Due to COVID-19 pandemic and challenges faced by taxpayers, Government has extended date for GST filings, return lower or nil Interest, Late fee & Penalty for Regular & Composite Taxpayers. I have prepared an article regarding various changes in Goods & Service Tax. This article provides summary of major changes from the inception of Lock down to till notification come on 27.05.2020 under GST portal due to COVID 19. The below article is meant for reference purpose only.
EXTENSION IN FILING OF DUE DATE OF VARIOUS RETURN (AS PER Notification No. 30/2020 Dated 03.04.2020, Notification No. 31/2020 Dated 03.04.2020, Notification No. 32/2020 Dated 03.04.2020, Notification No. 33/2020 Dated 03.04.20 AND Notification No. 36/2020 Dated 03.04.2020)
1. NATURE OF RETURN – GSTR – 3B (FOR REGULAR TAX PAYER)
| Case | Month | Due Date | Revised Due date | Interest | Penalty & Late fees |
| Turnover Less Than Rs. 1.5 Crores | February, 2020 | 22/24.03.20 | 30.06.2020 | No Interest levied if returns have been filed on or before the revised due dates | Not Payable if return is filed before revised due date |
| March, 2020 | 22/24.04.20 | 03.07.2020 | |||
| April, 2020 | 22/24.05.20 | 06.07.2020 | |||
| May, 2020 | 22/24.06.20 | 12/14.07.20 | |||
| Turnover More than Rs. 1.5 crore but up to Rs. 5 crore | February, 2020 | 22/24.03.20 | 29.06.2020 | No Interest levied if returns have been filed on or before the revised due dates | Not Payable if return is filed before revised due date |
| March, 2020 | 22/24.04.20 | 29.06.2020 | |||
| April, 2020 | 22/24.05.20 | 30.06.2020 | |||
| May, 2020 | 22/24.06.20 | 12/14.07.20 | |||
| More than Rs. 5 crores | February, 2020 | 20.03.2020 | 24.06.2020 | No interest till 15 days from ORIGINAL DUE DATE and @ then 9% till revised due date | Not Payable if return is filed before revised due date |
| March, 2020 | 20.04.2020 | 24.06.2020 | |||
| April, 2020 | 20.05.2020 | 24.06.2020 | |||
| May ,2020 | 20.06.2020 | 27.06.2020 |
2. NATURE OF RETURN – GSTR – 1 (FOR REGULAR TAX PAYER)
| Case | Month | Due Date | Revised Due date | Interest | Penalty & Late fees | |
| Turnover Less Than Rs. 1.5 Crore (QUATERLY) | January, 2020 | 30.04.2020 | 30.06.2020 | Not Applicable | Not Payable if return is filed before revised due date | |
| February, 2020 | ||||||
| March, 2020 | ||||||
| April, 2020 | 31.07.2020 | Not yet extended | Levied as per prevailing law | |||
| May, 2020 | ||||||
| June, 2020 | ||||||
| Turnover More than Rs. 1.5 crore (MONTHLY) | March, 2020 | 11.04.2020 | 30.06.2020 | Not Applicable | Not Payable if return is filed before revised due date | |
| April, 2020 | 11.05.2020 | 30.06.2020 | ||||
| May 2020 | 11.06.2020 | 30.06.2020 | ||||
Source:
https://taxguru.in/goods-and-service-tax/gst-composition-scheme-fy-2020-21-opted-30-06-2020.html
https://taxguru.in/goods-and-service-tax/gst-interest-rate-timely-filing-form-gstr-3b.html
https://taxguru.in/goods-and-service-tax/cbic-extends-due-date-furnishing-gstr-3b-2020-month.html
3. COMPLIANCES FOR COMPOSITION TAXPAYERS (AS PER NOTIFICATIONS NO 34/2020 DATED 03.04.20)
| Nature | Particulars | Month | Due Date | Revised Due date | Interest | Penalty & Late fees |
| GST- CMP-08 | A statement, containing the details of payment of self-assessed tax | January, 2020 | 18.04.20 | 07.07.20 | No relief has been granted so far, so the same will be levied as per prevailing law. | |
| February, 2020 | ||||||
| March, 2020 | ||||||
| GSRT-4 | Annual Return | F.Y.2019-20 | 30.04.20 | 15.07.20 | ||
NORMAL TAXPAYERS WANTING TO OPT FOR COMPOSITION SHOULD NOT FILE GSTR3B AND GSTR 1 FOR ANY TAX PERIOD OF FY 2020-21 FROM ANY OF THE GSTIN ON THE ASSOCIATED PAN
| Nature | Period | Revised Due date |
| GST CMP-02 | F.Y. 2020-21 | 30.06.2020 |
| GST ITC-03 | F.Y. 2019-20 | 31.07.2020 |
Source: https://www.gst.gov.in/newsandupdates/read/369
4. EXTENSION IN VARIOUS DUE DATE OF GST (AS PER NOTIFICATIONS NO 35/2020 DATED 03.04.2020)
| Form No | Filed by | Month | Due Date | Revised Date |
