Actionable Items for FY 2020-21 before September 2021 returns [Rohit Kumar]



Update Category Key Actionable Items for FY 2020-21 before September 2021 returns
Update Source GST Laws, Clarifications and Circulars
Release No. TM/GST/132 dated 30th August, 2021

Taxpayers under regular category are filing GSTR 1 and GSTR 3B to report their transactions. GSTR 1 is for reporting of details of outward supplies including amendments if any and GSTR 3B is for reporting summary transactions for payment of taxes and claiming ITC.

Transactions relating to the tax period April 2020 to March 2021 may be rectified while filing returns for September 2021 (Due date for filing GSTR 3B for September 2021 is 20th / 22nd / 24th October 2021). No additional claim of missing ITC may be made available post filing of September 21 returns. You may lose the right to claim any eligible ITC which appears in your books of accounts and not claimed till filing of September 2021 GSTR 3B return.

Action to be taken before on or before filing returns for September 2021 -

  1. Reconcile ITC appearing in GSTR 2A/2B with Inward Register

  2. Claim missing ITC not appearing in Purchase Register

  3. Follow up with suppliers who have not reported invoice details for sales made to you

  4. Reconcile if invoices raised to customers are reported in B2B (customers with GSTIN) or in B2C (URD customers)

  5. Reconcile turnover reported matches with Books of Account as well as GSTR1/3B

  6. Issue any pending credit notes pertaining to taxable outward supplies

We have prepared various scenarios wherein taxpayers may have erred in furnishing details in returns for 2020-21 and methodology to rectify the same in GSTR 1 or GSTR 3B of September 2021 Returns which is fast approaching.

Sl. No. Issue Type Return Type Action to be taken in GST Returns Table Reference in GST Returns
1 Missed to disclose domestic taxable outward supply transaction GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Disclose the domestic taxable outward supply transaction in GSTR-1 to be filed for September 2021 4A, 4B, 4C, 6B, 6C - B2B
5A, 5B - B2CL
7 - B2CS
GSTR-3B Add taxable turnover and tax liability in GSTR-3B to be filed for Sept’ 2021 along with Interest 3.1 (a) - Outward Taxable Supplies (Other than Zero Rated, NIL and Exempted)
2 Missed to disclose export outward supply transaction in GST Returns pertaining to any of the tax period April 2020-March 2021.

