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Analysis of extension of due dates under GST

Vivek Jalan
GST Notifications Extend Deadlines, Offer Relief on Interest, Penalties, and Fees; New Composition Scheme for Small Service Providers The Central Government issued several GST notifications on June 24, 2020, extending due dates for GST compliance. Notifications 51 and 52/2020-CT provide relief from interest and penalties for late filing of GSTR-3B for periods between February and July 2020, with varying interest rates and deadlines based on turnover. Notification 54/2020-CT extends the GSTR-3B filing deadline for August 2020 to October 1 or 3, depending on the state. Notification 53/2020-CT offers relief from late fees for non-filing of GSTR-1. Additionally, from April 1, 2020, service providers with turnovers up to 50 lakhs can opt for a composition scheme under specific conditions. (AI Summary)

Extension of due dates under GST

Recently Central Government has issued GST Notification No. 48/2020-Central Tax to Notification No. 54/2020-Central Tax on 24th June 2020 which relates to extension of Due dates under GST Law. Article analyses all such extension of due dates in recent past-

GST Due Date Extensions

N 51 52/2020-CT dated 24th June 2020 Relief from Interest & Penalty for Late furnishing of GSTR 3B

Period of ReturnDealersinterestLate FeeCondition/ Eg
Feb 2020 to April 2020Having PAN India turnover above ₹ 5 Crore– Lower rate of interest of NIL for first 15 days after the due date of filing return in FORM GSTR-3B

– @ 9% thereafter till 24th June 2020

– 18% thereafter

NIL – till 24th June 2020

₹ 100 per day (CT) – from initial Date if the above dates are violated

E.g. GSTR 3B for Feb 2020, Int is as follows –

1. Till 4th April –NIL

2. 5th Apr – 24th Jun – 9%

3. From 25th Jun 18%

Feb 2020 to April 2020Having PAN India turnover of ₹ 0 – ₹ 5 Crore

(For Simplicity Conservative dates have been taken for all states)

NIL – Till 30th June

2020 (For Feb 2020 3B)

– Till 3rd July 2020 (For Mar’20 3B)

– Till 6th July 2020 (For Apr’20 3B)

9% – From above dates till 30th Sep 2020

NIL – Till 30th June 2020 (For Feb 2020 3B)

Till 3rd July 2020 (For  Mar’20 3B)

Till 6th July 2020 (For Apr’20 3B)

₹ 100 per day (CT) – from initial Date if the above dates are violated

E.g. GSTR 3B for Feb 2020, Interest is as follows –

1. Till 3rd July – NIL

2. 3rd July – 30th Sep – 9%

3. From 1st Oct – 18%

May 2020 to July 2020Having PAN India turnover of ₹ 0 – ₹ 5 Crore

(For Simplicity Conservative dates have been taken for all states)

NIL – Till 12th Sep 2020 (For May’20 3B)

– Till 23rd Sep 2020 (For Jun’20 3B)

– Till 27th Sep 2020 (For Jul’20 3B)

9% – From above dates till 30th Sep 2020

NIL – Till 12th Sep 2020 (For May’20 3B)

– Till 23rd Sep 2020 (For Jun’20 3B)

– Till 27th Sep 2020 (For Jul’20 3B)

₹ 100 per day (CT) – from initial Date if the above dates are violated

E.g. GSTR 3B for May 2020, Interest is as follows –

1. Till 12th Sep – NIL

2. 13th Sep – 30th Sep – 9%

3. From 1st Oct – 18%

N 52/2020-CT dated 24th June 2020 One Time from Late Fees for non furnishing of GSTR 3B

Taxpayer CategoryLate FeeCondition/ Eg
GSTR 3B Not Filed between July, 2017 to January, 2020 – With SOME Central Tax Payable₹ 250/ – CT per monthThe return should be filed between July, 2020 to September, 2020
GSTR 3B Not Filed between July, 2017 to January, 2020 – With NO Central Tax PayableNIL

N 54/2020-CT dated 24th June 2020 Last Date of GSTR 3B for August 2020 Extended

Period of ReturnDealersLast DateLate Fee & Interest
August 2020Having PAN India turnover of ₹ 0 – ₹ 5 Crore1st October 2020 for Some States &

3rd October 2020 for Some States

NIL

N 53/2020-CT dated 24th June 2020 Relief from Late Fees for non furnishing of GSTR 1

Due Dates of GSTR 1 for All Taxpayers WITHOUT LATE FEES

Real Estate Developers paying Differential Tax Inst 3/2/2020

Use Form DRC-03 for making the payment of tax by promoter/developer required to pay tax in accordance with the N no. 11/2017- CT (R) N no. 3/2019- CT (R) ) on the shortfall from threshold requirement of procuring input and input services (below 80%) from registered person

N No 50/2020 – CT dated 24th June 2020 Sec 10(2A) read with Rule 7

From 1st April 2020, even Service Providers within a Turnover of ₹ 50 Lakhs and as per conditions u/s 10(2A) read wit Rule 7 may opt for Composition Scheme and pay Tax @6%

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