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GST Update on Rectification of Errors in GSTR-3B

Pradeep Jain
GST Circular: How to Correct Errors in FORM GSTR-3B Returns and Make Adjustments for Past Month Discrepancies Circular No. 26/26/2017-GST outlines procedures for rectifying errors in FORM GSTR-3B, which lacks provisions for reporting past month discrepancies. Errors can be corrected by reporting revised figures on a net basis in the current month's return. Negative entries are not allowed, and adjustments should be made in subsequent months' returns or claimed as refunds if necessary. Corresponding adjustments must be reflected in FORM GSTR-1. The circular addresses issues faced by taxpayers due to errors in returns filed since GST implementation. It clarifies that adjustments must be made in subsequent months if errors occur before filing. (AI Summary)

Circular No. 7/7/2017-GST dated 1st September 2017 was issued which clarified that errors committed while filing FORM GSTR – 3B may be rectified while filing FORM GSTR-1 and FORM GSTR-2 of the same month. It has been further decided that the time period of filing of FORM GSTR-2 and FORM GSTR -3 for the months of July 2017 to March 2018 would be worked out by a Committee of officers and communicated later.

Now Circular No. 26/26/2017-GST dated 29.12.2017 has been issued stating the way in which errors can be rectified in Form GSTR-3B which do not contain provisions for reporting of differential figures for past month. It is clarified that the revised figures may be reported on net basis along with the values for current month itself in appropriate tables. It may be noted that while making adjustment in the output tax liability or input tax credit, there can be no negative entries in the FORM GSTR-3B. The amount remaining for adjustment, if any, may be adjusted in the return in FORM GSTR-3B of subsequent month and, in cases where such adjustment is not feasible, refund may be claimed. Where adjustments have been made in FORM GSTR-3B of multiple months, corresponding adjustments in FORM GSTR-1 should also be made in the corresponding months. If the taxpayer has committed an error in submitting (that is before offsetting and filing) the information in FORM GSTR-3B, a provision for editing the same has been provided.

This has created a lot of problem for those who have filed the returns for five months since the implementation of GST and errors have been occurred while filing the return. Previously it was expected that the errors of FORM GSTR-3B would be rectified in GSTR-1 & 2. But due dates for filing GSTR-2 & 3 for the months of July 2017 to March 2018 has to be worked out. Now a circular has been issued stating that the rectifications in FORM GSTR-3B have to be amended in GSTR-1 (in case of Output liability) and further errors in the FORM GSTR-3B of subsequent months.

For instance while filing the FORM GSTR-3B for the month of July, Input tax credit of ₹ 1,00,00,000/- was misreported as ₹ 10,00,000/-. The return had been filed and ₹ 90,00,000/- was paid in cash. In this case, since the return has already been filed, the taxpayer shall add such Input tax credit in their return for subsequent months.

The content of this GST update is for educational purpose only and not intended for solicitation.

You can reach us at www.capradeepjain.com, at our facebook page on https://www.facebook.com/GSTTODAYBYPRADEEPJAIN/ as well as follow us on Twitter at https://www.twitter.com/@capradeepjain21

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