Overview of New GST Returns
New GST Returns
New GST returns are going through a public trial currently. New GST returns are scheduled to roll out with effect from Sep 1, 2020.
In order to reduce complexity and address various issues in GST returns filing, it was decided by GST council that new and simplified GST returns will be introduced in India. These new GST returns are set to roll out with effect from 01-Apr-2020. All businesses and tax professionals must build the knowledge, skills and tool-set so that smooth and error-free GST return filing can continue even after the introduction of new GST returns.
# Forms & Annexures
In the new simplified GST returns scheme, there are 2 annexures and 1 periodic GST return.
|ANX-1||Details of outward & some of the inward supplies. This needs to be uploaded by tax-payer to GST Portal.|
|ANX-2||Details of inward supplies. This is auto-populated based on ANX-1 uploaded by suppliers. Tax-payer can download it from GST Portal and may take actions on documents reported by suppliers.|
|Declaration of tax liability and ITC claim. Depending on the turnover and nature of supplies, tax-payer can select one of three returns (RET-1/RET-2/RET-3) and monthly/quarterly filing.|
|PMT-08||To be filed monthly by quarterly-filers for the payment of tax. It is a very simple form containing consolidated figures of liability and ITC declaration.|
# Filing Profile & Periodicity
Tax-payer is allowed to opt for quarterly return if the total turnover in last financial year is up to 5 cr. In case of quarterly return, tax-payer can further opt for smaller periodic return RET-2 or RET-3 depending on the nature of transactions. This process has been depicted in following diagram:
Quarterly returns are optional for eligible tax-payers. For example, a tax-payer is free to choose monthly filing even if he is eligible to select Quarterly Sahaj filing.
Features and contents of various filing profiles
The following table shows the features and contents available in different filing profiles. Please consider the limitations of Sahaj/Sugam filing profile before selecting it.
|Nature of supplies||Sahaj||Sugam||Normal Quarterly||Normal|
|Supplies to consumers or unregistered persons (B2C)|
|Supplies to registered persons (B2B)|
|Supplies to SEZ|
|Sales via e-commerce platforms|
|Import of Services|
|Import of Goods|
|Import of Goods from SEZ|
|Provisional ITC on invoices not reported by suppliers|
# Timeline of Monthly Filing
Tax-payer can upload the documents and summary in ANX-1 anytime except 18th to 20th of every month. Similarly, tax-payer can download ANX-2 anytime during the month and lock the invoices/documents uploaded by supplier by accepting them.
ANX-1 upload stop window conincides with due date of filing monthly return RET-1. Therefore, if you don't upload ANX-1 before 18th, you will not be able to file RET-1 timely.
# Timeline of Quarterly Filing
Tax-payer can upload the documents and summary in ANX-1 anytime except 23rd to 25th of the month following the quarter. Similarly, tax-payer can download ANX-2 anytime during the quarter and lock the invoices/documents uploaded by supplier by accepting them.
ANX-1 upload stop window conincides with due date of filing quarter return RET-1/2/3. Therefore, if you don't upload ANX-1 before 23rd, you will not be able to file RET-1/2/3 timely.
Even in case of quarterly filing, tax-payer still need to file PMT-08 monthly for payment of tax. PMT-08 is very simple form in which consolidated figures of tax liability and ITC claim need to be reported.
This annexure contains details of both outward and inward supplies.
# Details of outward supplies
Outward supplies subject to reverse charge, is not reported in ANX-1.
