Key Actionable Items for FY 2019-20 before September 2020 returns

Rohit Kumar Singh , Last updated: 09 September 2020
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Taxpayers under regular category are filing GSTR 1 and GSTR 3B to report their transactions. GSTR 1 is for reporting of details of outward supplies including amendments if any and GSTR 3B is for reporting summary transactions for payment of taxes and claiming ITC.

Transactions relating to the tax period April 2019 to March 2020 may be rectified while filing returns for September 2020 (Last date to file GSTR 3B for September 2020 is 20th October 2020). No additional claim of missing ITC may be made post filing of September 20 returns. You shall lose the right to claim any eligible ITC which appears in your books of accounts.

Key Actionable Items for FY 2019-20 before September 2020 returns

Action to be taken before on or before filing returns for September 2020 -

Reconcile ITC appearing in GSTR 2A with Inward Register
Claim missing ITC not appearing in Purchase Register
Follow up with suppliers who have not reported invoice details for sales made to you
Reconcile if invoices raised to customers are reported in B2B (customers with GSTIN) or in B2C (URD customers)
Reconcile turnover reported matches with Books of Account as well as GSTR1/3B
Issue any pending credit notes pertaining to taxable outward supplies

We have prepared various scenarios wherein taxpayers may have erred in furnishing details in returns for 2019-20 and methodology to rectify the same in GSTR 1 or GSTR 3B of September 2020 Returns which is fast approaching.

Sl. No.	Issue Type	Return Type	Action to be taken in GST Returns	Table Reference in GST Returns
1	Missed to disclose domestic taxable outward supply transaction GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Disclose the domestic taxable outward supply transaction in GSTR-1 to be filed for September 2019	4A, 4B, 4C, 6B, 6C - B2B 5A, 5B - B2CL 7 - B2CS
1		GSTR-3B	Add taxable turnover and tax liability in GSTR-3B to be filed for September 2020	3.1 (a) - Outward Taxable Supplies (Other than Zero Rated, NIL and Exempted)
2	Missed to disclose export outward supply transaction in GST Returns pertaining to any of the tax period April 2019-March 2020. Missed to update shipping bill & port code details for export transactions disclosed in the GST Returns during the period April 19-March 2020	GSTR-1	Disclose the export outward supply transaction in GSTR-1 to be filed for September 2020 Amend the export transaction with shipping bill details & port code	6A - Exports 9A - B2B, B2CL & Exports Amendment
2		GSTR-3B	Add taxable turnover and tax liability in GSTR-3B to be filed for September 2020	3.1 (b) - Outward Taxable Supplies (Zero Rated)
3	Missed to disclose Debit Note / Credit Note transaction in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Disclose the CN/DN transaction in GSTR-1 to be filed for September 2020	9B - CNDN (B2B, B2CL & Exports)
3		GSTR-3B	Adjust CNDN taxable value and tax liability in GSTR-3B to be filed for September 2020	3.1 (a) & 3.1 (b)
4	Missed to disclose advance tax liability in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Disclose the advance tax liability in GSTR-1 to be filed for September 2020	11A (1) - Advance Tax Liability
4		GSTR-3B	Add advance value and tax liability in GSTR-3B to be filed for September 2020	3.1 (a) & 3.1 (b)
5	Missed to adjust advance tax liability in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Adjust the tax liability in GSTR-1 to be filed for September 2020	11B (1) - Adjustment of Advances
5		GSTR-3B	Adjust advance value and tax liability in GSTR-3B to be filed for September 2020	3.1 (a) & 3.1 (b)
6	Incorrectly disclosed advance tax liability in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Adjust the advance tax liability in GSTR-1 to be filed for September 2020	11A - Advance Tax Liability
7	Incorrectly adjusted advance tax liability in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Correct the advance tax liability adjustment in GSTR-1 to be filed for September 2020	11B - Advance Tax Liability
8	Furnished incorrect Tax Invoice / CNDN No., Tax Invoice / CNDN Date, POS, Customer GSTIN, Tax Rate, Tax Amount, Taxable Value & Invoice Value in GST Returns pertaining to the outward supply transaction for the period April 2019-March 2020	GSTR-1	Amend the tax invoice / CNDN document with correct details as mentioned on the Tax Invoice in GSTR-1 to be filed for September 2020	9A - B2B, B2CL & Exports Amendment 9C - CNDN Amendment 10 - B2CS Amendment
8		GSTR-3B	Adjust the taxable turnover & tax liability to the extent of correction in GSTR-3B t be filed for September 2020	3.1 (a) & 3.1 (b)
9	Missed or incorrectly disclosed outward nil rated, exempt & non-GST supply in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-1	Add / correct outward nil rated, exempt & non-GST supply figures in GSTR-1 to be filed for September 2020	8A, 8B, 8C & 8D - Nil Rated, Exempt & Non-GST Supply
9		GSTR-3B	Add / correct outward nil rated, exempt & non-GST supply figures in GSTR-3B to be filed for September 2020	3.1 (c) & 3.1 (e)
10	Missed or incorrectly disclosed inward nil rated, exempt & non-GST supply in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-3B	Add / correct inward nil rated, exempt & non-GST supply figures in GSTR-3B to be filed for September 2020	5 - Inward Nil Rated, Exempt & Non-GST Supply
11	Missed or incorrectly disclosed RCM taxable value & tax liability in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-3B	Add / correct RCM taxable value & tax liability figures in GSTR-3B to be filed for September 2020	3.1 (d)
12	Missed to avail eligible ITC in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-3B	Avail missed ITC in GSTR-3B to be filed for September 2020	4A - ITC Available (B2B, RCM, Import)
13	Availed excess ITC in GST Returns pertaining to any of the tax period April 2019-March 2020	GSTR-3B	Adjust the excess claimed ITC in GSTR-3B to be filed for September 2020	4A - ITC Available (B2B, RCM, Import)
14	Missed to reverse ITC on account of non-payment to suppliers within 180 days from the date of invoice during the period April 2019-March 2020	GSTR-3B	Reverse proportionate ITC to the extent of non-payment to the suppliers beyond 180 days from the date of the invoice in GSTR-3B to be filed for September 2020	4B (2) - Other Reversal
15	Missed to reverse ITC on account of partly exempt / non-GST and partly taxable supplies in GST Returns during the period April 2019-March 2020	GSTR-3B	Reverse proportionate ITC as per the calculation u/r 42 & 43 of CGST Rules 2017 in GSTR-3B to be filed for September 2020	4B (1) - Reversal as per Rule 42 & 43
16	Missed to disclose Ineligible ITC in GST Returns during the period April 2019-March 2020	GSTR-3B	Disclose in-eligible ITC in GSTR-3B to be filed for September 2020	4D - In-eligible ITC
17	Missed to discharge interest liability on account of delay in payment of tax or reversal of ITC claimed in excess in GST Returns during the period April 2019-March 2020	GSTR-3B	Disclose interest liability in GSTR-3B to be filed for September 2020	5.1 - Interest & Late Fees
18	Excess reversal of ITC in GST Returns during the period April 2019-March 2020	GSTR-3B	Avail wrongly reversed ITC in GSTR-3B to be filed for September 2020	4A - ITC Available (B2B, RCM, Import)