Decoding Form GSTR-3B vis-à-vis legal provisions
By: – Anuj Bansal
Goods and Services Tax – GST
Dated:- 18-7-2017
As per the decision taken in 17th meeting of GST Council on 18th June, 2017, a summary return i.e. GSTR-3B is required to be filed for the month of July and August, 2017 in lieu of GSTR-3. According to the government this is a relaxation in filing GST returns for the first two month. However, there is a slight twist in the tale, GSTR 3B is not the only return to be filed for the month of July and August, 2017. Taxpayers also need to file GSTR-1, GSTR-2 for the aforesaid months. Let's have a glance on the return filing dates for the upcoming months:-
Returns to be filed in the month of August, 2017
20/08/2017
GSTR-3B of July, 2017
Returns to be filed in the month of September, 2017
05/09/2017
GSTR-1 for July, 2017
10/09/2017
GSTR-2 for July, 2017
15/09/2017
GSTR -3 for July, 2017
20/09/2017
GSTR-1 & GSTR-3B for August, 2017
25/09/2017
G
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egular return filing dates will be applicable as per present legal position.
What is GSTR- 3B?
Rule 61(5) of CGST Rules, 2017 states “Where the time limit for furnishing of details in FORM GSTR-1 under section 37 and in FORM GSTR-2 under section 38 has been extended and the circumstances so warrant, return in FORM GSTR-3B, in lieu of FORM GSTR-3, may be furnished in such manner and subject to such conditions as may be notified by the Commissioner.”
Let's scrutinize details to be furnished in GSTR-3B
1. Basic Information:-
Analysis:- No need to give detail of last year turnover pertaining to Financial year 2016-17 and from April 2017 to June 2017, which was required to be given in GSTR-3.
2. Details of Outward Supplies and inward supplies liable to reverse charge:-
Analysis: – In the aforesaid table details of both inter-state & intra-state outward supplies will be furnished. However, if taxpayer is making any supply on which tax is paid under RCM by the recipient
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ails of inter-state supplies pertaining to only unregistered persons, composite taxable persons and UIN holders separately? If the motive here is to capture the Place of Supply in case of inter-state supplies, then what about the details of B2B inter-state outward supplies? Secondly, how it is possible to capture the supplies made to composition taxable persons. At the time making outward supplies do we need to record the details of supplies made to composition dealers separately? Thirdly, for the details of outward supplies made to UIN holders, one need to capture such details in the books of accounts separately so as to furnish such details in the aforesaid table.
4. Eligible ITC:-
Analysis: – It is required that the taxable person should capture all such details beforehand, as per the aforesaid table in the accounting system in order to avoid last minute hassle. In Part (A) of above table all the ITCs available in the accounting system are required to be reported and tin part (B)
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wever, provisions with regard to TDS &TCS are deferred by the government, hence for the initial returns no such detail / information is required to be given.
Need of the hour – To get prepared:-
In the light of the above discussion, it is stated that registered person shall take care of capturing the details in the books of accounts in the manner that the same shall be available in the formats / form for reporting in GSTR-3B. Thus, one needs towork in a systematic manner right from today itself in order to avoid complexities at a later stage.
Reply By Narhar Nimkar as =
Thanks Anuj for the information and analysis done.
In the statement / 3B return, no clarity available for Cenvat balances carried forward in GST. How to give effect to this while calculating the liability for final payment in August, 2017 ??
Dated: 19-7-2017
Reply By SUMIT JHA as =
you have to file declaration in transitional form 1 to avail previous credit as per return and credit lying in raw material semi fi
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3
4
(A) ITC Available (whether in full or part)
(1) Import of goods
(2) Import of services
(3) Inward supplies liable to reverse charge (other
than 1 & 2 above)
(4) Inward supplies from ISD
(5) All other ITC
(B) ITC Reversed
(1) As
per rules 42 & 43 of CGST Rules
(2) Others
(C) Net ITC Available (A) – (B)
(D) Ineligible ITC
(1) As per section 17(5)
(2) Others
Integrated Tax
Central Tax
State/UT Tax
Cess
2
3
4
5
5.
Values of exempt, nil-rated and non-GST inward supplies
Nature of supplies
Inter-State supplies
Intra-State supplies
From a supplier under composition scheme, Exempt and Nil rated
107
2
3
supply
Non GST supply
6.1 Payment of tax
Description
Tax
payable Integrated
Paid through ITC
Central State/UT
Cess
Tax paid
TDS./TCS
Tax/Cess
Interest
Late
paid in
Fee
Tax
Tax
Tax
cash
2
3
4
5
6
7
8
9
10
Integrated Tax
Central Tax
State/UT Tax
Cess
6.2 TDS/TCS Credit
Details
1
TDS
TCS
Integrated Tax
2
Central Tax
3
S
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