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30 points of proposed New GST Returns !

CA Umesh Sharma , Last updated: 08 April 2020  
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Arjuna (Fictional Character): Krishna, GST Council had approved the basic principles of GST return design in its 27th meeting. So, what would you say about that?

Krishna (Fictional Character): Arjuna, GST Council approved the key features and new format of the GST returns. They have asked about the suggestions in this format. Along with that the salient features of the new return format also provided. Now taxpayers file GSTR 3B, GSTR 1 etc returns. But onwards GST PMT, GSTR (Main), GSTR SAHAJ, GSTR SUGAM and annexures of sales and purchases would be filed.       

Arjuna: Krishna, What are the key features of the proposed monthly return?   

Krishna: Arjuna, In new returns, very much importance is given to Invoice Uploading. following are the key features of the proposed monthly return :

  1. Monthly Return and due-date : All taxpayers excluding a few exceptions shall file one monthly return. The due date for filing of return by a large taxpayer shall be 20th of the next month.
  2. Nil return: Taxpayers who have no purchases, no output tax liability and no input tax credit to avail in any quarter of the financial year shall file one NIL return for the entire quarter. SMS facility also available to file the NIL return.
  3. Continuous uploading and viewing: There would be facility for continuous uploading of invoices by the supplier anytime during the month and such uploaded invoice shall be continuously visible to the recipient. Only uploaded invoice would be a valid document for availing input tax credit.
  4.  Invoice uploaded but return not filed: In cases where no return is filed after uploading of the invoices by the supplier, recovery proceedings shall be initiated against him.
  5. Missing invoice reporting: Missing invoices shall be reported by the supplier in the main return for any tax period with interest or penalty as applicable.
  6. Offline IT Tool: An IT tool/facility for matching of the invoices downloaded in XL format from the viewing facility, with the invoices stored in the accounting software by the taxpayer (recipient), shall be provided.
  7. Recovery of input tax credit: There shall not be any automatic reversal of input tax credit at the recipient’s end where tax has not been paid by the supplier
  8. Locking of invoices: Facility for locking of invoice by the recipient before filing of the return by him shall be available
  9. Rejected invoices: Recipient shall report the rejected invoices in the return.
  10. Pending invoices: Pending invoices shall be reported by the recipient and no input tax credit shall be availed by the recipient on such pending invoices
  11. Amendment of invoices: Amendment of an invoice may be carried out by the supplier where input tax credit has not been availed and the invoice has not been reported as locked by the recipient
  12. Payment of tax: Liability declared in the return shall be discharged fully at the time of filing of the return by the supplier.
  13. HSN: The details of HSN shall be captured at four digit or more in a separate table in the regular monthly return.
  14. Return format: The main return shall have two main tables, one for reporting supplies on which tax liability arises and one for availing input tax credit
  15. Amendment return: To address the problem of human error, there would be a facility for filing of amendment return
  16. Amendment of missing invoices: Amendment of missing invoices reported later by the supplier shall be carried out through the amendment return of the relevant tax period to which the invoice pertains
  17. Negative Liability: Negative liability arising from the amendment return shall be carried forward as negative liability in the regular return of the next tax period.
  18. Payment due to amended liability: Payment would be allowed to be made through the amendment return as it will help save interest liability for the taxpayer
  19. Monthly Accounting: Monthly liabilities shall be shown to the taxpayer on common portal.
  20. Exports: A separate facility for uploading shipping bill details at a later date shall be provided to the exporters.
  21. Transmission of data to ICEGATE: Once the information of S/B is completed, the entire data shall be transmitted to the ICEGATE
  22. Integrated flow of information: input tax credit on imports and supplies from SEZ shall be availed on self-declaration basis.
  23. Profile based return: a questionnaire shall be used to profile the taxpayer and only such part of return shall be shown to him which are relevant to his profile.
  24. Purchase information in the annual return: Invoices of ineligible ITC will have to be reported separately in the Annual return.
  25. Suspension of registration: From the date of suspension to the date of cancellation of registration, return would not be required to be filed.

Arjuna: Krishna, What are the key features of the proposed quarterly return?

Krishna: Arjuna, following are the key features of the proposed quarterly return:

26. It is proposed to provide facility for the filing of quarterly return and monthly payment to small taxpayers, who had a turnover upto Rs. 5 Cr. in the last financial year.

27. Option for filing monthly or quarterly return shall be taken from these small taxpayers at the beginning of the year

28. Two simplified quarterly returns “Sahaj” (only B2C outward supplies) and “Sugam” (both B2B and B2C outward supplies) are proposed.

29. These small taxpayers would continue to pay taxes on a monthly basis by using Payment declaration form for payment of monthly taxes

30. The benefit of this simplification would be the lower Compliance cost for small taxpayers

Arjuna: Krishna, What lesson the taxpayer should take from this?

Krishna: Arjuna, The new returns system is depending upon three words i.e UPLOAD – LOCK – PAY, The government has brought this format to simplify the return procedure. This simplified return includes the salient features of the new return format and business process for the information of trade and industry and other stakeholders. Also, the government has asked about the suggestions upto 31st August 2018 on www.mygov.in 

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CA Umesh Sharma
(Partner)
Category GST   Report

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