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Proposed GST Return - Salient features in brief

Manoj Agarwal
GST return obligations require a unified e-return, specified return types, reconciliation and automated enforcement measures. A single electronic return will cover central, state and integrated taxes and mandates periodic filing by all registrants, including nil returns. Regular taxpayers must file GSTR-1, GSTR-2 and GSTR-3 monthly, compounding taxpayers file quarterly GSTR-4, and all regular taxpayers file an annual reconciliation (GSTR-8) based on financial records with a 31 December cut-off; audited taxpayers must submit a CA-certified reconciliation. (AI Summary)
Dear Tax Payers,
 
Greetings of the Day!!
 
The Joint Committee on Business Process for #GST has submitted it's Report on GST Return. The salient features for proposed #GSTReturn are as below:

1. There will be common E-Return for CGST, SGST, IGST and Additional Tax.

2. Every registered person is required to file a return for the prescribed tax period. A return needs to be filed even if there is no business activity (i.e. Nil Return) during the said tax period of return.

3. Final invoice-level supply information pertaining to the tax period to be reported separately for goods and services. I have suggested at mygov.in that alternatively, it should also be allowed for customer wise i.e. aggregate supplies made to a GSTIN during a period should be allowed to be reported summarily instead of invoice level reporting to save valuable resources.

4. Normal / Regular taxpayers (including casual taxpayers) would have to file GSTR-1 (details of outward supplies) (Annexure-II), GSTR-2 (details of inward supplies) (Annexure-III) and GSTR-3 (monthly Return) (Annexure-IV) for each registration.

5. Compounding taxpayers would have to file a quarterly return called GSTR-4 (Annexure-V)

6. Annual return (GSTR-8) (Annexure-IX) will be filed by all normal / regular taxpayers. It will be based on financial records. Cut-Off date would be 31st December following the end of the FY. This statement would provide a reconciliation of the returns with the audited financial statements of the taxpayer. Since this return captures the minutest details of income and expenditure of the taxpayer, the gross profit/loss arrived on the basis of the details submitted in this statement should tally with the gross profit/loss indicated in the Profit and Loss Account of the dealer!!!
 
7. A separate reconciliation statement, duly certified by a Chartered Accountant, will have to be filed by those taxpayers who are required to get their accounts audited under section 44AB of Income Tax Act 1961. Currently this limit is ₹ 1 Crore under IT Act.

8. Cut-off date for filing of details of outward supplies (GSTR-1), inward supplies (GSTR-2) and Monthly return (GSTR-3) would be10th, 15th and 20th day respectively of the succeeding month for all Monthly filers.
 
9. There would be no revision of returns. All unreported invoices of previous tax period would be reflected in the return for the month in which they are proposed to be included. The interest, if applicable will be auto populated.
 
10. In case of failure by the taxpayer to submit periodic returns, a defaulter list will be generated by the IT system by comparing the return filers with the registrant database. Such defaulter list will be provided to the respective GST Authorities for necessary enforcement and follow up action. GST Law may also provide for imposition of automatic late fees for non-filers and late filers which can also be in-built in the notices.
 
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