Touted
as Good and Simple Tax (GST) by our Hon’ble Prime Minster, we believed it so.
But when we started finding HSN codes, setting up billing system, identifying
place of supply, determining the dilemma of applying IGST or CGST & SGST,
we came to know about the ground realities. Neverthless, we transcended the
journey of supplying and procuring goods and services in GST regime in July.
Now this Month of August is about payment of First GST liability coupled with
Returns. When, we were served with 3 return namely, GSTR-1,2 &3, GSTR-3B
took a wild card entry for July and August 2017. We thought a wild card entrant
will substitute the other strong Opponent GSTR-3. But time and again, we were proved wrong,
when Due dates for GSTR-1,2,3 & 3B were announced.
Now
a layman or for this matter even professionals are trying to find answers to 3
& 3B story. What is all about ? Would I file 4 returns for July &
August. Through this write-up we would attempt to address the confusion. Let’s
delve into returns one by one.
GSTR-1:
In
GSTR-1, you will report your outward supply (i.e. sale/service etc.) including
exports, SEZ supplies etc. Details would be filled in either Invoice-wise or
summary. Even details of Advance received, Debit Notes, Credit Notes, HSN
wise-summary will also be submitted. The criteria for Invoice-wise or summary
details is as under:
GSTR-2
GSTR-1
and 2 are twins and would always go together. GSTR-2 is Return for submitting
details of Inward Supply (i.e. Purchase/ services received etc.) including
import of goods/services. Most of the details in this Return would be
auto-generated from GSTR-1 filed by your Supplier and received by you in
GSTR-2A on GST Portal. You will verify details received in GSTR-2A and either
accept it or modify it to file your GSTR-2. The idea of matching of input tax
credit will be executed by GSTR-2 only.
GSTR-3
This
is a summary return of outward supply, inward supply, tax liability, tax paid
etc. Details in this return would be auto-generated from GSTR-1 & 2. You
will pay taxes with filing of this return either by cash or utilization of
Input tax credit or both.
Having
discussed 3 basic returns, let’s now understand the role of GSTR-3B.
What
is GSTR-3B. Is it a substitute of GSTR-3 ?
Firstly,
GSTR-3B is not a substitute of any other return. The law mandates filing of
GSTR-3B where due date of filing of GSTR-1 & 2 has been extended. Since,
due dates have been extended, consequently, GSTR-3B is required to be filed as
a provisional return for initial 2 months July and August. It means, GSTR-3
will still be filed for July and August. Yes. You heard it right, you would be
filing 4 returns for July and August.
The
sequence of returns filing for July and August, 2017 is as under:
Sequence
|
Remarks
|
July
|
August
|
GSTR-3B
|
Summary
Details only
|
20th
August
|
20th
Sept.
|
GSTR-1
|
Should
be matched with details submitted in 3B
|
1st-
5th September
|
16th-
20th Sept.
|
GSTR-2
|
Should
be matched with details submitted in 3B
|
6th
-10th September
|
21st-25th
Sept.
|
GSTR-3
|
This
will be auto-generated based on details furnished in 1,2 & 3B. You will
have an option to modify the details in case there is any discrepancy in 3B
filed earlier.
|
11th
to 15th Sept
|
26th
to 30th Sept.
|
Hence,
the Government has actually imposed 4 returns, instead of providing an option
that where GSTR-1 & 2 have been filed on time, you need not file GSTR-3B.
But it doesn’t seem so since GSTR-3B is mandatorily required to be filed by
virtue of Notification No. 21/2017-CGST, Rate dated 8th August,
2017.
Happy
Return Filing and Happy Independence Day !!
About Author:
CA. Nikhil M. Jhanwar is practicing Chartered Accountant in
Delhi/NCR specialising in GST, Start-up Advisory, Corporate Finance. He is also
a GST Trainer and Faculty Member of ICAI.
He has conducted various sessions on GST on different topics. He can be reached
at nmjhanwar@gmail.com/+91-8860876960.