LAST CHANCE FOR AVAILING ITC AND RECTIFICATION OF ANY ERRORS/OMISSION IN DISCLOSURES MADE IN THE RETURNS RELATING TO F.Y. 2018-19

Most of us are busy in F.Y. 17-18 itself. However we may miss the bus for compliance for F.Y. 18-19

It would be important to note the following important due dates for the F.Y. 2018-19 :-

(A) In terms of section 16(4) of the CGST Act, 2017, the due date for availing input tax credit (ITC) in respect of any invoice or debit note relating to F.Y. 2018-19 would be earliest of the following :

(i.) The due date of furnishing of the return for the month of September 2019 (i.e. 20th of Oct, 19), or

(ii.) The date of furnishing of the annual return for F.Y. 2018-19.

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(B) As per the first proviso to section 37(3) of the CGST Act, any amendments to the disclosures made in the returns or disclosure of additional details, pertaining to F.Y. 2018-19 would have to be done by :

(i.) The due date of furnishing of the return for the month of September 2019 (i.e. 20th of Oct, 19), or

(ii.) The date of furnishing of the annual return for F.Y. 2018-19, whichever is earlier.

(C) As per section 34(2) of the CGST Act, any adjustments by way of a credit note in respect of a supply made during F.Y. 2018-19 can be disclosed in a return filed up to :

(i.) 30th Sep, 19, or

(ii.) The date of furnishing of the annual return for F.Y. 2018-19, whichever is earlier.

(D) Credit re-computation in terms of rule 42 and 43 (in case of construction industry) of the CGST Rules, 2017 for businesses making taxable and exempt supplies. Comparison of the credit availed during F.Y. 2018-19 with the recomputed credit to identify any credit reversals or availment required. For the F.Y. 2018-19 this has to be done by due date of Sep, 19 3B return (i.e. 20th Oct, 19)

Thereby, it would be suggested to do the following to avail any missed credit or to disclose any credit notes or make any corrections in the disclosures in the returns, etc. for the F.Y. 2018-19 :

(A) Reconcile ITC as per books and the ITC as per Form GSTR-3B to check for any missed credits.

(B) Reconcile ITC availed in Form GSTR-3B and the entries in Form GSTR-2A to check for any missed credits.

(C) Re-computation of the credit eligibility as per rule 42 and 43 of the Rules, as applicable.

(D) Reconcile the turnover as per Form GSTR-3B and Form GSTR-1 to rectify any differences between the two.

(E) Review of the expenses (most importantly the foreign currency payments) to ensure that payment of tax under RCM is done and eligible ITC is claimed.

(F) Reconcile the credit notes issued as per books and the credit notes disclosed in returns to check if any disclosures are missed in the returns with respect to GST credit notes.

(G) Review of the contract terms or agreed clauses in respect of supplies made during F.Y. 2018-19 to identify any agreed downward revision in prices or discounts, that require issue of a GST credit note and issue and disclose the same.

Since the time available for the above is short, it is suggested that immediate steps be taken to address the above.

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