157 Short Presentation on New GST Returns · 2019-11-27 · Short Presentation on New GST Returns...

Short Presentation on New GST Returns

(Critical Analysis)

CA Jignesh Kansara

Knowledge Sharing @GST Bhavan @ BKC, Mumbai

Hosted by Thane Rural and Palghar CommissionerateOn 26th November 2019

Jignesh Kansara @ GST Bhavan, BKC on 26th Nov 19

DisclaimerDisclaimer

• The information in this presentation was compiled from various sourcesbelieved to be reliable and is for informational purpose only.

• While every efforts have been made to keep the information cited in thispresentation error free, we do not take the responsibility for anytypographical or clerical error which may have crept in while compiling theinformation provided in this presentation. Further, the information providedin this presentation are subject to the provisions contained under differentacts and reader is are advised to refer to those relevant act before relying onour presentation. This presentation does not purport to identify and dealwith all the issues and provisions related to subject and therefore should notbe regarded as comprehensive / sufficient for the purpose of decisionmaking. Author does not undertake any legal liability for any of the contentsof this presentation. The information provided is not, nor is it intended to bean advice on any matter and should not be relied on as such. Professionaladvise must be sought before taking any action on any of the informationcontained in it.


Agenda for the day Agenda for the day

Clarification are needed

Walk through of New Returns

Welcome Features

Kabhi Khushi KabhiGham

Not so Welcome features


Present Eco system of GST returnsPresent Eco system of GST returns

Slide 4

GSTR‐1On 11th of next

monthDetails of outward supply furnished

by supplier

GSTR‐2ADetails of outward supply furnished by

supplier made available to recipient

GSTR‐3B20th of the next

monthSummary Return

cum challan

ITC in 3B is ITC in 3B is not flowing from GSTR‐

2A


Eco system of New ReturnsEco system of New Returns

Slide 5

IANX 2

RET 1/2/3

IANX !

ANX 1

ANX‐1AAmendment stmt

RET‐1A/2A/3AAmendment Return

PMT‐08Payment challan

Sort of GSTR‐1

Sort of GSTR‐2

Sort of GSTR‐3/3B

GSTR‐4,5,6,7,8 &11 will continue

Other functionalities


ANX 1 –Birds Eye viewANX 1 –Birds Eye view

Table # Description Remark

1 & 2 Basic Details GSTIN, Name etc

3 Details of outward supplies, inward supplies attracting reverse charge and import of goods and services

Disclosure of details in Table 3 will create liability (except for Import of Goods)

4 Details of the supplies made through e‐commerce operators liable to collect tax under section 52 (out of any outward supplies declared in table 3)

Additional disclosure, even though already disclosed in Table 3 above

6


ANX‐1 ‐Table 3ANX‐1 ‐Table 3

3.A

3.G

3.B

3.D

3.C

3.J

3.E

3H

3.I

3.K

3.F

B2C

B2B

Export with Payment of Tax

Export without Payment of Tax

Supplies to SEZ units with payment of tax

Supplies to SEZ units without payment of tax

Deemed Export

Inward supplies attracting reverse charge

Import of services

Import of Goods

Import of goods from SEZ units on a BOE

3.L Missing documents

3A,3C,3D,3I & 3J – No GSTIN

3H,3K & 3L GSTIN of supplier

3B,3E,3F& 3GGSTIN of Recipient

3H even PAN, if GSTIN is missing


Birds Eye View– ANX 2Birds Eye View– ANX 2

• Auto Populated • Accept / Reject / Keep it Pending / Deemed Acceptance

Details uploaded by supplier (irrespective of frequency & type)

Say May 2020

Up to 10th of following month in

which details uploaded 10th of June 2020

By 18th June 2020AcceptReject Pending

Modification

Slide 8

Else deemed Acceptance


Birds Eye View ‐ RET 1Birds Eye View ‐ RET 1

Slide 9

Outward Supplies & LiabilitiesRCM & Advance Liabilities Dr / Cr Notes [Table 3]

