GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-2

GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-2

In earlier update, we discussed about the details to be filled in serial no. 4A of Part-II of the Annual Return requiring the details of advance, inward and outward supplies on which tax is payable as declared in returns filed during the financial year. In the present update, we seek to discuss on the details to be filled in serial no. 4B “Supplies made to registered persons (B2B)”.

The assessee is required to report the details of all supplies (intra-state and inter-state both) made to registered persons during the financial year 2017-18 but the outward supplies on which tax is payable on reverse charge basis by the recipient would not be taken for reporting under this serial. If we compare the details required to be furnished under this serial no. as against serial no. 4A-supplies made to un-registered persons (B2C), we find lot of difference. The supplies declared under serial no. 4A are to be shown net of debit/credit notes and amendments made during the financial year but while reporting supplies under serial no. 4B pertaining to B2B, the adjustments on account of debit/credit notes is to be separately reflected under serial no. 4J/4I of the Part-II of the annual return. Likewise, amendments made in B2B supplies during the financial year 2017-18 are to be separately reported under serial no. 4K/4L of the Part-II of the annual return. However, if the amendments pertaining to financial year 2017-18 are being carried out in the returns filed during the financial year 2018-19, such amendments made in financial year 2018-19 are to be reported in serial no. 10/11 of Part V of the annual return. This can be explained with the help of following examples:-
Example 1:-
B2B Supplies made in FY 2017-18 = Rs. 10,00,000/-
Supplies made in the month of December, 2017 were Rs. 2,50,000/- but were wrongly reported in GSTR-3B as 2,00,000/-. The amendment for the same was carried out in the GSTR-3B for the month of February, 2018.
In this case, the amount to be reported in serial no. 4B will be Rs. 9,50,000/- and amount of Rs. 50,000/- will be reported in serial no. 4K of the annual return.
Example 2:-
B2B Supplies made in FY 2017-18 = Rs. 10,00,000/-
Supplies made in the month of December, 2017 were Rs. 2,50,000/- but were wrongly reported in GSTR-3B as 2,00,000/-. The amendment for the same was carried out in the GSTR-3B for the month of May, 2018.
In this case, the amount to be reported in serial no. 4B will be Rs. 9,50,000/- and amount of Rs. 50,000/- will be reported in serial no. 10 of Part V of the annual return.

Now, the question that arises in the minds of assessee is that whether amendments carried out even after filing the return for the month of September, 2018 are to be considered in Part V while filing annual return for financial year 2017-18 in light of the Removal of Difficulty Order No. 02/2018-Central Tax dated 31.12.2018 issued by the government? If we study the Removal of Difficulty Order, it is found that the amendment in GSTR-1 (pertaining to invoice/debit note/credit note) is permitted after September, 2018 till the due date of furnishing GSTR-1 for the month of March, 2019 only with the objective to enable the recipient assessee to claim input tax credit unavailed due to non-reflection of input tax credit in GSTR-2A of the recipient. The Removal of Difficulty Order does not permit any amendment in GSTR-3B return through which assessee pays tax. Consequently, credit notes/debit notes pertaining to financial year 2017-18 included in GSTR-1 but not reflected in GSTR-3B upto due date of furnishing GSTR-3B for the month of September, 2018 will not be considered while filing details in serial no. 10/11 of Part V of the annual return.

The points as regards other aspects in filing annual return will be discussed in our next update. GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-2

In earlier update, we discussed about the details to be filled in serial no. 4A of Part-II of the Annual Return requiring the details of advance, inward and outward supplies on which tax is payable as declared in returns filed during the financial year. In the present update, we seek to discuss on the details to be filled in serial no. 4B “Supplies made to registered persons (B2B)”.

The assessee is required to report the details of all supplies (intra-state and inter-state both) made to registered persons during the financial year 2017-18 but the outward supplies on which tax is payable on reverse charge basis by the recipient would not be taken for reporting under this serial. If we compare the details required to be furnished under this serial no. as against serial no. 4A-supplies made to un-registered persons (B2C), we find lot of difference. The supplies declared under serial no. 4A are to be shown net of debit/credit notes and amendments made during the financial year but while reporting supplies under serial no. 4B pertaining to B2B, the adjustments on account of debit/credit notes is to be separately reflected under serial no. 4J/4I of the Part-II of the annual return. Likewise, amendments made in B2B supplies during the financial year 2017-18 are to be separately reported under serial no. 4K/4L of the Part-II of the annual return. However, if the amendments pertaining to financial year 2017-18 are being carried out in the returns filed during the financial year 2018-19, such amendments made in financial year 2018-19 are to be reported in serial no. 10/11 of Part V of the annual return. This can be explained with the help of following examples:-
Example 1:-
B2B Supplies made in FY 2017-18 = Rs. 10,00,000/-
Supplies made in the month of December, 2017 were Rs. 2,50,000/- but were wrongly reported in GSTR-3B as 2,00,000/-. The amendment for the same was carried out in the GSTR-3B for the month of February, 2018.
In this case, the amount to be reported in serial no. 4B will be Rs. 9,50,000/- and amount of Rs. 50,000/- will be reported in serial no. 4K of the annual return.
Example 2:-
B2B Supplies made in FY 2017-18 = Rs. 10,00,000/-
Supplies made in the month of December, 2017 were Rs. 2,50,000/- but were wrongly reported in GSTR-3B as 2,00,000/-. The amendment for the same was carried out in the GSTR-3B for the month of May, 2018.
In this case, the amount to be reported in serial no. 4B will be Rs. 9,50,000/- and amount of Rs. 50,000/- will be reported in serial no. 10 of Part V of the annual return.

Now, the question that arises in the minds of assessee is that whether amendments carried out even after filing the return for the month of September, 2018 are to be considered in Part V while filing annual return for financial year 2017-18 in light of the Removal of Difficulty Order No. 02/2018-Central Tax dated 31.12.2018 issued by the government? If we study the Removal of Difficulty Order, it is found that the amendment in GSTR-1 (pertaining to invoice/debit note/credit note) is permitted after September, 2018 till the due date of furnishing GSTR-1 for the month of March, 2019 only with the objective to enable the recipient assessee to claim input tax credit unavailed due to non-reflection of input tax credit in GSTR-2A of the recipient. The Removal of Difficulty Order does not permit any amendment in GSTR-3B return through which assessee pays tax. Consequently, credit notes/debit notes pertaining to financial year 2017-18 included in GSTR-1 but not reflected in GSTR-3B upto due date of furnishing GSTR-3B for the month of September, 2018 will not be considered while filing details in serial no. 10/11 of Part V of the annual return.

The points as regards other aspects in filing annual return will be discussed in our next update.

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GST UPDATE ON ANNUAL RETURN COMPLIANCE-PART-2

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