| GSTR-5 | Non Resident Taxpayers | March, 2020 | 20.04.2020 | 30.06.2020 |
| April, 2020 | 20.05.2020 | |||
| May, 2020 | 20.06.2020 | |||
| GSTR-6 | Input Service Distributors | March, 2020 | 13.04.2020 | 30.06.2020 |
| April, 2020 | 13.05.2020 | |||
| May, 2020 | 13.06.2020 | |||
| GSTR-7 | Tax Deductor at Source (TDS deductor) | March, 2020 | 10.04.2020 | 30.06.2020 |
| April, 2020 | 10.05.2020 | |||
| May, 2020 | 10.06.2020 | |||
| GSTR-7 | Tax Deductor at Source (TDS Collector) | March, 2020 | 10.04.2020 | 30.06.2020 |
| April, 2020 | 10.05.2020 | |||
| May, 2020 | 10.06.2020 |
Source: https://taxguru.in/goods-and-service-tax/due-date-gst-compliance-validity-e-way-bills.html
5. EXTENSION IN VALIDITY OF E-WAY BILL (AS PER NOTIFICATIONS NO NOTIFICATIONS NO 35/2020 DATED 03.04.20 & 40/2020 DATED 05.05.2020)
| Extension No | Particulars | Valid till |
| 1st extension | e-way bill has been generated under rule 138 of the Central Goods and Services Tax Rules, 2017 and its period of validity expires during the period 20th day of March, 2020 to 15th day of April, 2020 | Validity period of such e-way bill shall be deemed to have been extended till the 30th day of April, 2020 |
| 2nd extension | 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 | Validity period of such e-way bill shall be deemed to have been extended till the 31st day of May, 2020 |
Source:
https://taxguru.in/goods-and-service-tax/due-date-gst-compliance-validity-e-way-bills.html
https://taxguru.in/goods-and-service-tax/cbic-extends-validity-e-way-bills-31-05-2020.html
6. CBIC NOTIFIES EFFECTIVE DATE FOR RULE 87(13) & FORM GST PMT09 (AS PER NOTIFICATIONS NO 37/2020 DATED 28.04.2020)
- CBIC notifies 21.04.2020 as the date from which Rule 87(13) of CGST Rules & Form GST PMT-09 will come into effect.
- With effect from 21.04.2019, a registered person may, on the common portal, transfer any amount of tax, interest, penalty, fee or any other amount available in the electronic cash ledger under the Act to the electronic cash ledger for integrated tax, central tax, State tax or Union territory tax or cess in FORM GST PMT-09.
- PMT 09 is the prescribed challan for shifting the wrongly paid ITC. If you have paid a wrong tax, like CGST in place of SGST, you can shift it using this challan. 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
- After Form GST PMT-09 is filed
- ARN is generated on the successful filing of Form GSTPMT-09.
- An SMS and an email are 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:
https://taxguru.in/goods-and-service-tax/cbic-notifies-effective-date-rule-8713-form-gst-pmt09.html
https://www.gst.gov.in/newsandupdates/read/375
7. VERIFICATION OF FILING OF FORM GSTR – 3B RETURN THROUGH ELECTRONIC VERIFICATION CODE (EVC) (AS PER NOTIFICATIONS NO 38/2020 DATED 05.05.2020)
| Nature of Form | Period from -to | Mode of Verification |
| GSTR-3B | Period from the 21st day of April, 2020 to the 30th day of June, 2020 | Electronic Verification Code (EVC) |
Amendment in Sec 67A of the Rule
A registered person who is required to furnish a Nil return under section 39 in FORM GSTR-3B for a tax period, any reference to electronic furnishing shall include furnishing of the said return through a short messaging service using the registered mobile number and the said return shall be verified by a registered mobile number based One Time Password facility.
Source: https://taxguru.in/goods-and-service-tax/gstr-3b-nil-return-sms-companies-file-evc.html
8. FRESH GST REGISTRATION FOR POST APPOINTMENT OF IRP/RP (AS PER NOTIFICATIONS NO 39/2020 DATED 05.05.2020)
With effect from 21.03.2020, the said class of persons shall, with effect from the date of appointment of IRP / RP, be treated as a distinct person of the corporate debtor, and shall be liable to take a new registration (hereinafter referred to as the new registration) in each of the States or Union territories where the corporate debtor was registered earlier, within thirty days of the appointment of the IRP/RP or by 30th June, 2020, whichever is later.
