FCMA Sawinder Singh Chug

fcma-sawinder-singh-chug

GST system is getting smooth affair day by day. It still faces many challenges. One is where to show nil rated supply in GSTR1.  This issue is not highlighted till date.

GSTR-1 is a monthly or quarterly return that should be filed by every registered dealer. It contains details of all outward supplies. The return is divided into 13 sections.

Table 1, 2 & 3: Details of GSTIN and aggregate turnover in preceding year.

Table 4: Taxable outward supplies made to registered persons (including UIN-holders) other than Zero rated supplies and Deemed Exports.

Table 5: Taxable outward inter-State supplies to un-registered persons where the invoice value is more than INR 2.5 Lakh.

Table 6: Details of Zero rate supplies and Deemed Exports.

Table 7: Details of Taxable supplies (Net of debit notes and credit notes) to unregistered persons other than the supplies covered in Table 5.

Table 8: Details of Nil rated, exempted and non GST outward supplies.

Table 9: Details of debit notes, credit notes, refund vouchers issued during current period and any amendments to taxable outward supply details furnished in the GSTR1 returns for earlier tax periods in Table 4, 5 & 6.

Table 10: Details of debit note and credit note issued to unregistered person.

Table 11: Details of Advances Received/Advance adjusted in the current tax period or Amendments of information furnished in earlier tax period.

Table 12: HSN-wise summary of outward supplies.

Table 13: Documents issued during the tax period.

The thrust of this article is difficulties faced by return preparer while showing nil rated supply.

Suppose registered dealer A has sold goods  worth Rs. 100000/-  to registered dealer B. The category of goods is nil rated. Now as law, it should be shown in Table 8. If it is shown here then it is shown here as consolidated figure for the period for one month or three month as the case may be. No details regarding GST registration number of purchaser & name is mentioned here.  So purchaser cannot match his nil rated purchases with his seller. This is somewhat cumbersome.

Now come to second example.

If registered dealer A has sold goods worth Rs. 100000/-(nil rated) & Rs. 50000/-(5% category) in one invoice to Dealer B.   Now how dealer A will show his supply in Table 8 as some supply of same invoice includes sales that is to be shown in Table 4(Sale to registered dealer).

Now he will show all the sales in Table 4 as it also includes 0% supplies. So now nil rated supply is shown in Table 4 instead of Table 8, which is contradictory. Table 4 & table 8 both are designed to show sale to registered dealer under nil rated category.

Same is the case of sale to unregistered dealer(B2C Sale).  Nil rated supply can be shown both in Table 5/7 & Table 8 in case of B2C.

I invite members here to share their knowledge & experience in this regard.

(Author is a Practicing Cost Accountant and can be reached at  cma.sschug@gmail.com)

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2 Comments

  1. RANGA RAO says:

    Since the goods are NIL rated and no ITC is available, it may be disclosed in Table 8 only. If it is disclosed in both Table 4 and 8, in Annual return the same amounts appears in Table 4B as well as in Table 5E, which amounts to double value of supplies

    1. Feby Mathew says:

      The issue would not have arised if Exempted supplies were prevented in B2B & B2C Invoices. Instead it should have been specifically required of the suppliers that its bill shall only be made by using “Bill of supply” in which case inconsistency in GSTR1, GSTR3B & GST9 etc could have been avoided.

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