Summary of Inward supply ITC & Reversal [Table 4]

TDS/ TCS [Table 5]Offset & Cash payment [Table 7]

Interest & Late Fees[Table 6]

Refund [Table 8]Verification [Table 9]

Actual Return Majority of Details are auto populated from ANX‐1, ANX‐2, GSTR‐6 etc. Few details can be manually added


Return Periodicity (RET 1)Return Periodicity (RET 1)Re

turns

Big Tax PayerPrevious Year TO >

5CR

Monthly (Normal)RET‐1

Small Tax Payer Previous Year TO

<= 5 CR

Monthly (Normal)

Quarterly

Sahaj –RET‐2

Sugam RET‐3

Quarterly (Normal)RET‐1

10

OR OR

OR


Time Lines of New GST ReturnsTime Lines of New GST Returns

For Monthly Filers

ANX 1ANX 1

ANX 2ANX 2

RET 1RET 1

Upload Liability details by 10th of Subsequent month

Accept ITC details by 18thof Subsequent month / Deemed Acceptance

File by 20th of Subsequent month + payment


Who can file Sahaj (RET‐2) ?Who can file Sahaj (RET‐2) ?

• Tax payer opted to file Sahaj is allowed to declare– outward supply under B2C category and– inward supplies attracting reverse charge only

• Can’t make supply through e‐commerce (TCS – Section 52)

• No Credit on Missing Invoice.

• Such RTP Can make Nil rated, exempted or Non‐GST supplies

• Such RTP Can’t make any other type of inward or outward supplies

• Nil rated, exempted or Non‐GST supplies need not be declared in Sahaj.

12


Who can file Sugam (RET‐3)?Who can file Sugam (RET‐3)?

• Tax payer opted to file Sugam is allowed to declare– outward supply under B2B & B2C category and– inward supplies attracting reverse charge only

• Can’t make supply through e‐commerce (TCS – Section 52)

• No Credit on Missing Invoice

• Such RTP can make Nil rated, exempted or Non‐GST supplies

• Such RTP Can’t make any other type of inward or outward supplies

• Nil rated, exempted or Non‐GST supplies need not be declared in Sahaj.

13


Who can File Normal Return (RET‐1)?Who can File Normal Return (RET‐1)?

• Residue Category

• Periodicity Quarterly for small tax payer

• For Big Tax payer, monthly

• Can declare all types of outward supplies, inward supplies

• Credit Can be taken on missing invoices Subject to Restrictions, Reversal andInterest.

14


Summary of ComplianceSummary of Compliance

Large Tax Payer Invoice details

ANX 1

Real time

Upto 10th of next month

ITC DetailsANX 2

Near Real time

Upto 18th Next month (else Deemed filing)

Return RET‐1

Upto 20th Next monthWith payment


Summary of ComplianceSummary of Compliance

Small Tax Payer

Invoice detailsANX 1

Real time

Upto 10th of next Quarter

ITC DetailsANX 2

Near Real time

Upto 18th of Next Quarter

Tax Payment 20th of every month

Return RET‐1 Quarterly / RET 2 /3

Up to 25th of Next Quarter


Which Returns Tax payer will have to file ?Which Returns Tax payer will have to file ?

Large Tax Payer in PY)

Small Tax Payer(Upto 5 Cr Turnover

in PY)

Monthly ANX 1

Monthly ANX 2

RET1 Monthly

Quarterly ANX 1

Quarterly ANX 2

Quarterly RET1

Quarterly Quarterly RET 2

Quarterly Quarterly RET 3

Quarterly


How Tax payer will pay GST? How Tax payer will pay GST?

