The new GST quarterly returns are meant for the small businesses in India. It is an initiative by the GST Council to ease compliance procedures for such businesses. In this article, let us understand the key features of the new GST quarterly returns.

Who can file GST quarterly returns?

Persons whose turnover is up to Rs. 5 Crores in the last financial year can file quarterly returns.

Can a small business opt to file the monthly return instead of quarterly return?

A person whose turnover is up to Rs. 5 Crores has an option to file the monthly or quarterly returns. This choice will be taken from taxpayers at the beginning of a year. If the taxpayer wants to change from filing quarterly returns to monthly returns during a year, it can be done once during a year, at the beginning of a quarter.

How are quarterly returns different from monthly returns?

Quarterly returns will be simpler than monthly returns. The following details will not be required to be given in quarterly returns:

1. a. Missing and pending invoices

Missing invoices are the invoices which a taxpayer’s suppliers have missed uploading. Pending invoices are invoices which have been uploaded by the supplier but for which any of the following three situations exist:

• The supply has not been received by the recipient
• The recipient is of the view that the invoices requires amendment
• The recipient is not able to decide whether to take input tax credit on the invoice for the time being

A person filing quarterly returns will not be able to report missing and pending invoices. The GST Council has decided to omit these details from quarterly returns assuming that small businesses will deal with few known suppliers and situations of missing and pending invoices will not arise. However, in case a business requires the facility to report missing and pending invoices, they can opt to file the monthly returns.

1. b. Non-GST supplies, exempted supplies, etc. which do not create any liability.
2. c. Input tax credit on capital goods

However, persons filing quarterly returns will need to fill details of non-GST supplies, exempted supplies and input tax credit on capital goods in the Annual return.

What are the types of quarterly returns?

There will be 3 types of quarterly returns. Taxpayers can file the return which is applicable to them. The types of quarterly returns are:

a. Sahaj

Persons making purchases only from suppliers in India and supplying only to consumers or unregistered persons (B2C) in India can file the Sahaj return.

b. Sugam

Persons making purchases only from suppliers in India and supplying to both registered businesses as well as consumers or unregistered businesses (B2B + B2C) in India can file the Sugam return.

c. Quarterly return

Persons who make imports or exports, in addition to domestic purchases and supplies, can file the quarterly return.

How will the GST return filing procedure be?

The entire process of return filing will be simplified for all taxpayers. You can learn more about the new GST return filing procedure in our blog ‘New GST return filing process- A quick guide’.

Should tax be paid on quarterly basis also?

No, persons filing quarterly returns will need to pay tax on monthly basis. This will be done through a payment declaration form. In the payment declaration form, the taxpayer’s liability based on invoices uploaded will be shown. Similarly, input tax credit based on invoices uploaded by the taxpayer’s suppliers will be shown. Accordingly, the taxpayer can pay tax for each month. The benefit of payment declaration form is that it is not a return and minor mistakes made will not lead to legal action. This will again ensure that small businesses don’t have to pay additional penalties for minor mistakes made in the payment declaration form.

What happens if tax is not paid on monthly basis?

A taxpayer will be liable to pay interest for late payment of the tax due for each month.

Hence, the new GST quarterly returns are aimed at simplifying compliance for small business. Measures such as Sahaj and Sugam returns and the new GST return filing procedure are good steps in this regard. However, businesses must know that quarterly returns do not have the facility of reporting missing and pending invoices. If your business requires these facilities, it is recommended to opt for monthly returns.

The GSTR-3B of September, 2018 is little different compared to the GSTR-3B which you had filed all these days. The difference here is not about the format rather it is about compliance activities, effort and time involved in filing GSTR-3B of September, 2018.

Yes, you guessed it right! The difference is all about the last chance to claim unclaimed ITC on invoices pertaining to July’2017 to March’2018.

You might be aware that Input tax credit pertaining to invoices issued by the suppliers during 1 July 2017 to 31 March 2018 needs to be claimed on or before filing GSTR-3B of September, 2018. This implies that the last opportunity for you to claim ITC is to report it in GSTR-3B of September, 2018.

The good news is that the due date to file GSTR-3B is extended to 25th October, 2018 which was originally dated to 20th October, 2018.

Let us consider an example for ease of understanding.

If an invoice is issued by the supplier on 31 March 2018 and If ITC is not claimed on such Invoice in any of GSTR-3B filed till 25 October 2018, then credit pertaining to such invoice cannot be claimed and it will lapse.

In order to safeguard your ITC from getting lapsed, the following are some of the key actions which you need to consider before filing GSTR-3B of September, 2018.

