Post GST – Year End Precautions And Compliances

This march ending is going to be very crucial because of changeover from old taxation system to GST regime. Apart from the normal year end practice few additional things will have to be kept in mind while filing the last returns and closing books of accounts.

Refund of Deposit : As all VAT registered assessees have migrated to GST, ensure that you claim the refund of security deposit of Rs 25000 paid at the time of taking  voluntary registration under Maharashtra Value Added Tax.

Books OF Accounts: The Books of accounts should be finalized for  two different periods i.e 01/04/2017 to 30/06/2017 as per the VAT regime & 01/07/2017 to 31/03/2018 as per the GST regime.

Transitional Credit :a) Department is going to scrutinize all the cases of Transitional credits of old taxes taken while migrating to GST regime. The assessee who has claimed Transitional Credit should keep ready following Documents and records :

Copy of six months returns (Jan 17-June 17), Copy of Trans 1, Certified Copy Of invoices with duty paid bills, Certified Copy Of Stock Summary

b)  ensure that the stock as per Trans 1 is in accordance with the finalized books of accounts i.e stock as on 30/06/2017.

c)  check & file Trans 2 before 31/03/2018 for claiming credit against sale of stock for which tax/duty paid documents are not available.

Verification of Purchases/ Input Tax Credit : Though GSTR 2 has been suspended for time being still we can see form GSTR 2A on the GST site i.e monthly purchase from registered dealer. Verify the same with  purchase record & take necessary steps to reconcile with Books.

Reconciliation : Reconcile Sales/ Purchases, GST liability with the GSTR 3B returns. If there are any differences give the effect of same in GSTR 3B of March 2018. Reconcile the cash ledger, credit ledger and liability ledger with  books of accounts. All the entries should be done before the year end. Also debit note, credit note, rate difference, discount, etc also have to be accounted for and effect of the same has to be given in returns.

SME Funding : As the SME Funding will be linked to  GST returns hence ensure that the turnover of exempted & Non GST supplies are also properly reflected in GSTR 3B. Turnover as per books should match with the GST returns.,

Reversal of Input tax credit : As per the rules of Input tax credit, after issuance of tax invoice if receiver does not make the full payment  within 180 days then the credit taken on that invoice is to be reversed. And whenever the payment is made, the receiver can take the credit of the amount. Therefore the aging analysis of the debtors and creditors should be done. All old invoices issued before 1 October, 2017, should be paid before 31 March 2018.

Suppose the fees Rs. 15000 is payable to an Architect on 15 September, 2017, and the credit on that of Rs. 1800 has been taken in the return of that month, then the fees should be paid before 31 March, 2018. Otherwise the extra payment of Rs. 1800 is to be made in the month of March.

HSN Code in the Invoice :  Before preparing first invoice in the new financial year,taxpayers should check the turnover for the year 2017-18. Taxpayers whose turnover is above Rs. 1.5 crores but below Rs. 5 crores shall use 2-digit code and the taxpayers whose turnover is Rs. 5 crores and above shall use 4-digit code. Taxpayers whose turnover is below Rs. 1.5 crores are not required to mention HSN Code in their invoices.

New series for tax invoice :  If anyone wants to change the series for billing in the new year, then he can do that from 1 st April. New numbering should be started form 1st April.

Composition scheme : If any taxpayer wants to register under composition scheme then he can apply in Form GST CMP – 02 before 31st March. Similarly, those who wants to cancel the registration under composition scheme, they have to apply in Form GST CMP – 04 before 7th April. They have to calculate the effects of ITC on closing stock.

Due dates of the returns – There are various due dates in the April month for filing the returns relating to 31^st March. GSTR 3B for March is to be filed up to 20^th  April. GSTR 1 is to be filed by 10th May. GSTR 4 is to be filed by 18 April.

Deciding Monthly/ Quarterly frequency of returns in FY 18-19 – Taxpayers should check the turnover for the year 2017-18. If the aggregate turnover is above Rs. 1.5 Crore then the taxpayers have to file monthly return in FY 2018-19. If the aggregate turnover is below Rs. 1.5 Crore then the taxpayers have an option to file the quarterly GST returns.

Refund – As in Maharashtra VAT, there was a provision of refund for excess input tax credit, there is no such provision in GST law. Excess credit needs to be carried forward compulsorily.

Depreciation on the capital asset –  if ITC has been claimed on purchase of Fixed Assets, then do not include the same in cost of asset for calculating depreciation.

Anti profiteering – Compare the Gross Profit for the Years 16-17, 17-18 and for the period April17 to June 17 and July 17 to March 18. If the gross profit ratio for the March 2018 is higher, then check whether you have passed on the credit to the customer or not ?

Cancellation of Registration under GST : Those who have taken voluntary registrations but now do not want to continue because of lower turnover or closure of business can cancel their registration.

And last but not the least E Way bill is going to be operational with effect from 1^st April. So no more fooling now,  It will be  compulsory to issue E way bill from 1 April, 2018 for inter state transport. In case of inter state supply, if the the goods happens to be  in transit as on 1 April, 2018, it is compulsory to generate e way bill for them. So be prepared to generate E-Way Bill from 1^st April,2018.

Wishing you all a happy year ending and a prosperous new financial year ahead.

(The author can be reached at satishsardanagpur@gmail.com)