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GST Compliance relief pursuant to 2nd Wave of Covid-19

Rohit Kumar Singh , Last updated: 03 May 2021  
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The Central Board of Indirect Taxes and Customs (CBIC) has issued notifications under GST Laws to implement certain relief measures in view of the outbreak of the 2nd Wave of Covid-19 and lockdown in various States.

Summary of Compliance Relaxation in GST Regime issued on 1st May 2021

  • No late fees for filing GSTR 3B for Mar/April - up to 15 days and 30 days from the original due date for a taxpayer with turnover more than 5 Cr and up to 5 Cr resp. For the quarter ending 31st Mar, no late fees if GSTR 3B filed by 30 days from the original due date
  • Composition (GSTR-4) - extended to 31st May and Job Work Return (ITC-04) - extended to 31st May for the Jan-Mar quarter
  • GSTR-1 due date for April'21 extended to 26th May and IFF due date extended to 28th May.
  • Relaxation in Interest Payment for the month of March 21 & April 21 (See details)
GST Compliance relief pursuant to 2nd Wave of Covid-19

Table depicting a summary of waiver of late fees and Interest for GSTR 1, GSTR 3B and GSTR 4

A. Turnover Exceeding Rs 5 Crores in preceding FY (Monthly) - GSTR 3B

Month

Date without late fees

NIL Interest

9% Interest

18% Interest

March 2021

5th May 2021

Not Applicable

If filed till 5th May

Filed post 5th May

April 2021

4th June 2021

Not Applicable

If filed till 4th June

Filed post 4th June

B. Turnover up to Rs 5 Crores in preceding FY (Monthly) - GSTR 3B

Month

Date without late fees

NIL Interest

9% Interest

18% Interest

March 2021

20th May 2021

If filed till 5th May

6th May to 20th May

Filed post 20th May

April 2021

19th June 2021

If filed till 4th June

5th June to 19th June

Filed post 19th June

C. Turnover up to Rs 5 Crores in preceding FY (Quarterly - QRMP Scheme) - GSTR 3B

Quarter

Date without late fees

NIL Interest

9% Interest

18% Interest

Jan - Mar 2021 (Cat 1 States)

22nd May 2021

Till 7th May 2021

8th May to 22nd May

Filed post 22nd May

Jan - Mar 2021 (Cat 2 States)

24th May 2021

Till 9th May 2021

10th May to 24th May

Filed post 24th May

D. Waiver of late fees for filing of GSTR 1, IFF and GSTR 4

Return

March 2021

April 2021

 

GSTR 1

NA

26-05-2021

 

IFF

NA

28-05-2021

 

GSTR 4 (Quarterly)

31st May 2021

NA

 
           
 

Summary of the relaxation in compliance and other measures is presented in a lucid manner for easy understanding

A. Notification No - 08/2021- Central Tax dated 01-05-2021 - Waiver/Lower Rate of Interest for Delay in Filing of GSTR 3B (Notification to come into force with effect from 18th April 2021) and Notification No - 09/2021-Central Tax dated 01-05-2021 - Waiver of late fees for delay in Filing of GSTR 3B (Notification to come into force with effect from 20th April 2021)

S. No

Turnover

Rate of Interest %

Tax Period

Waiver of Late fees

1

Taxpayers having an aggregate turnover of more than rupees 5 crores in the Previous FY

First 15 Days from Due date - 9%

On and from 16th Day - 18%

Mar’21 and Apr’21

No late fees if the return is filed within 15 days from the due date of furnishing the return

2

Taxpayers having an aggregate turnover up to rupees 5 crores in the Previous FY

First 15 Days from Due date - NIL

Next 15 days - 9%

18% thereafter

Mar’21 and Apr’21

No late fees if the return is filed within 30 days from the due date of furnishing return

3

Taxpayers having an aggregate turnover up to rupees 5 crores in the Previous FY (IFF)

First 15 Days from Due date - NIL

Next 15 days - 9%

18% thereafter

Mar’21 and Apr’21

No late fees if the return is filed within 30 days from the due date of furnishing return

4

Taxpayers having an aggregate turnover up to rupees 5 crores in the Previous FY (Quarterly Return - QRMP)

