guidelines within 31^st March 2025 Please note the rate of tax will remain the same for whole of the year in such case.

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