The GSTR-1 filing schedule of Taxpayers whose turnover is above Rs.1.5 Crores is hectic that the GSTR-1 for the months of July, August, September and October must be filed within December 31. This means most of the companies will be required to file 3 GSTR-1 within a span of 31 days from now. To add insult to injury the November month GSTR-1 must be filed by January 10. So we have just 10 days per return. So in this hurry, there are certain niggles to which attention is required. Certain issues which are trivial for Quarterly return filers for which they should not strain and certain issues for which taxpayers whose turnover is greater than 1.5 Crores must heed special attention to.
Exempted and Nil rated Supplies
There is a widespread confusion regarding where the Exempted and nil rated supplies must be disclosed. Whether in B2B Column with 0% Tax rate or in table 8. The 'FAQ and User Manual Returns offline tool' clarifies on this. It says that only B2CS transactions must be shown in Table 8 if there is any B2B nil rated or exempted supply it must be shown in B2B column only. There is also a confusion regarding what is nil rated and what is exempted. Any item for which Rate of tax is mentioned as '0' in GST tax rate booklet in CBEC portal is Nil rated. In short, all nil rated supply are exempted but all exempted supply is not nil rated. In recent offline tool version 2.1 you cannot fill table 8 in excel offline tool you need to furnish this information to the portal.
There has been widespread rumours that taxpayers having turnover less than Rs.1.5 Crores need not furnish information in table 12. But it is absolutely wrong. Every one having turnover below Rs.1.5 Crore or above it need to furnish this detail. The taxpayers having turnover below Rs.1.5 Crore need not furnish the HSN Codes but they too must enter the description of goods, the value and quantity supplied and the amount of tax paid on such goods. The digits of HSN Code to be furnished is governed by Notification no. 12/2017 Central tax. Though the return can be filed without entering the details. It is advisable to furnish details as asked by the government to avoid future compliance burdens. Relaxed return filing will definitely lead to tensed Audits.
Sale In Course of Export (Previously Form H sales)
The government has issued a notification on 23rd October that Sale in Course of Export shall be taxed at 0.01%. But till now the feature to enter line items at this rate of tax in B2B Table 4 is not enabled. The Portal is not ready for this amendment!! :P . So we need to wait to file GSTR-1 for the month of October and November if we have supplies of this nature.
If you are a taxpayer who want Rebate on tax paid on export. You must be very cautious in entering details in table 6 because the Portal now practices the concept of matching your shipping bill number provided in this table with customs data to provide the rebate of duty paid on filling Table 6A of Form GSTR-1. So please be cautious while furnishing information in this table.
Certain information to be filled online only
The Return filing offline tool Version 2.1 does not give the taxpayers option to fill Documents issued table 13 and exempted nil rated supply table 8 in excel utility. The taxpayers must log into the portal to fill these details online.
Supply through E-Commerce
Some business supply goods through E-Commerce If supplies are made through E-Commerce the transactions shall be divided as B2B, B2CS and B2CL. In all these transaction E-Commerce GSTIN must be given and the respective sheets shall be filled in offline utility. But E-Commerce has not been issued for a while. In such cases ignore the E-Commerce GSTIN field this field will be significant when the TDS and TCS sections are notified, till then this will not be an issue.
Matching P&L and GSTR-1 and GSTR-3B
All those expenses and incomes except provisions and fluctuation reserves must be shown in GSTR-1 and GSTR-3B. it will be a good practice if taxpayers maintain Reconciliation of P&L for every month with amounts entered in GSTR-1 and GSTR-3B.
These issues discussed above will not have any tax implication, but for the smooth filing of returns and when department comes for the audit they expect the taxpayer to file returns in such fashion as explained above.