GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-1

GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-1

As we all know that all registered assesses under GST Law are required to comply with the filing of Annual Return by 30.06.2019. The details required in annual return requires extensive compilation. Moreover, the amendments made in the format of Annual Return have raised several doubts as regards the presentation of appropriate information in relevant columns in light of practical complications. The series of update are being prepared to help the assesses in best possible manner and try to resolve the confusions prevailing as regards presentation of information in the annual return.

The government has also released instructions for filing the annual return but detailed clarifications are expected from the government so as to facilitate the assessees to correctly present the desired information under relevant tables of the format. At the outset, we wish to point out that the instructions indicate the source of information that is to be derived for various serial numbers, and at most of the places except pertaining to input tax credit details, reference is being made to GSTR-1. However, it is worth noting that while filing annual return, the details of various tables of GSTR-1 are to be considered, PROVIDED TAX has been discharged from GSTR-3B filed by the assesses. Consequently, the base for filing annual return will be GSTR-3B as tax liability is discharged through this return while GSTR-1 is only informative. Furthermore, the assessee is also required to ensure that correct figures are being reported in the annual return in case there was error in reporting information in GSTR-3B filed by him as the assessee is required to report “details of outward supplies made during the financial year” and not “declared during the financial year”. The above discussion clearly reveals the caution to be exercised while filing annual return by the assessee. We intend to discuss the compliances to be made by the assessee while filing annual return in the next series of our updates and we hope that the same is useful to our netizens.

We hereby discuss the details required to be furnished in part A of serial no. 4 of the annual return “Details of advances, inward and outward supplies made during the financial year on which tax is payable”.
4A Supplies made to un-registered persons (B2C):
The assessee is required to submit the details of B2C supplies net of debit notes and credit notes along with amendments made in such supplies during the financial year 2017-18. Important point to note is that assessee is not required to consider amendments made in the GSTR-1 filed for the months of April, 2018 to September, 2018 with respect to financial year 2017-18 while filing amount in this table. This can be better explained with following situations:-
Situation No. 1-Assessee made B2C supplies of Rs. 5,70,000/- during July, 2017 to March, 2018 with credit notes of Rs. 20,000/- raised in the month of February, 2018 which were duly accounted for in GSTR-3B filed for the month of March, 2018. In such a scenario, the amount to be considered for filing 4A shall be Rs. 5,70,000/- Less Rs. 20,000/- = Rs. 5,50,000/-
Situation No. 2-Assessee made B2C supplies of Rs. 5,70,000/- during July, 2017 to March, 2018 with credit notes of Rs. 20,000/- raised in the month of February, 2018 which were duly accounted for in GSTR-3B filed for the month of June, 2018. In such a scenario, the amount to be considered for filing 4A shall be Rs. 5,70,000/-. However, amount of Rs. 20,000/- will be reflected as tax reduced through amendments in serial no. 11 of the annual return.
Situation No. 3-Assessee made B2C supplies of Rs. 5,70,000/- during July, 2017 to March, 2018 with credit notes of Rs. 20,000/- raised in the month of April, 2018 which were duly accounted for in GSTR-3B filed for the month of May, 2018. In such a scenario, the amount to be considered for filing 4A shall be Rs. 5,70,000/-. The credit notes of Rs. 20,000/- raised in financial year 2018-19 will be part of annual return filed for the financial year 2018-19 and will not be considered while filing annual return for the financial year 2017-18.

We hope we clarified the different presentations to be made in various situations as discussed above in simple manner. The other aspects of presentation of various figures in annual return will be discussed in our next update.
This is solely for the educational purpose.
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