1.1 Applicability:
Major outcome of the 31st Council meet was to introduce new return system under GST. New return system will contain simplified return forms, for ease of filing.
An insight of the new tool was provided in May 2019 with a prototype of the offline tool being shared on the GST Portal.
The Ministry of Finance has released the transition plan for the proposed GST new return system. The same was launched on a trial basis from July 2019 onwards and phase-wise implementation was scheduled from October 2019 onwards. The implementation is further recommended to be deferred to April, 2020 by 37th GST council meeting.
1.2 Decoding new return format:
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- Introduction of different types of returns based on turnover and type of supplies made.
- The new simplified process can be summarized as – ‘UPLOAD-LOCK-PAY’.
- Single GST Return with the concept of Annexures.
- Taxpayers without any purchase or sale in a period can file NIL returns through an SMS.
- Profile based returns format based on nature of supplies.
- 24/7 upload of invoices into GST Portal – Real time viewing facility of invoices uploaded by the suppliers i.e. Return Filing Status of the supplier can be viewed by the recipient in the portal.
- Amendment return introduced – The new returns also provide taxpayers the facility to amend their invoices and other details filed in the return by filing an amended return.
- Sehaj & Sugam – ITC allowed only on the invoice uploaded by the supplier.
- Normal Return – Automatic reversal of ITC on missing Invoice not allowed – ratification period of 2 months available.
- Taxpayers having turnover above Rs. 5 crores – monthly returns are compulsory to be filed.
- Taxpayers having turnover upto Rs. 5 crores –Required to file GST returns on a quarterly basis.
1.3 GST invoice management options
Deemed locking of invoice – Invoices which are uploaded by the supplier which are either not rejected or not kept pending by the recipient are deemed to be locked on filing of return.
Locking invoice – Once the invoice is locked, the supplier will not be able to alter the invoice. Seems when acceptance of entering into the transaction reported in the invoice.
Missing invoice – Can be exercised by the recipient for invoices or debit notes which have not been uploaded by the supplier on which the recipient has availed input tax credit.
Pending invoice – Can be exercised by the recipient for invoices uploaded by the supplier.
Reject invoice – Can be exercised by the recipient for invoices which are filed by the supplier having wrong GSTIN.
Viewing invoice – Invoices uploaded by the supplier will be visible to the recipient. The screen where it shall be visible to the recipient is called “viewing facility”. This is also called as inward supplies annexure.
1.4 GST Return Amendment Options
Amendment of GST Returns – 2 amendment returns allowed for each tax period.
Amendment of GST Invoices – Only when input tax credit has not been availed and the invoice has not been reported as locked by the recipient.
Amendment of Missing Invoices – Carried out through the amendment return of the relevant tax period to which the invoice pertains.
With the new return formats, Government aims to make return filing process smooth and hassle-free for taxpayers.
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Posted by:
CA Tarun Kapoor
AKGVG & Associates