GST: Don’t miss the last chance to rectify errors of FY 2017-18

Nothing is more expensive than a missed opportunity – A penny saved is a penny earned

Any  rectifications  in  the  details  already  furnished  in  returns  of  July  2017  to  March  2018  may  be corrected/added  in  the  return  to  be  filed  for  the  month  of  September  2018.  Details  of  outward supplies can be modified on or before 31.10.2018 – due date for filing GSTR 1 and details of inward supplies on or before 20.10.2018 – due date for filing GSTR 3B.

·         Outward Supplies: –

  1. Invoice pertaining to FY 2017-18 missed in GSTR 1 – The invoice may be added in GSTR 1 along with invoices of September 2018 in Table 4 with original date. If the tax pertaining to invoice is also not paid, the same may be added to taxable value and tax of the month of September 2018 respectively and, pay the tax along with interest from due date of payment of tax till date of actual payment. However, the Annual return format i.e. GSTR 9 does not provide the facility to add these types of missing invoices but the most suitable disclosures may be made in Point 10 of Form GSTR
  2. B2B Invoice details wrongly entered in GSTR 1 –Here is a case where the invoice details are entered in GSTR 1 but some fields are wrongly mentioned. Some of the situations are:-
  3. Error in GSTIN i.e. Invoice is in name of Mr. A but GSTR 1 is filed mentioning GSTIN of Mr. B,
  4. Error in taxable value,
  5. Error in tax rate, ,

These details may be modified in Table 9A, 9B, 9C of GSTR 1. The same may be disclosed in Part V, Point 10 or 11 in GSTR 9.

  1. B2C details wrongly entered in GSTR 1–There will be again 3 types of errors in B2C details.
  • B2B invoice entered as B2C – If an B2B invoice pertaining to month of January 2018 entered as B2C in GSTR 1 of January 2018, this error can be rectified by adding the invoice details in GSTR 1 of September 2018 along with September B2B invoices and amending the B2C supplies of January 2018 using Table 10 of GSTR 1.

If the invoice is already declared in GSTR 3B correctly, the liability is not affected and the same will not be disclosed anywhere in GSTR 9.

  • B2C Intra-state supplies entered as Inter-state – If B2C supplies of an assessee from the state of Delhi entered as B2C supplies of Uttar Pradesh i.e. Intra state entered as inter-state, the same may be rectified using Table 10 of GSTR 1. However, if the same error is also continued in GSTR 3B too, the liability may be affected since IGST is paid instead of CGST+SGST. This can be rectified by paying CGST+SGST and claiming refund of IGST. The same needs to be disclosed in Part V, Point 10 of GSTR
  • B2C Inter-State supplies wrongly entered as different state– If B2C supplies made to Uttar Pradesh was entered as B2C supplies to Punjab by a supplier registered in Delhi; the tax liability doesn’t change but the state mentioned is wrong. This also doesn’t affect the liability, but the wrong details need to be rectified for correct

·         Inward Supplies: –

  1. Failed to avail ITC– Did you miss claiming ITC on any invoice pertaining to FY 2017-18, the same can be claimed upto the month of September 201 Include the same in

 

GSTR 3B of September 2018 and the ITC can be availed and utilised. These details are to be declared in GSTR 9.

  1. GSTR 2A Vs GSTR 3B – Monthly data of GSTR 2A can be downloaded in Excel format now. Many assessee have been ignoring the reconciliation of ITC as per GSTR 3B with details available in GSTR 2 This reconciliation exercise should be a continuous process since it is a time consuming one, but major outcomes are as under:-
    • Any missed credits i.e. supply on which ITC is available but not availed will come under notice when the reconciliation is done. It is important to note that the ITC pertaining to FY 2017-18 cannot be availed after the return for the month of September 2018 is
    • There may be situations where ITC has been claimed as per Invoice issued by the supplier, but the supplier failed to file GSTR 1. If supplier doesn’t file GSTR 1, the invoice details doesn’t appear in GSTR 2 This exercise helps us to follow up with the supplier and intimating/educating them to file their GSTR 1.
  2. Excess ITC claimed – There may be situations where excess ITC would have been claimed due to error. For example, instead of entering only tax amount in ITC IGST column in GSTR 3B, amount of purchases may be entered which inflates IGST ITC. The same may be rectified now by reversing the excess ITC availed by entering the amount to be reversed in Table 4(B)(2) of GSTR 3B for the month of September 2018 and the same may be disclosed in Part V Point 12 of GSTR

The situations discussed above are the most common issues which are required to be addressed in this September  return.  Now,  one  may  agree  that  September  month  is  made  crucial  even  from  indirect taxes point of view and hence please be cautious and re visit all the returns filed, reconcile with books of accounts and GSTR 2A and claim the missed ITC and rectify any errors that were made while filing the returns for FY 2017-18.