FAQs on Banking Sector under GST

FAQs on Banking Sector under GST

The CBIC has published the FAQs on different topics and sectors. Following are the FAQs on Banking Sector under GST:-  

Download The Full pdf for FAQs on banking Sector: Banking Sector

1. Whether Banks are required to capture the details of ATMs in registration certificate as a ‘place of business’?

Ans. No. Banks are not required to provide the details of ATMs while applying for registration. For the purposes of registration, ATM on its own does not constitute a place of business, as defined in the CGST Act, 2017.

2. As per RBI guidelines, Banks can use third-party ATMs, Business Correspondents (BC), Customer Service Points (CSP) or third-party warehouses. Are Banks required to include these third party places also in their GST registration?

Ans. No. Third party places are neither places of business nor fixed establishments from where Banks ordinarily carry on their business. These are independent service providers to the Bank which are subject to GST. Thus, these places are not required to be declared as a place of business by the Bank.

3. What will be the time of supply in respect of services rendered up to 30th June 2017 where the invoices are raised or payments are received after 30th June 2017?

Ans. Where the services are rendered up to 30th June 2017 and invoices in respect thereof are also raised on or before 30th June 2017, the point of taxation would be as per the earlier service tax law and the services will be subject to service tax.

Where the services are rendered up to 30th June  2017 and the services are liable to be taxed under the reverse charge mechanism, the point of tax for such services as per the Point of Taxation Rules, 2011 shall be the date of payment. If the payment is made on or after 1st July 2017, the supply of services shall be liable to GST.

4. Which tax is to be applied by the service provider on the invoice issued on or after 1st July 2017 for services rendered up to 30th June 2017?

Ans. The time of supply being the issuance of invoice under the CGST Act, 2017, the supplier of services must charge GST in this case. However, where the payment for such supplies has been made (prior to issuance of invoice) as advance before the 1st of July, 2017, the tax would be payable under the law prevalent prior to 1st July, 2017, as the point of taxation had arisen before this date to the
extent of advance.

5. Is it necessary for Banks / insurers to report the details of exempt and non-GST supplies in Table 8 of GSTR-1?

Ans. Yes. In the absence of any specific exemption to the Banks/insurers, the information is required to be provided in the said table.

6. Is it necessary for Banks/insurers to report the details of invoices in Table 13 of GSTR-1?

Ans. Rule 54(2) of the CGST Rules, 2017 provides that in case of an insurer or a banking company or a financial institution, including a non-banking financial company, the tax invoice or any other document in lieu thereof, may not be serially numbered. But this does not mean that such document will not have any identification number which is required for the purpose of matching. The said entities are, therefore, required to provide the details in column 5 to 7 (but not in column 3 & 4) of table 13 of FORM GSTR-1.

7. It is envisaged that many customers may not provide the GSTIN to the Banks in time. In such cases, the Banks/insurers would report the supply as B-to-C transactions in the returns filed by it. Later, in case the customer reverts with the GSTIN, how should this amendment be reflected?

Ans. A transaction once reported as B2C cannot be amended later to add GSTIN and convert the transaction as B2B.