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There have been various compliance related relaxations and extension of last dates in relation to GST. Some of them are listed hereunder including other recent amendments. 

Amendment in Rule 36(4) on ITC

 Rule 36(4) of CGST Rules, 2017 has been amended to the following effect:

Before amendment: 

  • The registered person shall be required to claim ITC to the extent of 110% of eligible ITC getting reflected in GSTR-2A of the tax
  • Taxpayer was required to calculate the amount as per the above provision for every tax period before filing of GSTR-3B.

 After amendment:

  • Cumulative calculation of ITC allowed for period of February, March, April, May, June, July and August 2020. Therefore, for the returns furnished in said tax period, condition of Rule 36(4) not be
  • GSTR 3B return for September, 2020 to be furnished after adjustment of cumulative ITC calculated for the said months.

 (Source : Notification No. 35/2020-CT dated 03.04.2020) 

Also Read-Relaxations in GST Compliances Due to Covid 2019- Part 1

Relief provided in respect of certain challenges faced by the registered persons in implementation of provisions of GST laws:

Cancellation of Goods and Services contract

The treatment under GST has been clarified in respect of certain transactions of supply of goods and services when when cancelled for any reason:

Nature of  Supply Original Event Document Issued Trigger Event Treatment under GST
Services Advance


Tax Invoice issued before

supply           of service

Contract cancelled before supply of service (a)  a) Credit note to be issued under section 34 of CGST Act, 2017 for    reduction     of tax liability.

(b)  Details of such credit notes shall be declared in the return for the month during which such credit note has been  issued. There is no need to file a separate refund claim.

(c)  Where there is no output liability against which a credit note can be adjusted, refund  claim allowable under  ‘Excess payment of tax, if any’ through FORM GST RFD-01.

Services Advance Received Receipt voucher Contract cancelled before supply of service Issue refund voucher under GST. Refund claim to be filed by filing FORM GST RFD-01 under the category    ‘Refund   of excess payment of tax’
Goods Goods supplied Tax invoice Goods returned (a)  Credit note to be issued under section 34 of CGST Act, 2017 for    reduction  of tax liability.

(b)  Details of such credit notes shall be declared in the return for the month during which such credit note has been issued.

(c)  There is no need to file a separate refund claim.

(d)  Where there        is no output liability against which a credit note can be adjusted, refund claim allowable under ‘Excess payment of tax, if any’ through FORM GST RFD-01.

Deferment of filinging of refund claim if expiring on 31.03.2020

As per notification No. 35/2020-Central Tax dated 03.04.2020, where the timeline for refund compliances falls during the period from 20.03.2020 to 29.06.2020, the same stand extended till 30.06.2020.

 Due Date extension of deposit of TDS

  • The due date for furnishing of return in FORM GSTR-7 along with deposit of tax deducted during the period from 20.03.2020 to 06.2020 has been extended till 30.06.2020.
  • No interest under section 50 of CGST Act, 2017 shall be leviable if tax deducted is deposited by 30.06.2020.

(Source : Circular No. 137/07/2020-GST dated 13.04.2020)


Form GST PMT-09 has been made available on GST portal and it enables a taxpayer to make intra-head or inter-head transfer of amount available in Electronic Cash Ledger. A taxpayer can file GST PMT 09 for transfer of any amount of tax, interest, penalty, fee or others available under one (major or minor) head to another (major or minor) head in the Electronic Cash Ledger. Form GST PMT 09 provides flexibility to taxpayers to make multiple transfers from more than one Major/Minor head to another Major/Minor head if the amount is available in the Electronic Cash Ledger.

To file Form GST PMT-09, taxpayers are required to log in on GST portal with valid credentials and navigate to Services > Ledgers > Electronic Cash Ledger > File GST PMT-09 for Transfer of Amount option. After Form GST PMT-09 is filed:

  • ARN is generated on the successful filing of Form GSTPMT-09.
  • An SMS and an email is sent to the taxpayer on his registered mobile and email id.
  • Electronic Cash ledger will get updated after successful filing of Form GST PMT- 09.
  • Filed form GST PMT-09 will be available for view/download in PDF

(Source : Notification No.: 37/2020-Central Tax dated 28.04.2020)

Extension of validity of E-way bills

CBIC had vide Notification No. 35/2020 dated 3rd April, 2020 extended the period of validity till 30th April, 2020 for e-way bill validity expires during the period 20th day of March, 2020 to 15th day of April, 2020.

Now CBIC has provided that where an e-way bill has been generated on or before the 24th day of March, 2020 and its period of validity expires during the period 20th day of March, 2020 to the 15th day of April, 2020, the validity period of such e-way bill shall be deemed to have been extended till the 31st day of May, 2020. 

[Source: Notification No. 40/2020- Central Tax dated 05.05.2020] 

Extension of due date of Annual Return & Reconciliation Statement for the FY 2018-19

The time limit for furnishing of the annual return in Form 9 and Reconciliation Statement in Form 9C specified under section 44 of the said Act read with rule 80 of the said rules, electronically through the common portal, for the financial year 2018-2019 has been further extended till the 30th September, 2020. 

[Source: Notification No. 41/2020- Central Tax dated 05.05.2020] 

Verification of filing of Form 3B through EVC

Considering the difficulty faced by registered taxpayers in applying for DSC, CBIC has provided that a registered person registered under the provisions of the Companies Act, 2013 (18 of 2013) shall, during the period from the 21st day of April, 2020 to the 30th day of June, 2020, also be allowed to furnish the return under section 39 in FORM GSTR-3B verified through Electronic Verification Code (EVC) i.e one time password.

New Rule 67A provide for furnishing of NIL return by short messaging service (SMS) to registered person in Form GSTR-3B for a tax period by using the registered mobile number. Nil return would mean a return u/s 39 that has nil or no entry in all tables of Form-3B.

[Source: Notification No. 38/2020- Central Tax dated 05.05.2020] 

Extended due date for GST ITC-04

The due date of filing Form GST-ITC-04 in respect of goods dispatched to a job worker or received from a job worker for the quarter ending March, 2020 which falls due on 25.04.2020 has been extended upto 30.06.2020.

(Source: Notification No. 35/2020-Central Tax dated 03.04.2020;

Circular No. 138/08/2020-GST dated 06.05.2020)

Retrospective Amendment to Section 140 (Transitional Credit)

  • CBIC has appointed 18.05.2020 from which retrospective amendment in Section 140 of the CGST Act, 2017 prescribing the time limits for taking transitional credits as per Section 128 of the Finance Act, 2020 shall come into force.
  • The amendment is made effective retrospectively from 01.07.2017.
  • By virtue of this retrospective amendment , the relief given by various Courts to GST tax payers had been taken away by the Government.

[Source: Notification No. 43/2020 – Central Tax, dated 16.05.2020]


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July 2024