• Download GSTR-2A from GST Portal
• Reconcile GSTR-2A with your books of Accounts.
• The reconciliation activity involves line-wise comparison of your purchase register with GSTR-2A.
• Post reconciliation, identify the purchases pertaining to July’17 to March’2018 on which ITC is not claimed.
• Ideally, purchases which are part of GSTR-2A but not reflected/accounted in your books are the ones which you need to look for and claim ITC.
• You may also need to verify your previous GSTR-3B returns to identify the invoices accounted in books but not claimed.
• After the identification of unclaimed purchase invoice, determine the ITC eligibility on such invoices. Meaning, the ITC should not be either blocked or restricted.
• Claim eligible ITC on Invoice pertaining July’17 to March’18 by reporting it in GSTR-3B along with ITC of September month.

Reconciliation of books with returns is key for any business to be GST complaint. It is not a one-time activity which you need to do it for availing unclaimed ITC, rather it is a continuous activity which needs to be carried out every month. The Reconciliation of returns with books of accounts will help the businesses in identifying the following:

• Suppliers who have not filed their GSTR-1
• Instances where wrong details are being disclosed by your Suppliers
• Cases where Wrong GSTIN is disclosed
• Invoices on which ITC has not been availed
• Mismatch due to Debit notes and credit notes issued

Over and above, it helps you to identify the GAP between 2Aà3BàBooks, follow-up and act on time.

While the benefits of reconciliation are many but you can leverage on these only with help of system assisted reconciliation. The efforts and time involved in manual reconciliation are huge. It involves line-by-line comparison of GSTR-2A with your books of accounts. Therefore, it is recommended that you need to have a software which automates the reconciliation activity by reading the GSTR-2A and the purchase invoices recorded in the books.

Using Tally.ERP 9, you can upload the GSTR-2A and automatically reconcile the purchases accounted in books and GSTR-2A. To know more, please read Reconciliation of GSTR-2A with Books of Accounts

It’s been more than 15 months since the introduction of GST  and by now, most of the businesses registered under GST are quite familiar in filing GST returns i.e. GSTR-1 which needs to be filed either quarterly or monthly and GSTR-3B on a monthly basis. Now, it’s time for businesses to file yet another return ‘Annual GST return in GSTR-9 Form’.

On 4th September 2018, the new GSTR-9 format for filing annual return was notified by CBIC which details the information to be furnished.  In this blog, we will understand the following:

What is GSTR-9?
Who Should File GSTR-9?
Different types of GST Annual returns
Due date to File GSTR-9
Penalty for Late Filing of GSTR-9

What is GSTR-9 Form?

Form GSTR-9 is an annual return to be filed by the businesses registered under GST. In Form GSTR-9, you need to declare the consolidated details of outward supplies, inward supplies, GST payable and ITC claimed for the previous financial year. For the previous financial year 2017-2018, you need to furnish the consolidated details of supplies made or received from July, 2017 to March 2018.

All you need to do here is to consolidate the details which you have already furnished through GSTR-3B and GSTR-1 either on a monthly or quarterly basis and declare it in the prescribed format of GSTR-9.

Who Should File GSTR-9 Form?

The annual return in GSTR-9 form needs to be filed by all the businesses who have obtained regular GST registration. In other words, the annual return in form GSTR-9 is not required to be filed by the businesses registered under Composition scheme, Input Service Distributor, casual taxable person, non-resident taxable and e-commerce operator.

Different Types of GST Annual returns

The following are the different type of annual GST returns applicable to the businesses.

Type of Business	GST Annual Return Form
Regular Registered Business	GSTR-9 Form
Business opted for Composition scheme	GSTR-9A Form
E-commerce Operator	GSTR-9B Form

Currently, only Form GSTR-9 format has been notified by the CBIC and other formats are yet to be notified.  Over and above the annual return form GSTR-9, the business who have obtained regular GST registration and if the aggregate turnover during a financial year exceeds 2 crore rupees, they are required to submit audited annual accounts and a reconciliation statement by filing GSTR-9C.

Form GSTR-9 Due Date

As prescribed in the GST Act, all the annual returns should be filed on or before the 31st of December following the end of such fiscal year. Thus, the GSTR-9 form for July’17 to March’18 is 31st December, 2018, unless it is extended through a notification. Currently, the provision for filing of GSTR 9 form in GST portal is yet to be made available.

Penalty for Late filing of GSTR-9 form

Failure to furnish the annual return in GSTR-9 form will attract penalty. A late fee will be levied if GSTR-9 is not filed with the due date. Late fees for failure to furnish GSTR-9 is 200 Rs per day (CGST 100 Rs + SGST 100 Rs). However, the maximum amount of penalty cannot exceed 0.25% of the total turnover of the taxpayer.

