Action to be taken on or before filing returns for Sept 2021

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Transactions relating to the tax period April 2020 to March 2021 may be rectified while filing returns for September 2021 (Due date for filing GSTR 3B for September 2021 is 20th / 22nd / 24th October 2021). No additional claim of missing ITC may be made available post filing of September 21 returns. Taxpayer may lose the right to claim any eligible ITC which appears in books of accounts and not claimed till filing of September 2021 GSTR 3B return.

Below is the reconciliation which need to do by the taxpayer before filing Sept GST-1 on or before (11th Oct and 13th Oct 2021) and GST3B on or before (20th Oct/ 22nd Oct/24th Oct 2021).

  • Reconcile ITC appearing in the GSTR2A /2B with Inward Supplies Register.
  • Reconcile and Claim ITC which is not appearing in inward supplies register but appearing in GST2A/2B subject to appearing in the books.
  • Follow up with the supplier who have not reported Invoice or filed return for your GSTIN Number.
  • Reconcile turnover reported matches with books of accounts as well GST-1 and GST3B.
  • Issue any pending credit notes pertaining to taxable supplies recorded during the F.Y 2020-21.
  • Reconcile and make correction if invoice has raised under B2B but has been reported under B2C Segment and vice versa.
  • Reconcile and make correction if invoice has raised under Export without payment but has been reported under Export with payment and vice versa.

Action to be taken in Outward Supplies

As per first proviso of Section 37(3) of the CGST act no rectification of error or omission in respect of the detail furnished under sub section 1 shall be allowed after furnishing the return under section 39 for the month of September following the end of the financial year to which such detail pertain or furnishing of the relevant annual return whichever is earlier.

Correspondingly supplier/clients may also be informed about the time limit if any transaction need to be amended in the GST-1 on the basis of reconciliation done for F.Y 2020-21, the same can be done while filing the return GST-1 of Sept 2021, no amendment can be filed for the relevant period is allowed after the due date of GST-1 of Sept 2021.

Below is the area which need to be identified and report in the respective GST-1 and GST3B with applicable interest rate (if any)

  • Non disclose of domestic taxable outward supply transaction GST Returns pertaining to any of the tax period April 2020-March 2021
  • Disclose the domestic taxable outward supply transaction in GSTR-1 to be filed for September 2021 and Add taxable turnover and tax liability in GSTR-3B to be filed for Sept’ 2021 along with Interest.
  • No disclose of export outward supply transaction in GST Returns pertaining to any of the tax period April 2020-March 2021. Forgotten to update shipping bill & port code details for export transactions disclosed in the GST Returns during the period April 2020-March 2021
  • Disclose the export outward supply transaction in GSTR-1 to be filed for September 2021 Amend the export transaction with shipping bill details & port code and Add taxable turnover and tax liability in GSTR-3B to be filed for Sept’ 2021 along with Interest.
  • Non Reporting of Debit Note / Credit Note transaction in GST Returns pertaining to any of the tax period April 2020-March 2021.
  • Report the CN/DN transaction in GSTR-1 to be filed for September 2021 and Adjust CN/DN taxable value and tax liability in GSTR-3B to be filed for September 2021.
  • Non-Reporting of advance tax liability (for supply of services) in GST Returns pertaining to any of the tax period April 2020-March 2021.
  • Report the advance tax liability in GSTR-1 to be filed for September 2021 and Add advance value and tax liability in GSTR-3B to be filed for September 2021.
  • Non adjustment of advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021.
  • Adjust the tax liability in GSTR-1 to be filed for September 2021 and Adjust advance value and tax liability in GSTR-3B to be filed for September 2021.
  • Wrongly reporting of advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021 and Wrongly adjusted advance tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021
  • Adjust the advance tax liability in GSTR-1 to be filed for September 2021 and Correct the advance tax liability adjustment in GSTR-1 to be filed for September 2021.
  • Furnished incorrect Tax Invoice / CN-DN No / CNDN Date, POS, Customer GSTIN, Tax Rate, Tax Amount, Taxable Value and Invoice Value in GST Returns pertaining to the outward supply transaction for the period April 2020-March 2021
  • Amend the tax invoice / Credit Note /Debit Note document with correct details as mentioned on the Tax Invoice in GSTR-1 to be filed for September 2021 and Adjust the taxable turnover and tax liability to the extent of correction in GSTR-3B to be filed for September 2021.
  • Non reporting or incorrectly reported outward nil rated, exempt and non-GST supply in GST Returns pertaining to any of the tax period April 2020-March 2021
  • Reporting/ correct outward nil rated, exempt and non-GST supply figures in GSTR-1 to be filed for September 2021 and add / correct outward nil rated, exempt and non-GST supply figures in GSTR-3B to be filed for September 2021.
  • No Reporting or incorrectly disclosed RCM taxable value & tax liability in GST Returns pertaining to any of the tax period April 2020-March 2021.
  • Reporting and correction of RCM taxable value and tax liability figures in GSTR-3B to be filed for September 2021 and pay interest if due any.

Action to be taken in Inward Supplies and ITC availment and reversal.

  • Non availment of eligible ITC in GST Returns pertaining to any of the tax period April 2020-March 2021
  • Avail ITC in GSTR-3B to be filed for September 2021, subject to reconciliation with GST2B.
  • Availed excess ITC in GST Returns pertaining to any of the tax period April 2020-March 2021
  • Reverse the excess claimed ITC in GSTR-3B to be filed for September 2021with applicable interest.
  • Non- reversal of ITC on account of non-payment to suppliers within 180 days from the date of invoice during the period April 2020-March 2021
  • 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 2021 with applicable interest.
  • Non-Reversal of ITC on account of partly exempt / non-GST and partly taxable supplies in GST Returns during the period April 2020-March 2021
  • Reverse proportionate ITC as per the calculation under rules 42 and 43 of CGST Rules 2017 in GSTR-3B to be filed for September 2021.
  • Non reported Ineligible ITC in GST Returns during the period April 2020-March 2021
  • Report in-eligible ITC in GSTR-3B to be filed for September 2021.