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GST AND FINANCIAL YEAR 2017-18

Dr. Sanjiv Agarwal
GST year-end compliance: review transitional credits, invoices, and reconciliations to secure correct carry-forward and tax positions. GST year-end compliance requires completion of transitional migration tasks and securing correct carry forward of tax positions. Taxpayers must ensure payment and filing obligations, raise or rectify all invoices and debit/credit notes within the year, confirm applicable GST and compensation cess rates, and address TDS/TCS and tax on advances. Conduct due diligence on transitional and ongoing input tax credit, make necessary reversals or adjustments, perform inter ledger reconciliations, verify valuation of closing stock, and ensure anti profiteering compliance before books are closed. (AI Summary)

The first financial year of GST regime is coming to an end next week on 31.03.2018. This is also the year of transition or migration of old indirect tax regime (VAT, Service Tax, Central Excise and other taxes)  into goods and services tax regime (GST).

Accordingly, the current financial year 2017-18 is crucial for transitional events as well as carry forward of balances including input tax credit and various compliances which may have ramifications and monetary impact in future for tax payers.

Here are few events which ought to be verified, documented and suitable action taken:

  • Re-check all due dates and compliances as dates for payment, filing etc were extended more than once.
  • Check compliances on account of temporary exemptions, withdrawal, etc in implementation of various provisions such as TDS, TCS payment under reverse charge, tax on advances for goods etc.
  • Rates of GST have been changed several times. Ascertain application of correct GST rate on items of goods and services based on effective date of such rate change. The same may be followed for levy of compensation cess.
  • All invoices required to be raised must be done within the year.
  • Due tax payments to be made before 31.03.2018, if not paid so far.
  • Pending or due returns to be filed now, if not done till now
  • Ensure that invoices may be raised and debit or credit notes issued as may be required. Defective invoices be rectified before year end. This is more important in case of Government contracts and continuous supply cases.
  • The correctness of input tax credit and transitional credit may be ascertained by way of an independent or internal supervisory due diligence. If required, credit reversal may be done.
  • Any adjustments in accounts, invoices etc can be done now before 31st March, 2018 so that all balances are correctly carried forward and books of accounts are clean of any past error / adjustment w.e.f. 1.4.2018.
  • Proper inter-account / ledger reconciliations may be done.
  • Verification and valuation of closing stock as on 31.03.2018 ought to be done
  • Taxpayers should also ensure compliance with anti-profiteering law to avoid possible penal action, once books are closed.
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