Type

of R

TP RET‐1 monthly filer

RET‐1 for regular payment

RET‐1A – for liability due to amendment

RET‐1 Quarterly filer/ RET‐2 / RET‐3 filer

PMT‐08 ‐ for first two months of the quarter

RET‐1/ 2/3 (for third month of the quarter)

RET‐1A/2A/3A – for liability due to amendment

18


Restriction on Upload ‐ ANX 1Restriction on Upload ‐ ANX 1

Return Window of Prior Period

Return Window of Current

Period

Real-time Upload

Real-time upload

fMonthly filers –No uploading 18-20 of next

month

Quarterly filers –No uploading 23-25 of next

month

If prior period Invoice is wrongly entered in current period window, will reflect in

Recipient ANX‐2 next month

Invoice can be uploaded upto :• Due date of Furnishing Return of Sep Next FY or

• Due Date of Annual Ret. Whichever is earlier


Editing of Invoice by Supplier Editing of Invoice by Supplier

20

Invoice de

tails

invoice not accepted by recipient up to 10th of next

monthSupplier can edit

Invoice already accepted by recipient up to 10th of next

month

First Reset / unlock by Recipient

Separate Utility


Credit Mechanism in New ReturnCredit Mechanism in New Return

• Recipient will get credit during a tax period (say April 2020) on the basis of thedetails of documents uploaded by the supplier up to the 10th of the monthfollowing the month for which the return is being filed for (10th May 2020)

21

ITC in New

form

s

Recipient Monthly Filer

Confirmed Credit for docs uploaded by supplier up to

10th of Next month

Claim Provisional Credit(Not for Sahaj & Sugam)

Recipient Quarterly Filer

Confirmed Credit for docs uploaded by supplier up to

10th of Next Quarter

Claim provisional credit(Not for Sahaj & Sugam)


Switch over Normal / Sahaj / Sugam for Quarterly filersSwitch over Normal / Sahaj / Sugam for Quarterly filers• Newly registered taxpayers will also have the option to file monthly, Sahaj, Sugam or

Quarterly (Normal) return.• Periodicity depends upon Turnover of preceding year for existing tax payers• Change in periodicity of the return filing ‐ allowed only once at the time of filing the first

return by a taxpayer. If RTP has choosen monthly filing as frequency, for rest of the yearfrequency can’t be changed to Quarterly and vice versa.

• The periodicity of next FY will remain unchanged unless changed before filing the firstreturn of that year

• However Quarterly Return filer can choose/shift between– Sahaj, Sugam or Quarterly(Normal).

22

• Quarterly filer (RET‐1)

Switchover

• Sugam (RET‐3)• Sahaj (RET‐2)

Switchover• Sahaj (RET‐2)

Once a year


Switch over Normal / Sahaj / Sugam for Quarterly filersSwitch over Normal / Sahaj / Sugam for Quarterly filers

23

• Sahaj (RET‐2)

Switchover

• Sugam (RET‐3)• Quarterly Normal (RET‐1)

Switchover• Quarterly Normal (RET‐1)

More than once

Basic Rule Opting for Higher compliance, switch N number of times Opting for Lower Compliance, switch possible only once a year


What if filing of ANX‐1 is delayed?What if filing of ANX‐1 is delayed?

24

Consequences if details are not uploaded by 10thof Next month / Quarter in ANX‐1

• Details will be reflected in ANX‐2 of Recipient innext month.

• Recipient will have to claim provisional credit(Not possible in Sugam and Sahaj)

• Adjustment to be made next month by recipientwhen credit is reflected.

• See Separate slides for hassles of provisionalcredit.


Invoice Rejection by RecipientInvoice Rejection by Recipient

Invoice rejection only for those error which can’t be rectified through Debit / Credit Note

Slide 25

AA

BB

CC

DD

Rejection will be conveyed to the supplier only after filing of the return by the recipient

Supplier can edit before filing subsequent Return

Credit will appear only in next open GST ANX‐2

Liability of the period in which uploaded. Supplier will be required to pay Tax


What if Return (RET 1/2/3 is not filed) two consecutive months?What if Return (RET 1/2/3 is not filed) two consecutive months?

