GST COMPLIANCES REQUIRING ATTENTION NOW
By: – Dr. Sanjiv Agarwal
Goods and Services Tax – GST
Dated:- 10-4-2018
31st March, 2018 marks the end of Financial Year 2017-18, first fiscal year of GST and last year of service tax. This is also the transitional year for migration and as such crucial for taxpayers to migrate balances and tax credits fully but accurately. This calls for due diligence and careful closing of financial books of accounts.
Here are few action points in the new financial year for immediate compliance under GST in April, 2018 for the new Financial Year 2018-19.
Annual Reconciliation of Books and GST returns
For this, assessees are required to reconcile the sale ledger/ GST liability / cash ledger/ credit ledger as per books of accounts and as per GST returns. Further, in case there is any difference, then company is required to take the effect of the same in March, 2018, GSTR 3B and GSTR 1.
New Invoice Series
A registered person may develop the n
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ction 16(2) of CGST Act, 2017. If the payment is not made, the credit taken on that invoice must be reversed. And whenever such payment is made credit may be taken then. By this logic, invoices issued before 1st October, 2017 must have been paid by 31st March, 2018. If not, you'll have to reverse the input credit claimed. This requires proper ageing analysis of outstanding debtors and creditors.
* Filing of TRAN 2 for the period July, 2017 to December, 2017 has been extended to be filed by 30th June, 2018. Earlier, it was to be filed by 31st March, 2018.
* In the past, there have been many instances and complaints that assessees were not able to file TRAN-1 which was required to carry forward balances of input credit pertaining to old tax regime (excise, service tax, VAT) due to technical snags. There were many writ petitions filed across the country and various high courts directed the Government to allow further opportunity to the tax payers who could not file TRAN-1. [M/s. Ariha
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not be allowed to amend the amount of credit in TRAN-1 during this process vis-à-vis the amount of credit which was recorded by the taxpayer in the TRAN-1, which could not be filed.
* The taxpayers are allowed to complete the process of filing of TRAN 1 stuck due to IT glitches, as discussed above, by 30th April 2018 and the process of completing filing of GSTR 3B which could not be filed for such TRAN 1 shall be completed by 31st May 2018.
It may be noted that this extention is not for all taxpayers who did not file TRAN-1 but only for those who attempted to file but were not successful. This will be verified from GSTN audit trail.
Application / Renewal of LUT
Exporters making zero rates supplies have to furnish an LUT to the jurisdictional commissioner. An LUT is valid for one financial year. Therefore, LUT tendered in FY 2017-18 was valid until 31st March, 2018 only. Exporters who wish to continue to export under LUT need to submit a fresh LUT for FY 2018-19 to have thi
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e been rejected ab initio.
Thus, LUT will be deemed to be accepted as soon as ARN is generated and no documents need to be submitted in physical form to the tax office.
Use of E-way Bills
1st April has become a land mark date in the GST journey, as it marks the advent of e-way bills in the country under the GST regime, a tool to check tax evasion and bring in operational efficiency so far as taxpayers and logistics management is concerned.
Date of Introduction of e-way bills is 1st April, 2018 for inter-state movement of goods.
Every registered person who causes movement of goods of consignment value exceeding fifty thousand rupees (including tax)-
* in relation to supply, or
* for the reasons other than supply, or
* due to inward supply from unregistered person,
shall require to furnish an e-way bill. No e-way bill is required if the value of the goods in an individual consignment is less than ₹ 50,000/- even if the total value of all such consignments in a single c
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rticulars
To whom applicable
Period
Due date
GSTR-1
(Monthly)
Taxpayers with annual aggregate turnover more than ₹ 1.5 crore
Feb 2018
10.04.2018
GSTR 4
Composition dealers
Jan – Mar 2018
18.04.2018
GST Payment
All taxpayers
March 2018
20.04.2018
FORM 3B
All taxpayers
March 2018
20.04.2018
GSTR 5
Non-resident taxable persons
March 2018
20.04.2018
GSTR 5A
Online Information and Database Access or Retrieval (OIDAR)
March 2018
20.04.2018
GSTR 1
Taxpayers with annual aggregate turnover upto ₹ 1.5 crore
Jan – Mar 2018
30.04.2018
TRAN 1
Taxpayers who failed to file TRAN 1 due to IT glitches
30.04.2018
Now that most of the returns will be filed in next three months, it appears that another major GST reforms / amendments may take place w.e.f. July, 2018, when it completes first year of levy of GST in the country. GST Council has had 26 meetings so far and yet lot of issues have to be ironed out, the most crucial being technical interface.
Account
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