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Extension in Due Dates filing of GST returns and Year end activities to be carried out before 30.09.2020 – Real Estate Sector

Manasa Reddy
New Deadlines Announced for Real Estate GST Returns: GSTR 9, 9C, 1, and 3B Extended to Sept 30, 2020 The article outlines the extension of due dates for filing GST returns for the real estate sector, with new deadlines set for various forms such as GSTR 9, GSTR 9C, GSTR-1, and GSTR 3B, among others, extending up to 30 September 2020. It specifies conditions regarding interest and late fees depending on turnover and filing dates. The article also details year-end activities required before the deadline, including reconciliations of accounts, ITC claims, and compliance with tax regulations. It emphasizes the importance of monthly reconciliations, invoice amendments, and vendor management for the real estate industry. (AI Summary)

Extension in Due Dates filing of GST returns and Year end activities to be carried out before 30.09.2020 – Real Estate Sector

Part A: Extension in Due Dates filing of GST returns

Form GSTR 9 & GSTR 9C

Tax period

Due date

Extended date

Remarks

FY 18-19

30.06.2020

30.09.2020

  • Registered persons having aggregate turnover for more than ₹ 2 Crores are required to file annual returns in Form GSTR 9.
  • Further, registered persons having aggregate turnover of more than ₹ 5 Crores are required to file reconciliation statement duly certified in Form GSTR 9C.

GSTR-1

Tax period

Due date

Extended date

Interest and Late fee

March’20

11.04.2020

30.06.2020

No Late fee, return filed on or before 30.06.2020

 

April’20

11.5.2020

May’20

11.06.2020

Quarter ending March’20

30.04.2020

Form GSTR 3B having aggregate Turnover > 5 Crores

Tax period

Due date

Extended date

Interest and Late fee

Feb’20 and March’20

20.03.2020

20.04.2020

24.06.2020

  • Return is filed within 15 days from original statutory due date.
  • No interest shall be payable.
  • Return is filed by 24.06.2020 then interest at the rate of 9% p.a. shall be payable from said 16th day till the date of filing return.
  • No late fee if filed within extended date.

April’20

20.05.2020

May’20

20.06.2020

27.06.2020

  • Return filed beyond extended date interest @18% p.a. shall be payable from the statutory due date.
  • If filed beyond relaxed date late fees would be levied from the original statutory date.

Form GSTR 3B having aggregate Turnover more than 1.5 Cr < 5 Crores

Tax period

Due date

Extended date

Interest and Late fee

Feb’20 and March’20

22.03.2020

22.04.2020

29.06.2020

  • No interest & late fee if filed till relaxed date.
  • However, 9% interest would be leviable if filed beyond extended date till 30.09.2020.

 

April’20

22.05.2020

30.06.2020

Filing of Form GSTR 3B having aggregate Turnover less than 1.5 Cr

Tax period

Due date

Extended date

Interest and Late fee

Feb’20

22.03.2020

30.06.2020

No interest & late fee if filed till extended date.

Mar’20

22.04.2020

03.07.2020

Apr’20

22.05.2020

06.07.2020

May’20

20.06.2020

Sep’20 (staggered dates to be notified)

June’20

20.07.2020

July’20

22.08.2020

Form GSTR 4 and CMP 08 for Composition Taxpayers

Tax period

Due date

Extended date

Interest and Late fee

Quarter ending Mar’20

18.04.2020

07.07.2020

No interest & late fee if filed till extended date.

FY 19-20

30.04.2020

15.07.2020

Filing of ISD return, TDS return and Form ITC-04

Tax period

Due date

Extended date

Interest and Late fee

Mar-20 to

May-20

13 day of

following

month

30.06.2020

The due date of compliance falls during the period from 20.03.2020 to 29.06.2020 is extended till 30.06.2020 Vide Notification number 35/2020,

 

Mar-20 to

May-20

10 day of

following

month

 

Jan-20 to

Mar-20

25.04.2020

  

Part B: GST–Year-end activities to be performed before 30.09.2020

Reconciliations to be performed

Books of Accounts

GSTR 1

GSTR 3B

GSTR 2A

Outward supplies as per books and GST returns

Yes

Yes

Yes

No

ITC claimed

Yes

No

Yes

Yes

Electronic Credit Ledger

Yes

No

Yes

Yes

Electronic Cash Ledger

Yes

No

Yes

Yes

Refund/Cancellations

Yes

Yes

Yes

No

ITC reversals/Blocked Credit

Yes

No

Yes

Yes

Tax paid under RCM  with RCM challans

Yes

No

Yes

Yes

Following points to be taken care on or before 30.09.2020 w.r.t Real Estate Industry:

  1. Monthly reconciliation for the purpose of GSTR 9 and 9C.
  2. Passing of ISD entries, raising the Invoices to map the books if any.
  3. Follow up for any required amendments in tax invoice (demand letters), debit note, credit note etc.
  4. Rule 37 – ITC reversal on account of non-payment within 180 days or reclaim of any ITC for which payment has been made.
  5. The defaulted vendors to be identified for the purpose of recovery of tax.
  6. Renewal of agreements w.r.t procurements if any.
  7. Mapping of revenue recoginition as per Ind AS 115 (if applicable) with the GST turnover disclosed in returns vis-a-vis Books of accounts.

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CMA Manasa Reddy

Goods and Services Tax - GST
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