Goods and Services Tax – GST – By: – Nikhil Mohan Jhanwar – Dated:- 18-9-2018 Last Replied Date:- 18-9-2018 – If you think GST is a Good and Simple Tax , you are mistaken. GST is all about technical glitches, daily amendments, and confusions. More the Government tries to put to rest the confusions, the poorer its implementation becomes. If you think Annual Return is just another return seeking consolidation of data filed in GSTR-3B & GSTR-1 in Financial Year 2017-18, you are again mistaken. Imagine you studied the whole year and all of sudden, during exam time, the syllabus is changed. That s what the Annual Return format is. The Government is liberal enough to seek as much as details they could in 5-page Annual Return Format coupled with 5-page instructions notified on 4th September 2018. If you think you have time till 31st December 2018 to file Annual Return that would be your third mistake, Sir. Because, if I state that you have time till 20th October 2018, would you believe m
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GSTR-3B and other from GSTR-1. Similarly, the way details have been sought, it would be very difficult for the ERP systems to fetch data in the same fashion as demanded in the Annual Return. For example, Exports made with payment of IGST and without payment of IGST is filed in Table 6A of GSTR-1. However, Annual Return Format seeks details in Separate Tables. It would have been easier for taxpayers if most of the details could be auto-populated by GSTN from GSTR-3B and GSTR-1 filed in sequential or appropriate manner. This will surely slog various hours of extra nights for taxpayers and for professionals as well. In the instructions for filing Annual Returns, reference of Table No s of GSTR-1 & GSTR-3B has been mentioned at most of the places. If all details are to be taken from 1 & 3B, would not be it prudent to auto-populate the data from returns directly. In other words, the Annual Return should have been formulated in a way which facilitates auto-population of data in resp
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om where this part of the world, Annual Return is asking for these details. The Instructions also states to obtain these figures from Table 9B of GSTR-1. If you refer to Table 9B, it comprises of details only in respect of B2B taxable supplies and Exempt, Nil rated & Non-GST Supply. Details of Input tax credit- Real Mess Input tax credit is like a spoiled brat of rich Dad which has all the luxury in-house as it is not less than a hard cash. But when this brat is excessively exploited, he gives you dangerous results. That s what happened with Part III seeking details of ITC in Annual Return. This Part is so confusing that even lawmakers appear to be clueless about their purpose and intention about kind of disclosure required. Table No. 6: Bifurcate details of Input, Capital goods & Input services Table seeks separate bifurcation for inputs, capital goods & input services in respect of Input tax credit. This is beyond my imagination as these details were never part of GSTR-1
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ld have been paid by him as one of the conditions to avail ITC. GSTR-2A is created from GSTR-1 filed by the Supplier. But does it ensure payment of tax by the Supplier? There may be a situation where Supplier has filed GSTR-1 but has not filed GSTR-3B for corresponding supply and thus, not paid tax. Ideally, GSTR-2A is required to be verified whether a tax on these supplies have been paid or not to enable complete compliance of the conditions of availment of input tax credit. Lapse of ITC- Innovative thought This is an interesting thing. The Annual return calculates for you the input credit lapsed in last financial year i.e. 2017-18. It comprises of 3 things: The difference in ITC available as GSTR-2A and ITC actually availed in GSTR-3B filed for the period July 2017 to September 2018 which is further classified into : ITC available but not availed ITC available but ineligible The difference in ITC available on the import of goods and ITC actually availed in GSTR-3B Note: However, no c
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ssional to have an easy life. The task of digging HSN wise details of Inward supply is like repeating the same Semester not because we failed in exams but because syllabus has changes. This will only add to compliances woes of taxpayers. Before parting……… It would not be out of context if this Annual Return format is terms a Surgical Strike by the Government. Two quick recommendation for GST Council: To introduce an online facility wherein details of GSTR-3B and GSTR-1 filed for July, 2018 to March, 2018 is made available on consolidated basis. To mandate filing of Annual return first year only for Taxpayers having Aggregate Turnover of more than 1.5 crs. This would ease compliance burden and increasing costs of small taxpayers About Author: CA. Nikhil M. Jhanwar is practicing Chartered Accountant and Faculty Member of GST by ICAI in Delhi/NCR specializing in GST, UAE VAT, end-to-end start-up formation, compliances & advisory. He has deliberated his views on va
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