Summary of GST Notifications issued on 9th Oct 2019

Notification No. 44/2019 – Central Tax – dated 09/10/2019

As the rollout of new returns has been postponed, notification has been issued for the filing of GSTR – 3B for the months of Oct 2019 to March 2020. The date of filing of GSTR – 3B is 20^th of the next month.

Notification No. 45/2019 – Central Tax – dated 09/10/2019

As the rollout of new returns has been postponed, notification has been issued for the filing of GSTR– 1 for the taxpayers having turnover less than Rs 1.50 Crs and opted for quarterly filing of returns is

 Notification No. 46/2019 – Central Tax – dated 09/10/2019

As the rollout of new returns has been postponed, notification has been issued for the filing of GSTR – 1 for the taxpayers whose turnover is more than Rs 1.50 crs and the filing returns monthly basis for the period from Oct 2019 to March 2020. The due data for filing of the GSTR – 1 is 11^th of the next month.

Notification No. 47/2019 – Central Tax – dated 09/10/2019

Basis on the outcome of the 37^th GST Council, for taxpayers whose turnover is less that Rs 2.00 crores during the financial years 2017-18  and 2018-19 are given an option to file the annual or return or not. In case if the taxpayer opts for not filing of the annual return, then it is deemed that the taxpayer has filed the return.

Notification No. 48/2019 – Central Tax – dated 09/10/2019

Due date for filing of returns for the taxpayers in the state of Jammu & Kashmir

Notification No. 49/2019 – Central Tax – dated 09/10/2019

Issue of Invoices/Debit Notes during the period of suspension of Registration

Explanation has been added that when the GST Registration is in suspension status, during this period the taxpayers cannot issue any tax invoices or debit notes.

Matching for claiming Input Tax Credit

Though the new return formats have been deferred to next financial year, the Government has introduced the Matching concept indirectly through the insertion of Sub-Rule (4) in Rule 36, that the taxpayers can claim input tax credit to the extent of 20% of the matched invoices. This means that, the recipient can claim only 20% of the input tax credit of the invoices which are uploaded by suppliers in their GSTR – 1’s.

Example – say the taxpayer has an inward supplies of Rs 25,000 during the month from three different suppliers A, B & C for an invoices of Rs 10,000 by A, Rs 10,000 by B and Rs 5,000 by C and assuming the tax rate is 10%, the recipient can claim Input tax credit of Rs 2,500 and the same is being claimed in GSTR – 3B.

Assuming that Supplier A & C have only filed their GSTR – 1, then the amount reflected in GSTR – 2A of the recipient is only Rs 15,000.

As per the new provisions, the recipient can claim only 120% of Rs 15,000 i.e. Rs 1,800 only.

This means the recipient has to pay Rs 700 in cash, which means additional requirement of working capital.

So, going forward, the taxpayers have to follow up or chase their suppliers for filing of the GSTR – 1 by the due date else they will be facing liquidity crunch.