26

Fraud

• The documents uploaded in FORM GST ANX‐1 for month ‘M’ by a supplier (June 2020)

• Previous two consecutive tax periods (M‐1 and M‐2 months) RET‐1 not filed. (April and May 2020)

No ITC• Such Invoices will be visible to the recipient in ANX‐2• However Recipient cannot claim ITC on such inward supplies for June 2020

Till

• Recipient can reject or keep such documents pending until filing of return by the supplier

• For Supplier filing return on quarterly basis, this period will be one quarter instead of 2 months.

• Grace period : Monthly filer ‐2 months. Quarterly filer – 1 Quarter


Rigmarole/Hassles of Provisional credits Rigmarole/Hassles of Provisional credits

27

Prov

ision

al Credits Claim credit in RET1 4A.10

If shown by supplier subsequently

Reverse in 4B.2(No Interest impact)

If Not shown by Supplier. Who is monthly filer

Reverse ITC with Interest if not reported in next 2 month ANX 1 Table 3L

If Not shown by Supplier. Who is Quarterly filer

Reverse ITC with Interest if not reported in next

Quarter ANX 1 Table 3L


AgendaAgenda


Welcome FeaturesWalk through of New Returns


Not so Welcome features


Welcome FeaturesWelcome Features Effective Transitional Mechanism• If any Outward supply / Inward supply subject to RCM is not disclosed in 3B or 1 for FY

1920 same can be disclosed in New Returns. Even ITC of FY 1920 if not claimed earlier can be claimed in new Returns.

Documents flow to be uni‐directional• In GSTR‐2, recipient could have made amendment in document details uploaded by

Supplier.• Such modification further needs approval of supplier• Only on approval such amended details forms parts of GSTR‐1 of Supplier• Two way flow of documents leading to portal failure.• In new returns, Recipient will have only 3 options, Accept, Reject, Pending. Recipient can’t

modify.

Staggered Due Date • RET‐1 Due date for monthly filers : 20th of Next month• RET‐1 Due date for Quarterly filers : 25th day from end of Quarter• RET‐1 Due date for Sahaj / Sugar filers : 25th day from end of Quarter

29


Welcome FeaturesWelcome Features

Only Reject or Keep it pending and let portal do the rest• Instead of accepting all inward supplies invoice wise, RTP may take action of

rejecting or keeping pending invoices, rest of the invoices will be automaticallyaccepted by system, leading to ease in compliance burden.

Disclosure of Negative Liability • In GSTR‐3B negative figures can’t be reported. E.g. Sales return (Credit Note)

exceeds value of Sales for a month can’t be reported in GSTR‐3B. In new returnsnegative figures can be reported

Locking of Invoices in case of Refund • Tax invoices on which refund is already claimed by RTP will not be available for

amendment

30


Welcome FeaturesWelcome FeaturesFiling of NIL Return (RET 1/2/3) by SMS • If RTP has not uploaded any supplies in Form GST ANX‐1 and • If no inward supplies have been auto‐populated in Form GST ANX‐2 and • There is no other information the taxpayer is required to report in the Form GST

RET‐3 (manual entry) • Nil return can be filed by way of an SMS

If Returns are not filed by Supplier, No Credit flow to Recipient • Supplier (Monthly filer) has not filed return for 2 months, the invoices uploaded

by him from the 3rd month onwards will not be available to the recipient for acceptance in his Form GST ANX‐2

• Supplier (Quarterly filer) has not filed return for 1 Quarter, the invoices uploaded by him from the next quarter onwards will not be available to the recipient for acceptance in his Form GST ANX‐2.

• Even recipient can’t claim provisional credit in respect of such supplier.

31


Welcome FeaturesWelcome Features Auto calculation of Interest• Portal will auto‐calculate interest for following events

i. Late filing of the return, ii. Delay in upload of invoices for outward supplies

Adjustment of Negative Liability • In case of decrease in tax liability (amendment in Form GST ANX‐1 or in Form GST

RET‐1A), RTP can adjust such excess tax paid against future liability, however no refund is permissible

Simple form for Small Tax Payers • RET‐2, minimum disclosure of POS wise B2C details (Not invoice wise) • RET‐3, moderate disclosure of POS wise B2C details (Not invoice wise) & POS

wise Invoice wise B2B details.

