As per Notification 17/2017 of Central Tax major changes have been introduced in the way GSTR-3B is to be filed. This article will bring out important points of this Notification as they related to filing of GSTR-3B.
GSTR-3B is not in lieu of GSTR-3
Earlier Rule 61(5) specified that GSTR-3B is to be filed in lieu of GSTR-3. Which meant that if you are filing GSTR-3B, you need not file GSTR-3.
The words 'in lieu of' have been removed in the amended Rule 61(5). This means
• A tax payer has to file GSTR-3B
• A tax payer also has to file GSTR-3
GSTR-3B can be filed by two means
Amended Rule provide for filing of returns
Auto Generation of GSTR-3
A new rule 61(6) provides that once GSTR-3B has been filed, GSTR-3 will be auto-generated by GSTN.
• GSTR-3 will be generated after due date for furnishing GSTR-2
• Part A of GSTR-3 will be auto-generated based on information provided in
GSTR1 and GSTR2 Other liabilities of preceding tax periods
• Part B of GSTR-3 will be auto-generated based on information provided in GSTR-3B
Discrepancy between GSTR-3 and GSTR-3B
Tax liability in GSTR-3 and GSTR-3B will be matched and
• If tax liability in GSTR-3 is higher than what is declared in GSTR-3B, tax payer will have to modify Part B of GSTR-3 and discharge the shortfall in liability
• If tax liability in GSTR-3 is less than what is declared in GSTR-3B, the surplus will be credited to electronic credit ledger of the taxpayer.
Due date for July 2017 Filing
|GST Return Type||Purpose||Due Date/Date for filing|
|GSTR-3B for July||Consolidated Return and Payment for the month of July||20th August 2017|
|GSTR-1 for July||Outward Supplies||1st to 5th September, 2017|
|GSTR-2 for July||Inward Supplies||6th to 10th September, 2017|
|GSTR-3 for July||Summary return based on GSTR-1, GSTR-2 and GSTR-3B||11th to 15th September, 2017|
Due date for August 2017 Filing
|GSTR-3B for August||Consolidated Return and Payment for the month of August||20th September 2017|
|GSTR-1 for August||Outward Supplies||16th to 20th September, 2017|
|GSTR-2 for August||Inward Supplies||21st to 25th September, 2017|
|GSTR-3 for August||Summary return based on GSTR-1, GSTR-2 and GSTR-3B||26th to 30th September, 2017|
Relevant Rules reproduced
61(5) Where the time limit for furnishing of details in FORM GSTR-1 under section 37 and in FORM GSTR-2 under section 38 has been extended and the circumstances so warrant, return in FORM GSTR-3B, in lieu of FORM GSTR-3, may be furnished in such manner and subject to such conditions as may be notified by the Commissioner.
61(5) Where the time limit for furnishing of details in FORM GSTR-1 under section 37 and in FORM GSTR-2 under section 38 has been extended and the circumstances so warrant, the Commissioner may, by notification, specify that return shall be furnished in FORM GSTR- 3B electronically through the common portal, either directly or through a Facilitation Centre notified by the Commissioner.
New Rule Inserted
61(6) Where a return in FORM GSTR-3B has been furnished, after the due date for furnishing of details in FORM GSTR-2 :
(a) Part A of the return in FORM GSTR-3 shall be electronically generated on the basis of information furnished through FORM GSTR-1, FORM GSTR-2 and based on other liabilities of preceding tax periods and PART B of the said return shall be electronically generated on the basis of the return in FORM GSTR-3B furnished in respect of the tax period;
(b) the registered person shall modify Part B of the return in FORM GSTR-3 based on the discrepancies, if any, between the return in FORM GSTR-3B and the return in FORM GSTR-3 and discharge his tax and other liabilities, if any;
(c) where the amount of input tax credit in FORM GSTR-3 exceeds the amount of input tax credit in terms of FORM GSTR-3B, the additional amount shall be credited to the electronic credit ledger of the registered person.
The author is a veteran entrepreneur and has spent the last two decades working in the field of compliance automation. He can also be reached at @dktejwani.