First 15 Days from Due date - NIL

Next 15 days - 9%

18% thereafter

Quarter Ending Mar’21

No late fees if the return is filed within 30 days from the due date of furnishing return

 

i. Manner of calculation of interest for taxpayers filing monthly Return (aggregate turnover above Rs. crores)

Illustration: Calculation of interest for delayed filing of return for the month of April 2021 (due date of filing being 20.05.2020) may be illustrated as per the below Table:

Sl. No

Actual date of filing GSTR 3B

Delay in Days

Interest Applicable

Liability

(in Rs)

Interest to be paid (Year = 365 days)

1

01.06.2020

12

9% for the first 15 days

Rs 1,00,000

296

2

19.06.2020

30

9% for the first 15 days

Then 18% p.a. thereafter

Rs 1,00,000

1,110 (Rs 370 for 15 days and Rs 740 for the next 15 days)

ii. Manner of calculation of interest for taxpayers having aggregate turnover up to Rs. 5 Cr.

Example - The calculation of interest in respect of this class of registered persons for delayed filing of return for the month of April 2021 (for registered persons for whom the due date of filing was 20.05.2020)

Sl. No

Actual date of filing GSTR 3B

Delay in Days

Interest Applicable

Liability

(in Rs)

Interest to be paid (Year = 365 days)

1

01.06.2020

12

NIL for the first 15 days

Rs 1,00,000

0 (NIL)

2

24.06.2020

35

Nil for the first 15 days

9% for the next 15 days

Then 18% p.a. thereafter

Rs 1,00,000

617 (NIL for the first 15 days, Rs 370 for 15 days and Rs 247 for the next 5 days)

Similar Notification has been issued under IGST Act and UT GST Act - Notification No. 01/2021 - Integrated Tax and Notification No. 01/2021 - Union Territory Tax both dated 1st May 2021

B. Notification No - 10/2021-Central Tax dated 01-05-2021 - Extension of the due date of furnishing FORM GSTR-4 for Financial Year ending 31st March 2021 (For Composition Dealers) and Notification No - 11/2021-Central Tax dated 01-05-2021 - Extension of the due date of furnishing FORM GST ITC 04 for the Quarter ending 31st March 2021 (For Job Work) -

Sl. No

Category

Form Name

Period

Revised Due Date

1

Composition Dealer

GSTR 4

Financial Year 2020-21

31st May 2021

2

Job Work

ITC 04

Quarter Jan 21 to Mar 21

31st May 2021

C. Notification No - 12/2021-Central Tax dated 01-05-2021 - Extension of the due date of furnishing FORM GSTR-1 for the month April 2021

Sl. No

Category

Form Name

Period

Revised Due Date

1

Registered Persons

GSTR 1

April 2021

26th May 2021

D. Notification No - 13/2021-Central Tax dated 01-05-2021 - CGST (Third Amendment) Rules, 2021 -

Following major changes are made in CGST Rules, 2017 -

Cumulative application of Rule 36(4) of CGST Rule, 2017 for April and May 2021 ( ITC availment based on GSTR 2A) -

A proviso has been entered in sub-rule (4) of rule 36 of the CGST Rules which is to be checked cumulatively for the tax period April 2021 and May 2021. Any adjustment for the said periods shall be made in Return in Form GSTR 3B to be furnished for the month of May 2021.

Extension of Due Date for furnishing invoice details using Invoice Furnishing Facility (IFF) for April 2021 (Rule 59) -

A registered person may furnish such details, for the month of April 2021, using IFF from the 1st day of May 2021 till the 28th day of May 2021

Extension of Time limit for Issuance of notice, filing of appeal, furnishing of returns, completion of proceedings, etc. - 14/2021-Central Tax dated 01-05-2021 -

Sl. No.

Particulars

Original Date

Revised Date

1

Completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, by whatever name called

15th April 2021 to 30th May 2021

31st May 2021

2

Filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called

15th April 2021 to 30th May 2021

31st May 2021

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Published by

Rohit Kumar Singh
(Founder - TaxMarvel Consulting Services LLP)
Category GST   Report

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