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NEW GST Return Form -SAHAJ

In the 37th Council Meeting, held on 20th September 2019, it was decided by the GST Council that the New GST Returns shall be implemented from April 2020. These new GST forms, initially, were supposed to be implemented from September 2018.

However, taking into consideration the representations and difficulties faced in the current system, such decision for extension was made so that the businesses and tax professionals may adapt to the new version of returns during the proposed trial period. The New GST Forms will replace the existing GST returns, i.e. GSTR 3B, GSTR 1 and GSTR 2A.

New GST Return Forms -

Understanding new GST SAHAJ Form in detail

The New GST Return forms are designed on the original concept on which GST implementation was conceptualized. New forms applicability is dependent on whether the registered taxpayer is a small taxpayer or a large taxpayer.

Large taxpayer, whose turnover exceeds INR 5 crores, has to file Form GST Ret 01 on a monthly basis mandatorily. Small taxpayers, who are below or up to INR 5 crores can opt for monthly or quarterly filing. Small taxpayers can opt for Form GST RET 01 (Normal return) or Form GST RET 02 (Sahaj) or Form GST RET 03 (Sugam).

New GST Return forms consists of Form GST ANX-1, Form GST ANX-2, Form GST RET 01 /02/ 03 and Form GST PMT-08.

Large taxpayers and small taxpayers opting for monthly filing have to upload Form GST ANX-1, Form GST ANX-2 and Form GST RET-01 on a monthly basis. Small taxpayer, those opting for quarterly filing, have an option to choose from Form GST RET-01/ 02/ 03. These taxpayers have to file Form GST ANX-1, FORM GST ANX-2 and FORM GST RET-01/ 02/ 03 on a quarterly basis. Further, they have to make payment of liability for the first two months of the quarter through FORM GST PMT-08.

Let us now understand Form GST RET-02 SAHAJ in detail.

Any registered person opting to file quarterly return Form GST RET 02, shall also have to upload FORM GST ANX-1, FORM GST ANX-2 and file Form GST PMT 08. For such taxpayers, all the forms will be in simplified format when compared to other returns (Form GST RET 01 / 03).

Those opting to file a return under Form GST RET 02 Sahaj, can declare details only for supplies made to an unregistered person (B2C) and inward supplies attracting a reverse charge.

Form GST ANX-1 -

- This form contains details of all liabilities.

- Under Sahaj, a taxpayer can provide details only concerning outward supplies made to an unregistered person and inward supplies attracting a reverse charge.

- These details may be uploaded at any time during the quarter (24*7).

- However, details cannot be uploaded from 23rd to 25th of the month following the month in which the quarter ends.

- Also, any prior period details may be at any time subject to such details shall be declared before the due date of filing September return of next financial year or filing of annual return (GSTR 9) for the relevant financial year whichever is earlier.

- It is optional for the taxpayer to mention HSN details.

- In case of inward supplies liable to reverse charge, PAN details of unregistered person may be disclosed.

- Supplies may be disclosed net of debit note and credit notes.

- Negative values for supplies shall be accepted.

- Advances received shall not be reported in this form.

Table wise details of Form GST ANX-1 -

  1. Financial year and Tax period for which the details are to uploaded
  2. GSTIN of the registered person
  3. Legal name and trade name of the registered person
  4. ARN, i.e. Acknowledgement Receipt Number shall be generated after the return is filed along with the date of filing of return.
  5. Table 3A - details of outward supplies made to an unregistered person (B2C). Amount declared there shall be net of debit note or credit note. The details shall be classified based on the place of supply and tax rate.
  6. Table 3H - Details of inward supplies liable to reverse charge. Amount declared there shall be net of debit note or credit note. Adjustments for advances paid may also be made.

Form GST ANX-2 -

- Form GST ANX-2 contains details of documents uploaded by the supplier from whom purchases are made.

- The registered taxpayer has to take action on such documents uploaded by his supplier.

- The registered taxpayer can take action by marking the invoices as accept. Pending or reject. Under Accept - he agrees with the details of documents uploaded,

Pending - it is undecided whether to accept or reject, this marked as pending until more clarity is received
Reject - he denies the document. It may be due to various reasons like incorrect details, value, tax rate etc.

- Any document marked as pending will be reflected in the next period for further action to be taken.

- Actions in Form GST ANX-2 may be taken after 10th month following the month for which the details are uploaded.

- Accepted documents cannot be amended by the supplier.

- Summary of the amount of total available credit for accepted documents, credit on pending documents and credit on rejected documents shall be available in Table 4 of Form GST ANX-2.

Form GST RET-02 -

- It is the primary return where final tax liability is determined.

- It is to be filed in the month following the month in which the quarter ends.

- Details of advance received and advance adjusted may be directly reported here.

- Nil rated, exempt, non-GST supply may be made by the registered supplier, but no disclosure of the same can be made anywhere if one opts to file a return under Form GST RET-02.

- Scope for making transitional adjustments have been provided

- Details from Form GST ANX-1 and Form GST ANX-2 will be auto captured.

- Details of reversals, ineligible ITC shall have to be manually updated.

- In this form, bifurcation of Input tax credit available into ITC on capital goods and input services is not required.

 

Form GST PMT-08 -

- This form is to be filed for the first two months of the quarter to discharge tax liability.

- Details of tax payable, input tax credit availed, tax paid and net tax paid is to be declared.

- Due date of filing Form GST PMT-08 is 20th of the month following the month to which the liability pertains.

Limitation of Form GST ANX-2 -

- Details of any supply other than that to an unregistered supplier cannot be declared.

- Thus, supplies made to registered persons (B2B), exports, SEZ, deemed exports, e-commerce operators cannot be declared.

- Details of missing documents for a supplier cannot be updated in Form GST ANX-1.

 

- Details of nil rated, exempt and Non-GST supplies cannot be declared.

Final Verdict -

A registered payer shall opt for quarterly filing under Form GST RET-02, only if he is sure that there will be no other form of supply other than that to an unregistered person/consumer (B2C).

To simplify the GST filing process under new returns, one must opt for a GST filing software for ease and time saving as 5 forms are required to be uploaded or filed for every quarter which will be 20 forms for a year in addition to annual return (GSTR 9) and reconciliation statement (GSTR 9C).

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