32


Welcome FeaturesWelcome Features

Reduction of Interest Liability for Tax Payers in some cases • Even though RTP can pay Tax any time, his liability will be adjusted only

on filing of GSTR‐3B. E.g. Tax payer has filed Return of Oct 19 on due dateand thereafter noticed one invoice, which is not disclosed in GSTR‐3B andhas immediately paid applicable GST in cash, however his interest liabilitywill continue till next filing date of GSTR‐3B. In new returns situationswhere amendment can be filed by way of ANX‐1A can be off set any timeby filing RET‐1A, this will lead to saving of interest. However certainamendment in Invoice can be made only in RET‐1 and in such casesInterest liability will continue till filing of next RET‐1

Option to shift from one type of Return to another• Quarterly filers have option to switch between RET‐1, RET‐2 and RET‐3

subject to certain restrictions

33


Welcome FeaturesWelcome Features ANX‐1 is aligned to RET‐1/2/3• Though ANX‐1 format is similar to every one, if Tax payer has opted to file RET‐2,

his ANX‐1 will only tables for B2C supplies and Inward supplies subject to RCM, leading to ease in compliance. Similarly for RET‐3 filers, ANX‐1 will seek limited data from RTP

Facility to upload / view supply details online• Supplier can upload the details of invoices in ANX‐1 on real‐time basis. • Recipient can Accept / unlock details of documents uploaded by suppliers on

near real time basis. Rejection or keeping pending action can be done only between 11th to 18th of Next month for monthly filer.

34


Welcome FeaturesWelcome FeaturesFacility of Locking & Unlock Invoices • Recipient has wrongly accepted Invoices.• Supplier can’t amend already accepted Invoices • Recipient is allowed to unlock such wrongly accepted invoices • Only on unlocking such invoices by recipient, supplier can make

amendment in such invoices in next return.

Option to disclose who will claim Refund?• If Supplies are made to SEZ unit/developer with payment of tax an option

would be enabled for the Supplier to declare whether refund will beclaimed by supplier or the recipient

• Similar option is given in case of Deemed Export supply

35


Welcome FeaturesWelcome Features No Invoice level B2CL disclosure • In present GSTR‐1 B2C Supply where invoice value is more than Rs. 2.5 lakhs

needs to reported invoice wise. Whereas in new returns no invoice wise detailsare required for B2C supplies, irrespective of turnover.

Supplies liable under reverse charge • In GSTR‐1 supplier is required to disclose Invoice level details of supplies liable

under reverse charge on which recipient is required to pay GST. Whereas undernew returns recipient would disclose such supplies basis PAN / GSTIN & POS,consequently invoice level details are not required.

Facility to shift table • If details of the Supply Invoices/credit note etc. are correct but have been

disclosed in the wrong table, separate facility of shifting table will be madeavailable instead of amending the same. This will save time lost inamendment

36


Welcome FeaturesWelcome Features Auto flow of ITC in RET‐ 1/2/3 from ANX‐2 • Portal will allow ITC based on matching of documents as uploaded

by supplier, however option to avail ITC on provisional basis is givenin RET‐1. As per Section 43A provisional ITC can’t exceed 20% ofconfirmed credits

Missing Invoice details – Huge data points for Investigation • RTP while reversing provisional credit is mandated to disclose

GSTIN wise Invoice wise details of supplier who have not reportedsupplies within 2 months / 1 Quarter.

37


Welcome FeaturesWelcome Features Compliance status of Supplier now known to recipient • Status of return filing (not filed, filed) by the supplier will also be made known to

the recipient in ANX‐2 of the tax period after the due date of return filing is over.

Annexure and Return are now completely in Sync • Information declared through FORM GST ANX‐1 and FORM GST ANX‐2 shall be

auto‐populated in the main return (FORM GST RET – 1).