|B2C||Supplies to consumers or unregistered persons||Consolidated summary of sales in each state for different GST rates. Net value of sales, credit/debit notes needs to be reported.|
|B2B||Supplies to registered persons||Each document including all line items|
|Export||Export supplies with or without payment of tax||Each document including all line items|
|SEZ||SEZ supplies with or without payment of tax||Each document including all line items|
|DE||Deemed export supplies||Each document including all line items|
|ECOM||Supplies made via e-commerce platform||Consolidated summary of sales, sale-returns, net taxable value and, tax amounts for each e-commerce platform|
# Details of inward supplies
|RCM||Purchases subjected to reverse charge||Consolidated summary of taxable value and tax amount to be reported by the recipient, GSTIN wise for every supplier, net of debit/credit notes and advances paid, if any. If supplier is not registered, supplier's PAN has to be reported.|
|IMPS||Import of services||Consolidated summary of taxable value and tax amount for each place of supply. Net value of invoices, debit/ credit notes and advances paid needs to be reported.|
|IMPG||Import of Goods||Details of Bill of entry along with all line items|
|IMPG-SEZ||Import of goods from SEZ on bill of entry||Details Bill of entry along with all line items|
|Missing Invoices||B2B invoices on which provisional ITC was taken in earlier period and still not reported by supplier||Each document including all line items|
# Supplier Liability & Receiver ITC
Receivers will be able to see and claim ITC on invoices which are uploaded by suppliers before the 10th of next month. If supplier uploads an invoice after 10th of next month, receiver will be able to claim ITC on it in next period only. But the liability has to be discharged by supplier in the same month. For example, assuming both supplier and receiver are filing monthly, consider these two invoices:
|Invoice No||Invoice Date||Supplier Uploaded On||Supplier Return||Receiver Return|
|N1||25/07/2019||09/08/2019||Supplier has to discharge this liability in RET-1 of Jul-2019 (which has to be filed on or before 20-Aug-2019)||Receiver can claim ITC in RET-1 of Jul-2019 (to be filed on or before 20-Aug-2019)|
|N2||28/07/2019||11/08/2019||Supplier has to discharge this liability in RET-1 of Jul-2019 (which has to be filed on or before 20-Aug-2019)||Receiver can claim ITC in RET-1 of Aug-2019 (to be filed on or before 20-Sep-2019)|
In above case, receiver can claim ITC on N1 in RET-1 of July 19. But ITC claim on N2 is possible only in RET-1 of Aug 19. However, supplier will have to discharge the tax liability of both N1 & N2 in RET-1 of July 19.
The details of invoices/documents reported by suppliers is made available to receivers in ANX-2.
|B2B||Auto-populated details of inward supplies from registered persons||Each document with supplier trade name and all line items including HSN code as reported by supplier|
|ISD||Auto-populated details of ITC received from ISD (Input Service Distributor)||Each document including tax amounts|
Accept: If a document is available in ANX-2, receiver can lock it by accepting that document. Once it is locked, supplier will not be able to make any changes to that document.
Reject: If the details in the invoice/document uploaded by supplier are incorrect, Receiver can reject that document. Suppliers will be able to see all rejected document in next period so that they can make suitable amendments and upload again.
Pending: If the receiver does not wish to claim ITC in the same period, receiver can keep the invoice/document pending. All such pending invoices will be rolled over to next period.
Points to note:
- Receiver cannot modify any invoice. Receiver can only reject it. Only supplier can amend the invoices in next period.
- If receiver does not take any action on the invoices appearing in ANX-2, all invoices will be deemed accepted.
- If the supplier does not file the return for two consecutive periods and uploads an invoice in ANX-1, receiver will be able to see that invoice in ANX-2 but ITC will not be available on such invoices.
This section compares the new GST returns with current returns to highlight the main changes:
|Information||Current GST Returns||New GST Returns|
|Claiming ITC||ITC can be claimed in GSTR-3B on the basis of self assessment.||ITC will be auto-populated in RET-1/2/3 based on invoices accepted in ANX-2. Although provisional ITC can be claimed but if supplier does not report the same in next period, all such missing invoices has to be reported by receiver. It is also proposed that facility of provisional ITC will be removed eventually.|
|Reverse Charge Supplies||Outward B2B supplies subject to reverse charge, needs to be reported in GSTR-1.||Outward RCM supplies are not reported.|
|Credit/Debit Notes||Invoice number and date against which the credit/debit note is issued, has to be reported.||Reference invoice details is not reported.|
|Large B2C Invoices||Large B2C invoices (interstate sale worth more than 2.5 lakh) has to be reported at invoice level in GSTR-1.||No separate identification of B2C small or large. Only consolidated summary of all B2C invoices need to be reported in ANX-1.|
|HSN Details||HSN summary of outward supplies is reported in GSTR-1.||HSN code details has to be reported with each invoice. Separate HSN summary is not reported.|
|Doc No Series||Document number series (invoice or credit/debit no) is reported in GSTR-1.||Not reported.|
# Trial Run on GST Portal
New GST returns will be introduced from Sep 1, 2020. Current facility of new GST returns on GST portal is for trial run only. Data uploaded in new returns is not used for liability of ITC calculation & it will be deleted before the roll-out.
Government has provided the facility to try new GST returns on GST Portal. All tax-payers are encouraged to use this facility to test and prepare their IT systems for new GST returns. Tax-payers are also encouraged to submit their feedbacks to improve the new GST returns and eliminate any issues before their introduction.
Octa GST has also been updated to facilitate the tax-payers to try the new GST returns on GST Portal. Using Octa GST you can:
- Upload Sales/Purchase data
- Prepare & preview ANX-1
- Generate JSON of ANX-1 and upload to GST Portal
- Download JSON file of ANX-2, add in Octa GST and view the data uploaded by suppliers