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Arjuna (Fictional Character): Krishna, monsoon has arrived in India with all it’s glory. Similarly it’s raining in GST, with downpour of various notifications and circulars by CBIC after 35th GST Council meeting in the Month of June 19, what are they about?

Krishna (Fictional Character): Arjuna, change in season is always refreshing, let us see whether these issuance of notifications and circulars bring change of season for taxpayers as well:

The monsoon breeze comes with circular on Post sales discount:

  • Post sale discount given by the supplier to the dealer would not be included in value of supply, if there is no obligation or action to be taken on the part of dealer. But it would be included if discount is like post-sale incentive. For eg., If dealer on behalf of supplier exhibits goods in exhibition and in consideration to it gets additional discount then this will be supply of service by the dealer and is taxable. Hence distinction between pre agreed discount and post-sale additional discount need to be taken care of.
  • Additional discount given by supplier to the dealer for offering goods at special reduced price to it’s customer to increase sales would be taxable, as this is not pre sales discount. This is light showering clarification.
  • ITC claimed need not be reversed if above pre sales discount is provided by way issuance of financial credit/debit note i.e. no tax impact has been given. This is welcome clarification.

Rainbow in GST with the extension of due dates: 

  • The due date for filing of annual return and GST Audit Report has been extended to 31st August 2019.
  • The due date for GSTR-7 (Oct 18 to Jul 19) and GST ITC-04 (Jul 17 to Jun 19) has been extended to 31st August 2019.
  • Date for filing GSTR-1 by registered person having t/o up to Rs. 1.5 Cr has been extended to 31st October, 2019 for the returns of month of Jul 19 to Sept 19.
  • Date for filing GSTR-1 by a registered person having t/o above Rs. 1.5 Cr for the months of Jul 19 to Sept 19 is 11th day of the succeeding month.
  • Date for filing GSTR-3B for the months of Jul 19 to Sept 19 is 20th day of the succeeding month.

Umbrella of GST: Inter-head adjustment of the tax wrongly paid

As umbrella protect from rain similarly Form GST PMT-09 has come to allow inter head adjustment of wrong payment of tax, interest, penalty, etc. for eg. If taxpayer has made payment in the head CGST instead of SGST then he can make the inter head adjustment by filing form GST PMT 09. 

As the monsoon arrives late, Late expected changes have been made in GSTR-9 are:

Earlier GSTR-9 require to report amendments from April to September, 2018 but the law has allowed amendment till March, 2019 same has been changed in GSTR-9.

  • The persons now registering under GST can provide bank details within 45 days from registration earlier it was to be provided at the time of registration.
  • As rain brings relief to farmers similarly relief has been brought for the composition dealers under GST by way of filing only one annual return GSTR 4. Further quarterly payments are required to be made by filing CMP-08.

Arjuna: Krishna, what should one learn from this?

Krishna: Arjuna, as rain washes away the dirt similarly issuance of notifications and circulars in GST has washed away doubts by bringing in the clarity on certain issues. Monsoon season is the pleasant season and now let’s see how these amendments prove pleasant to taxpayers. As the rain has not yet arrived, similarly some amendments are yet to be notified.


Published by

CA Umesh Sharma
Category GST   Report

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