ITC utilisation Table • Suggested utilisation of ITC will be made available in the payment table.

However, taxpayer can make changes in the suggested ITC utilization

38


AgendaAgenda




Welcome Features Not so Welcome Features


Not So welcome FeaturesNot So welcome FeaturesHSN Reporting • For Small Tax payers (Turnover up to 5 Crore) HSN reporting is not mandatory.

For others including exporters at least 6‐digit HSN to be reported for goods andservices.

• Presently NN 12/2017‐CT(R) mandates disclosure of HSN details (0/2/4 digitsbased on Turnover of Preceding FY)

HSN wise, Rate wise disclosure• B2B Invoice to be uploaded HSN wise. If a invoice has 10 different items having 6

HSN, 6 line items to be reported.• If a B2B invoice has 10 different items having 6 HSN and 1 HSN has 2 different

GST rates (e.g. Readymade garments), 7 line items to be reported.• B2C Invoices HSN Reporting not required

40


Not So welcome FeaturesNot So welcome Features

Monthly payment for every one (including Sahaj and Sugamfilers)

• Presently Composition dealers are making quarterly payments whereas small tax payers opting for Sahaj and Sugam will be required to make monthly payments of GST.

Every one will be forced to opt for monthly return • Recipient will not get credit unless documents are reflected in ANX‐2. Quarterly

filers may not upload details on monthly basis by 10th of next month in ANX‐1• Recipient will have to undergo rigmarole of Provisional Credit.

41


Not So welcome FeaturesNot So welcome Features

Punching error can be costly !!!!• RTP has made error in punching details. E.g. Taxable value was correctly

mentioned in Invoice at Rs 10,000 + GST. While uploading taxable value ofRs. 10,000 was reported as Rs. 1,00,000.

• As GST payable is auto calculated by portal and for such punching errorCredit note can’t be issued, only recipient will have to reject such invoicein ANX‐2. However such rejected invoice can be amended by supplier onlyin next return consequently supplier will have to pay GST on Rs. 1,00,000first and on amending invoice next month can adjust his negative liabilityaccordingly.

42


Not So welcome featuresNot So welcome features

GST paid on Advances • If advance is paid for inward supplies attracting reverse charge, GST liability for such

advance will be disclosed in table 3H of ANX‐1 as Inward supplies attracting reversecharge in ANX‐1. New forms automatically shows such liability as eligible credit inRET‐1/2/3. RTP would be compulsorily required to reverse such ineligible ITC (asservices are not received) in RET‐1/2/3 else he runs risk of claiming wrong ITC.

• Ideally separate table should be given to disclose such advance in ANX‐1 and GSTpaid thereon shall not be auto populated as eligible credit in RET 1/2/3

Partial Credits• In situations where inward supply is partly used for outward taxable

supply and partly for exempt supply, there is no mechanism to claimpartial credits in ANX‐2. Consequently RTP will have to accept suchinvoices in ANX‐2 and then offer applicable reversal in RET‐1/2/3

43


Not So welcome featuresNot So welcome features

Blocked Credits • In situations where inward supply is subject to blocked credits, Recipient can’t

reject such invoice as there is no error in document details uploaded as such.Recipient is therefore required to accept such documents in ANX‐2 and thenoffer 100% reversal in RET‐1/2/3

No Provisional Credit in RET‐2 and RET‐3 • RTP opting to file RET‐2 and RET‐3 can’t claim provisional credit. Such

small tax payers will be hit hard if their vendor delays in filing outwardsupply details.

Obligation of Tax Collector shifted to Tax Payer• RTP is mandated to match and mismatch ITC while filing Return, Demand

of back end matching by Department is not accpeted

44


Not So welcome featuresNot So welcome featuresMissing Invoice can’t be disclosed in ANX‐1A• If any invoice is not disclosed in ANX‐1, same can’t be disclosed in ANX‐

1A. Supplier will have to wait till next period ANX‐1, consequently interestcost will continue. Ideally supplier should be allowed to disclose suchinvoice in ANX‐1A to save on interest cost.