Form GST Sahaj is a quarterly GST return to be filed by 20th of the subsequent quarter. The businesses whose turnover in the previous financial year is up to 5 Crores and engaged in making outward supplies only to B2C i.e. end consumers or unregistered businesses can opt to file GST Sahaj return.

Though the GST Sahaj return filing is on a quarterly basis, the payment of GST needs to be made on monthly basis using the payment declaration form. The businesses need to determine the payable tax and Input tax credit on the self-assessed basis to determine the monthly tax payable.

In this article, we will understand the GST Sahaj return filing Cycle.

The details of outward supplies in GST Sahaj form are required only at a summary level. This is because, GST Sahaj is applicable only if you are making B2C supplies and your customer (the buyer) who is either an end consumer or an unregistered business who will not be in a position to claim ITC on the supplies made by you. Hence, the details are required only at summary level instead of invoice-wise.

Let us understand GST Sahaj return filing with an illustration

We have considered the April-June, 2019 to explain the GST Sahaj return filing cycle. In the above illustration:

• The taxpayer makes the self-assessed payment for the month of April, 2019 and May, 2019 using Payment Declaration Form.
• On completion of the quarter April to June, 2019, GST Sahaj return needs to be filed by 20th of July 2019 with the payment of Tax.
• In GST Sahaj form, the taxpayer needs to furnish the consolidated outward supplies details at rate-wise (5%, 12% etc.) and place of supply-wise.
• Input Tax credit details will be auto-populated in GST Sahaj form.
• As illustrated, as and when the invoices are uploaded by the supplier, details of ITC will be auto-captured in inward supplies annexure and which in turn gets auto-populated in GST Sahaj return form.
• Remember, quarterly returns forms will not have a concept of claiming and reporting ITC on missing invoices which supplier has not uploaded. You can claim the ITC only to the extent of invoice uploaded by the supplier.
• Once the required details are furnished in GST Sahaj return, the next step is to make payment.
• The tax payment here includes :
  • Tax payable for supplied made during 3rd month of the quarter.
  • Adjustment due to the difference in tax paid on the self-assessed basis in the first and second-month versus the outward supplies details declared in the Sahaj return.
  • Adjustment due to ITC claimed on self-assessed basis versus the auto-populated ITC available in inward supplies annexure.
• Once the tax payment is done, you can submit and file the GST Sahaj returns.

Conclusion

For businesses, the Sahaj return filing cycle is very simple. All you have to do is self-assessed monthly payment and mention the consolidated details of outward supplies. The rest of the details are auto-populated in Sahaj return. The businesses can leverage on simplification only when they carefully assess their businesses profile and choose the one which is suitable.

In order to simplify the GST return filing process, the GST council meeting held on 21st July, 2018 has approved the new GST returns. Different new GST return forms have been introduced considering the diversity of businesses operating in the country.

In another way, you must have heard the famous quote ‘One Size Does Not Fit All’. This is exactly the same reason for having new GST return forms. Based on the size the businesses, the type of supplies, the customers you deal with and the geography, the GST council has designed different type of new GST returns which will simplify the GST return filing process each of type of business instead of having a common GST return format for all.

In this article, we will understand the different types of new GST return forms which are approved by the GST Council.

As illustrated above, broadly the new GSTreturns are classified into quarterly returns and Monthly returns. Again, the quarterly returns are further classified into Form GSTR Sahaj, Form GSTR Sugam and GSTR quarterly.

Worried! Because there are too many GST Returns forms to be filed?

No need to worry! You are not required to file all the forms illustrated above. Just like selecting the right size which fits you, you need to select one of the new GST return forms which suits your business profile.

Let us understand each of the new GST return forms in detailed.

Quarterly Returns

The Registered businesses with the turnover up to 5 Cr in the previous financial year are allowed to opt for filing quarterly returns. However, the payment needs to be made on monthly basis and it will be a self-assessed basis. The input tax credit will be available only to the extent of invoices uploaded by the supplier. The quarterly returns will not have a concept of claiming ITC on missing invoices which are not uploaded by the supplier.

As illustrated above, quarterly returns consist of three different GST return forms which business can choose based on their profile.

Let us understand the different type of quarterly GST returns forms

1. Form GSTR Sahaj

The businesses who often purchase only from the domestic market (within India) and their 100 % outward supplies are made to end consumers and unregistered business, known as B2C supplies can opt for GST return Form Sahaj.

The details of outward supplies are required to be captured at summary level with a break-up of tax rate and place of supply.  The details of ITC from inward supplies annexure which gets auto-populated based on the invoices uploaded by the supplier.

