Relaxation in Statutory & Regulatory Compliance of GST

CBIC on 3rd Apr 2020 has issued notification in continuation with press release specifying relaxation for statutory & regulatory compliance in wake of COVID 19 spread, which has halted and restricted regular functioning of business activity. This relaxation is in terms of reduced interest rate and waiver of late fees for submission of various GST returns, however, this waiver is conditional, which are discussed in this note.

CBIC has already issued notification and continued with current filing system of GSTR 3B and GSTR 1 till Sept 30, 20 and deferred implementation of new return system.

Following are area wise relaxation:

1) Return GSTR 3B: Compliance has been divided into 3 categories with different timelines based on turnover of the entity

Sr No Category Feb 20 Mar 20 Apr 20 May 20 June 20 Condition
1 Turnover upto Rs. 1.50 Cr 30th Jun 20 3rd July 20 6th July 20 12/14th July 20 20th July 20 No interest and late if return submitted as revised timeline. Refer note-1 below
2 Turnover > Rs. 1.50 Cr & upto Rs. 5 Cr 29th Jun 20 29th Jun 20 30th Jun 20 12/14th July 20 20th July 20
3 Turnover > Rs. 5 Cr 24th Jun 20 24th Jun 20 24th Jun 20 27th Jun 20 20th July 20 Refer note-2 below


1. There will be no late fees and interest for first 2 categories, if they submit return as per above referred timelines. However, if dealer failed submit return as per above time limit interest and late fees will be applicable, as if there is not extension.

2. In case 3rd category dealer, there will be no late fees and penalty if return is submitted as per above time limit. In case of interest, no liability upto 15 day from due date i.e. in case of Feb 2020 return no interest will be charged upto 4th Apr 2020 and thereafter interest will be charged @ of 9% till submission return as per above timeline.  If dealer fail to submit the return as per above timeline regular interest of 18% will be charged along with late fees.

3. Turnover has to be calculated for preceding financial year.

2) Return GSTR-1: Late fees has been waived as detailed below, subject to submission of return within following revised timeline:

Sr No Compliance Calendar Revised  timeline
1 Mar 20 to May 20  30th Jun 20
2 Quarterly  Return

Jan20 to Mar 20

 30th Jun 20
3 June 20  11th July 20
4 Quarterly Return

Apr 20 to June 20

31st July 20

3) Compliance for Rule 36 (4)- Relaxation in restriction of ITC:

As per rule 36(4) of CGST Rule, ITC in GSTR 3B cannot exceed 10% GSTR 2A, however, Govt has relaxed this condition as below:

i. GSTR 3B Return from Feb 20 to Aug 20 can be submitted by calming ITC as per books, without restriction of Rule 36(4) of CGST Act.

ii. However, GSTR 3B return for Sept 20 has to be submitted after complying Rule 36(4) of CGST Act on cumulative basis for Period Feb 20 to Aug 20.

4) Composition Dealer:

This compliance has been divided into 2 segments as detailed below:

S N From Period Due date
1) Exiting Assess under the scheme
i) GST CMP-08 Jan to Mar 20 7th July 20
ii) GSTR-4 F Y 2019-20 15th July 20
2) New Assesse wish to opt
i) GST CMP-02 F Y 2020-21 30th Jun 20
ii) GST ITC-03  Upto 31st Mar 20 15th Jul 29

5) E-way Bill extension in validity:

E-way which has been expired or expiring its validity during 20th Mar 20 to 15th Apr 20 shall deemed to be expiring on 30th Apr 2020.

6) Other due date due between 20th Mar 20 to 29th Jun 20:

i. Extension to all proceeding/ passing of order or issuance of notice, intimation, notification, sanction or approval or any action by authority, commission or tribunal due under CSGT Act upto 30th June 20.

ii. Extension in filing of appeal, reply or application or furnishing of any report, document, return, statement or any other record under CGST Act upto 30th Jun 20.

iii. Extension of in submission of TDS/TCS return, submission of ISD return and return by non-resident and causal taxable person upto 30th Jun 20.

iv. However, this extension is not applicable for issue of tax invoice, date of registration, validity of registration of causal taxable person & non-resident taxable person.

Relaxation in interest and late fees as notified in submission of due returns for period of Feb 20 to May 20 is subject to condition of submission of return in revised timeline, failure of which will lead to paying regular interest and late fees.

It is also clarified by CBIC that there no extension of due date for submission return, but extra period is granted without burden of interest, late fees & penalty.

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Qualification: CA in Practice
Company: C A H & Associates
Location: Pune, Maharashtra, IN
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October 2020