Missed to update shipping bill & port code details for export transactions disclosed in the GST Returns during the period April 19-March 2020
GSTR-1 Disclose the export outward supply transaction in GSTR-1 to be filed for September 2021
Amend the export transaction with shipping bill details & port code
6A - Exports
9A - B2B, B2CL & Exports Amendment
GSTR-3B Add taxable turnover and tax liability in GSTR-3B to be filed for Sept’ 2021 along with Interest 3.1 (b) - Outward Taxable Supplies (Zero Rated)
3 Missed to disclose Debit Note / Credit Note transaction in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Disclose the CN/DN transaction in GSTR-1 to be filed for September 2021 9B - CNDN (B2B, B2CL & Exports)
GSTR-3B Adjust CNDN taxable value and tax liability in GSTR-3B to be filed for September 2021 3.1 (a) & 3.1 (b)
Sl. No. Issue Type Return Type Action to be taken in GST Returns Table Reference in GST Returns
4 Missed to disclose advance tax liability (for supply of goods)  in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Disclose the advance tax liability in GSTR-1 to be filed for September 2021 11A (1) - Advance Tax Liability
GSTR-3B Add advance value and tax liability in GSTR-3B to be filed for September 2021 3.1 (a) & 3.1 (b)
5 Missed to adjust advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Adjust the tax liability in GSTR-1 to be filed for September 2021 11B (1) - Adjustment of Advances
GSTR-3B Adjust advance value and tax liability in GSTR-3B to be filed for September 2021 3.1 (a) & 3.1 (b)
6 Incorrectly disclosed advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Adjust the advance tax liability in GSTR-1 to be filed for September 2021 11A - Advance Tax Liability
7 Incorrectly adjusted advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Correct the advance tax liability adjustment in GSTR-1 to be filed for September 2021 11B - Advance Tax Liability
8 Furnished incorrect Tax Invoice / CNDN No., Tax Invoice / CNDN Date, POS, Customer GSTIN, Tax Rate, Tax Amount, Taxable Value & Invoice Value in GST Returns pertaining to the outward supply transaction for the period April 2020-March 2021 GSTR-1 Amend the tax invoice / CNDN document with correct details as mentioned on the Tax Invoice in GSTR-1 to be filed for September 2021 9A - B2B, B2CL & Exports Amendment
9C - CNDN Amendment
10 - B2CS Amendment
GSTR-3B Adjust the taxable turnover & tax liability to the extent of correction in GSTR-3B t be filed for September 2021 3.1 (a) & 3.1 (b)
9 Missed or incorrectly disclosed outward nil rated, exempt & non-GST supply in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-1 Add / correct outward nil rated, exempt & non-GST supply figures in GSTR-1 to be filed for September 2021 8A, 8B, 8C & 8D - Nil Rated, Exempt & Non-GST Supply
GSTR-3B Add / correct outward nil rated, exempt & non-GST supply figures in GSTR-3B to be filed for September 2021 3.1 (c) & 3.1 (e)
10 Missed or incorrectly disclosed inward nil rated, exempt & non-GST supply in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-3B Add / correct inward nil rated, exempt & non-GST supply figures in GSTR-3B to be filed for September 2021 5 - Inward Nil Rated, Exempt & Non-GST Supply
11 Missed or incorrectly disclosed RCM taxable value & tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-3B Add / correct RCM taxable value & tax liability figures in GSTR-3B to be filed for September 2021 3.1 (d)
12 Missed to avail eligible ITC in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-3B Avail missed ITC in GSTR-3B to be filed for September 2021 4A - ITC Available (B2B, RCM, Import)
Sl. No. Issue Type Return Type Action to be taken in GST Returns Table Reference in GST Returns
13 Availed excess ITC in GST Returns pertaining to any of the tax period April 2020-March 2021 GSTR-3B Adjust the excess claimed ITC in GSTR-3B to be filed for September 2021 4A - ITC Available (B2B, RCM, Import)
14 Missed to reverse ITC on account of non-payment to suppliers within 180 days from the date of invoice during the period April 2020-March 2021 GSTR-3B Reverse proportionate ITC to the extent of non-payment to the suppliers beyond 180 days from the date of the invoice in GSTR-3B to be filed for September 2021 4B (2) - Other Reversal
15 Missed to reverse ITC on account of partly exempt / non-GST and partly taxable supplies in GST Returns during the period April 2020-March 2021 GSTR-3B Reverse proportionate ITC as per the calculation u/r 42 & 43 of CGST Rules 2017 in GSTR-3B to be filed for September 2021 4B (1) - Reversal as per Rule 42 & 43
16 Missed to disclose Ineligible ITC in GST Returns during the period April 2020-March 2021 GSTR-3B Disclose in-eligible ITC in GSTR-3B to be filed for September 2021 4D - In-eligible ITC
17 Missed to discharge interest liability on account of delay in payment of tax or reversal of ITC claimed in excess in GST Returns during the period April 2020-March 2021 GSTR-3B Disclose interest liability in GSTR-3B to be filed forSeptember 2021 5.1 - Interest & Late Fees
18 Excess reversal of ITC in GST Returns during the period April 2020-March 2021 GSTR-3B Avail wrongly reversed ITC in GSTR-3B to be filed for September 2021 4A - ITC Available (B2B, RCM, Import)

Note – You may reach out to us for carrying out an assessment for evaluating unclaimed ITC or reconciling any discrepancy in books Vs. GST Returns.

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