Source: https://taxguru.in/goods-and-service-tax/gst-registration-compulsory-post-appointment-irp-rp.html
PROCEDURE FOR REGISTRATION OF IRP/RP IN THE GST PORTAL (DATE 27.05.2020)
- IRP/RP should select the Reason for Registration as “Corporate Debtor undergoing the Corporate Insolvency Resolution Process with IRP/RP” from the drop down menu.
- The date of commencement of business for IRP/RPs will be the date of their appointment. Their compliance liabilities will also come into effect from the date of their appointment.
- IRP/RP shall be the Primary Authorized Signatory for the newly registered Company.
- Details as specified in original registration of the Corporate Debtors are required to be entered in the Principal Place of business/ Additional place of business.
- The new registration application shall be submitted electronically on GST Portal under DSC of the IRP/RP.
IN CASE WHERE IRP/RP CHANGED
| Sl. No | Case | Remarks | Who will Change |
| A | After Initial Appointment | No fresh Registration would be required for authorized Person. The same would be deemed to be change of authorized signatory. | a) The change in Primary Authorized Signatory details on the portal can be done either by the authorized signatory of the Company.
OR b) By the concerned jurisdictional officer (if the previous authorized signatory does not share the credentials with his successor) on request of IRP/RP. |
| B | During the CIRP Process | The change in the GST system may be carried out by a non- core amendment in the registration form. |
Source: https://www.gst.gov.in/newsandupdates/read/377
9. EXTENSION OF DUE DATE OF ANNUAL RETURN & RECONCILIATION STATEMENT FOR THE FY 2018-19 (AS PER NOTIFICATIONS NO 41/2020 DATED 05.05.2020)
| Relevant Section/ Rule | Form No | Particular | F.Y. | Extended date | Mode of filing |
| Section 44 of the said Act read with rule 80 of the said rules | Form 9 | Annual Return | 2018-19 | 30.09.2020 | electronically |
| Form 9C | Reconciliation Statement | 2018-19 | 30.09.2020 |
10. REVISED DUE DATE OF FILING OF GSTR-3B FOR UNION TERRITORY OF JAMMU & KASHMIR & LADAKH (AS PER NOTIFICATIONS NO 42/2020 DATED 05.05.2020)
| Name of Union Territory | Month | Revised Due Date |
| Jammu & Kashmir | November, 2019 | 24.03.2020 |
| December, 2019 | ||
| January, 2020 | ||
| February, 2020 | ||
| Ladakh | November, 2019 | 24.03.2020 |
| December, 2019 | ||
| January, 2020 | 20.05.2020 | |
| February, 2020 | ||
| March, 2020 |
Source: https://taxguru.in/goods-and-service-tax/revised-gstr-3b-due-dates-ut-jk-ladakh-notified.html
11. AMENDMENT TO SECTION 140 OF THE CGST ACT I.E. TRANSITIONAL CREDIT (AS PER NOTIFICATIONS NO 43/2020 DATED 05.05.2020)
- Central Government has been appointed from 18.05.2020 for retrospective amendment in Section 140 of the CGST Act, 2017 prescribing the time limits for taking transitional credits, as per provisions of section 128 of the said Act.
- Section 140 of the CGST Act, 2017 has been amended with retrospectively from 01.07.2017 (i.e. starting date of GST Act)
Source: https://taxguru.in/goods-and-service-tax/amendment-section-140-cgst-act-notified-wef-18-05-2020.html
12. ADVISORY ON OPTING-IN FOR COMPOSITION SCHEME FOR 2020-21 – EXTENSION OF DATES IN VIEW OF COVID-19 PANDEMIC
Due to COVID-19 pandemic and challenges faced by taxpayers, Government has extended dates for opting for composition scheme by normal taxpayers, for the financial year 2020-21. These are notified in Notifications 30/2020 Central Tax, dated 03.04.2020. Circular No. 136/06/2020-GST dated 3rd April, 2020 has also been issued
Existing Normal taxpayers who want to opt for Composition Scheme in Financial Year 2020-21 may note following changes
1. Revised date to file Form GST CMP 02
Normal and registered taxpayers who want to opt in for Composition in FY 2020-21 can apply in Form GST CMP-02 by 30th June 2020.
2. No GSTR 1 or 3B must be filed in 2020-21 financial year for associated PAN
The taxpayers should not file any GSTR-1/GSTR-3B, for any tax period of FY 2020-21, from any of the GSTIN on the associated PAN, or else they will not be able to opt for composition scheme for FY 2020-21.
3. No need for re-opting for the composition scheme
The taxpayers who are already in composition scheme, in previous financial year are not required to opt in for composition again for FY 2020-2021.
4. Revised date to file Form GST ITC 03
Form GST ITC-03 to reverse ITC for the stock in hand at the time of transition can be filed till 31st July, 2020.
5. Modification in earlier advisory date 18.02.2020
The advisory issued on 18.02.2020 and available on GST Portal (click here for the link https://www.gst.gov.in/newsandupdates/read/356) stands modified to above extent.
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