Aspects to be considered before filing GST Returns for September 2020

 

In view of the specific provisions of the GST law, following aspects need to be finalized before furnishing the returns for the month of September 2020:

 

Sr No	Section/ Rule Reference	Particulars	Action Required
1	Section 16(4) of CGST Act, 2017	ITC in respect of any invoice and debit note raised during FY 2019-20 shall not be available after the due date for filing the return for September 2020 or after furnishing the annual return for FY 2019-20, whichever is earlier	►    ITC on invoices and debit notes dated upto 31 March 2020 should be availed by 30 September 2020.   ►    In this regard, invoices received and unaccounted till date should be posted in books on or before 30 September 2020.  Reference in this regard can be made to the PR-2A reconciliation summary in respect of invoices appearing as addition in Form GSTR-2A.
2	Section 34(2) of CGST Act, 2017	Credit notes pertaining to FY 2019-20 against invoices raised during FY 2019-20 should be reported in Form GSTR-1 before filing the return for September 2020 or the annual return for FY 2019-20, whichever is earlier	►    Credit notes pertaining to invoices of FY 2019-20 should be issued on or before 30 September 2020 and reported in the GST returns to be filed for September 2020.    ►    Any credit note issued after 30 September 2020 will not be available as adjustment against GST liability and may be a cost to the Company.
3	1. Proviso to Section 37(3) of CGST Act, 2017 2. Proviso to Section 38(5) of CGST Act, 2017 3. Proviso to Section 39(1) of CGST Act, 2017	Rectification of error/ omission in respect of details already furnished in GST return	►    Undertake reconciliation activity between Form GSTR 1 and Form GSTR 3B and report any errors/ omission in the details furnished in GST returns for FY 2019-20, by rectification in returns to be filed for September 2020.   ►    Accordingly, any rectification on account of errors/ omissions in GST returns filed for the period between April 2019 to March 2020 would not be permissible after the above prescribed timelines.
4	Rule 42(2) of CGST Rules, 2017	Reversal of ITC in respect of inputs/ input services availed partly used for business purpose and partly for other purposes, or partly used for effecting taxable supplies including zero rated supplies and partly for effecting exempt supplies	►    The amount of ITC reversed on monthly basis during FY 2019-20 is required to be recalculated for the entire year before the due date for filing the return for September 2020.  Further, for any additional reversal there shall be interest liability.
5	Rule 36(4) of the CGST Rules	Rule 36(4) inserted vide Notification No. 49/2019 dated 9 October 2019, had restricted ITC availment to 110% (effective 1 January 2020) of the matched credit available in Form GSTR 2A.    Such reversal has been kept in abeyance for tax periods February 2020 to August 2020 in view of COVID-19 with an option to reverse the cumulative amount for these periods in the return to be filed for the month of September 2020.	►    Reversal of ITC under Rule 36(4) of the CGST Rules, if not reversed in the individual months of February 2020 to August 2020 should be done cumulatively and reported in the return to be filed for the month of September 2020.

 

Additionally, it should be noted that new return system alongwith e-invoices is also expected to go live from 1 October 2020. Further information in this regard is awaited from the Government and we will keep you posted on all relevant update in this connection.