2. Form GSTR Sugam

The Form GSTR Sugam can be opted by the businesses who supply to both B2B as well as B2C. This implies that businesses who make outward supplies to registered businesses (B2B), as well as end consumers or unregistered business (B2B), can opt for Sugam

The details of B2B supplies need to be captured at invoice level in outward supplies annexure from where the details will be auto-populated to Form GSTR Sugam. The details B2C supplies should be reported at a summary level in Sugam returns. Similar to Sahaj, the details of ITC will be auto-populated from inward supplies annexure based on the invoices uploaded by the supplier.

3. Form GSTR Quarterly Return

This is similar to Sugam and the only difference is that if you are engaged in making exports including SEZ, you need to choose GST quarterly return form. The format of the quarterly form will be similar to monthly return form applicable to large taxpayers.

The details of B2B supplies along with exports need to be captured at invoice level in outward supplies annexure from which the details will be auto-populated to Form GSTR Quarterly return.  The details B2C supplies should be reported at a summary level.  Similar to Sugam, the details of ITC will be auto-populated from inward supplies annexure based on the invoices uploaded by the supplier.

Monthly Return

The Registered businesses with the turnover exceeding 5 Cr in the previous financial year should file the monthly return with payment of tax.  Here, the businesses are required to upload all the B2B invoices which in turn gets auto-populated in outward supplies annexure and then the details will get auto-captured in your monthly return. ITC will be available on the invoices uploaded by the supplier with an option to claim and report the missing invoices which are not uploaded by the supplier. The monthly return along with the payment need to be filed by 20th of the subsequent month.

Conclusion

The new GST return forms are designed keeping in mind the diversity of businesses operating in the country. The simplification in new GST return filing will be possible only when you chose the right type of new GST return suitable to your business. Therefore, it is utmost important for a business to carefully asses their vendors, type of supplies, customers etc. and chose the return which will simplify the compliance.

After the introduction of GST on 1st July, ’17, the GST Council has repeatedly taken measures to simplify the GST return filing process for taxpayers. As part of this exercise, the GST Council is working to bring in the second phase of GST, with greater simplification in multiple areas of compliance. In our article ‘Highlights of new GST returns’, we learnt that the new GST return filing process can be summarised as ‘Upload-Lock-Pay’. Let us understand this process in detail.

New GST return filing process – Upload

Upload refers to the upload of invoices by suppliers. In the new GST return filing process, suppliers will have the facility to continuously upload invoices anytime during the month and the invoices uploaded will be instantly visible to the buyers.

New GST return filing process – Lock

Once a supplier uploads an invoice, the next step is for the buyer to lock the invoice. In this respect, the buyer has the following options:

Lock

Locking of an invoice by a buyer indicates that the buyer is accepting the transaction reported by the supplier. Only an invoice uploaded by the supplier and locked by the buyer will be eligible for claim of input tax credit by the buyer. Once a supplier uploads an invoice, buyers can lock the invoice any time before filing of the GST return for the period. Buyers who have a huge number of invoices to lock can make use of the facility of deemed locking. Under deemed locking, all invoices which are not marked as rejected or pending will be automatically locked when the buyer files the GST return for the period.

Here, an important point to note is that once an invoice is locked by a buyer, the supplier cannot make any amendments to the invoice. The supplier will need to issue a credit note or debit note to amend such invoices. However, in case a buyer has wrongly locked an invoice, the invoice can be unlocked by the recipient, provided input tax credit claimed on the invoice is reversed.

Reject

In case the supplier has entered the GSTIN of the buyer wrongly, the invoice would appear for a taxpayer who is not the actual recipient of the supply. In such a case, the taxpayer can reject the invoice.

Pending

A buyer can mark an invoice uploaded by the supplier as pending in the following scenarios:
a. The supply has not been received by the buyer
b. The buyer believes that the invoice needs to be amended
c. The buyer is not able to decide whether to take input tax credit on the invoice for the time being

A buyer cannot avail input tax credit on invoices marked as pending. An important point to note is that the facility to mark an invoice as pending is only available to persons filing monthly returns, and not for persons filing quarterly returns. We will discuss more about this in our blog on key features of the new GST quarterly returns.

New GST return filing process – Pay

The new GST return filing process is complete with the filing of return and payment of GST liability by both suppliers and buyers, after considering their respective input tax credit. As discussed earlier, every taxpayer’s eligible input tax credit will be automatically arrived at based on the invoices uploaded by their suppliers and locked by them. Similarly, their GST liability will be arrived at based on the invoices uploaded by them. Hence, majority of their new GST return will be auto-populated, thus ensuring that manual effort required to file the GST return is reduced significantly.

Hence, the new GST return filing process seeks to simplify compliance for taxpayers with the new feature of continuous locking of invoices by buyers. Buyers will not need to wait for the supplier to file their return to know whether the supplier has uploaded their invoice. Also, the facility of deemed locking will make buyers’ life easier by reducing the time required to lock invoices.