GST late registration: How to pay GST for earlier invoices

Dear Sir/Madam,

I am a self-employed professional, offering business consultancy services. In the FY 2020-21, I have exceeded 20L threshold in the month of December 2020. I got my registration in Mar 2021. From Dec 2020 to the point I got my GST registration, I have nearly 6L invoices done and got paid. After obtaining the GST registration, in the month of Mar 2021, I have invoiced 3.5L, for which I made proper GST invoices.

After researching a while, I came to understand that I now need to pay the GST on the amount that crossed the threshold 20L. That means for the 6L, I am going to pay 18% GST with interest. Now, considering the cum-tax relief (CUM TAX VALUE FOR SERVICE TAX (taxmanagementindia.com), I have made the computation for the dues (file attached)

My questions are:

Is this computation correct?
How to pay for this? What is the proper challan? Is there any return for this, now that it is Apr 2021?

Thanks a lot,

Cronus

Attached File : 3374647 20210408101222 computation.jpg downloaded: 30 times

Hi Cronus, here’s how to deal with your GST liability for earlier invoices issued before registration:

1. Is your computation correct?

Yes, GST is payable on taxable supplies made from the date you crossed the threshold (Dec 2020) till the date of registration (Mar 2021).
You are liable to pay GST at the applicable rate (18% for consultancy services) along with interest under Section 50 on the amount collected during that period.
The "cum-tax" method (adjusting service tax paid earlier while calculating GST) applies only if the same supply was subjected to service tax and GST overlap—usually not applicable if your turnover just crossed GST threshold in Dec 2020.
Interest calculation should be from the date the tax became due (date crossing threshold) till date of payment.

2. How to pay? What challan/return?

You must pay GST and interest using Challan Form GST PMT-06 on the GST portal.
Since you were unregistered earlier, this payment is made without filing any return for those months.
File Form GST TRAN-1 (if not done already) to declare your opening ITC (if any).
After registration, start filing regular returns (GSTR-1 and GSTR-3B) for subsequent months.
For past supplies before registration, you cannot file retrospective returns but must deposit tax & interest voluntarily.