Unless Tax is paid, RET‐1 can’t be filed • No facility of filing of RET‐1 without tax being paid / facility of installments

is missing

Single day delay in uploading documents in ANX‐1 willprove costly

• Even single day delay in uploading document details in ANX‐1 will costsupplier in terms of business, relations and recipient will have to undergorigmarole of Provisional credits.

45


AgendaAgenda

Not so Welcome Features



Welcome Features

Clarifications are welcome


Certain matters which need more clarification Certain matters which need more clarification Auto Interest working • Portal will auto‐calculate interest for Invoices on which ITC is already claimed but

later on rejected by recipient. However if recipient has sufficient ITC to offsetsuch reduction in ITC whether portal will accommodate such situation or willwork out interest ignoring such available credits

Rules not prescribed • Applicable rules for new returns are not prescribed.• Presently document can be amended in GSTR‐1 only once. Instructions to new

forms suggest number of times document can be amended in ANX‐1 will be asprescribed in Rules, which is not yet published.

Missing details amendment • Whether missing invoice details on which provisional credit is earlier claimed but

supplier has not disclosed in 2months / 1 quarter can be amended ?

47


Certain matters which need more clarification Certain matters which need more clarification

Period for which Liability will be accounted in RET‐1?• Eg. RTP has uploaded few invoices of April 2019 in ANX1 on say 12th May, 2019

(after due date), whether liability will be accounted in RET‐1 of April 2019 or May2019. Instructions of form only speak about eligibility of ITC in the hands ofrecipient in such situation.

PAN based reporting of Inward supply subject to Reversecharge

• Inward supplies attracting reverse charge can be reported on the basis PAN also. Whether such reporting is compulsory or voluntary? Whether recipient has legal power to ask PAN in absence of any specific provision in GST Act?

Fate of Unaccepted Invoices • Whether Unaccepted (Neither rejected nor kept pending) Invoice can be

amended by Supplier between 11th day to 18th day of next month

48


AgendaAgenda

Not so Welcome Features


Clarifications are welcome

Welcome Features

Kabhi KhushiKabhi Gham


Kabhi Khushi / Kabhi GhamKabhi Khushi / Kabhi Gham

Deemed filing of ANX‐2• Form GST ANX‐2 need not be filed separately but will be deemed to be filed

when Form GST RET‐1 is filed. Accidentally RTP may end up claimingwrong/blocked credits.

Amendment facility will increase compliance burden• If One B2C Invoice of say April 2020 which was disclosed in ANX‐1 and RET‐1 of

April 2020 was later on amended (value increased / reduced etc), same can beamended by filing ANX‐1A (to amend value) and GST‐RET 1A (To pay differentialtax / To recover excess paid tax)

50


FORM GST ANX‐1A vs ANX‐1FORM GST ANX‐1A vs ANX‐1

ANX‐1A to amendment to details of previously filed GST ANX‐1

Amendment of invoice, debit /credit notes shall be carried outthrough ANX‐1 A in relation totable• 3A(B2C),• 3C (Export with Tax),• 3D (Export without payment

of tax) ,• 3H (RCM),• 3I (Import of Services),• 3J (Import of Goods) and• 3K (SEZ Import)of FORM GST ANX‐1. [GSTIN ofsupplier not available]

ANX‐1A (Amendment)Amendment in relation to table• 3B (B2B),• 3E (SEZ Supply with tax),• 3F (SEZ Supply without tax)

and 3G (Deemed Export)shall be carried out in FORMGST ANX‐1 of the main return(FORM GST RET‐1) itself.[GSTIN of supplier available]

ANX ‐1 (Main Annexure)

52

THANKS !

Any Questions ?

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www.jkaca.in

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Jignesh KansaraCharteredAccountantsB-1208, Wall Street , ChakalaJunction, Near Holy Family Church, Andheri East, Mumbai 93Cell:+919987199329Email:[email protected]:www.jkaca.in

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