GST Insights- Compliances before 31st March 21 and Changes w.e.f. 1st April 2021

I. Compliances before 31st March 2021

A. File GSTR 9 & 9C for F.Y. 2019-20

The due date file GSTR-9 (for taxpayers having aggregate turnover of more than 2 crs.) and GSTR-9C (for taxpayers having aggregate turnover of more than 5 crs.) has been further extended from 28th February 2021 to 31st March 2021 by CGST Notification No. 04/2021 dated 28.02.201 which can be accessed here 2019-20

B. File LUT for zero-rated supplies for F.Y .2021-22

Taxpayers are required to submit a Letter of Undertaking for undertaking zero-rated supplies i.e. export of goods or services or supply to SEZ Unit/Developers without payment of IGST every Financial Year. For F.Y. 2021-22, LUT is due to be filed latest by 31st March 2021 if you are engaged in zero-rated supplies or planning to do it:

Note: ARN generated vide LUT filed should be mentioned in Tax Invoice raised for Export/SEZ Supplies

C. Opt-in for GST Composition Scheme for F.Y. 2021-22

If you wish to opt for the Composition Scheme subject to the fulfilment of criteria and conditions for F.Y. 2012-22, the last date to file CMP-2 is 31st March 2021.

Note: In case of the switch from Normal to Composition Scheme, ITC claimed on inputs lying in form of Inputs, WIP, finished goods stock as of 31.03.2021 and capital goods (on a reduced percentage basis) is required to be reversed by filing ITC-03 by 30th May 2021.

Related Topic:
GST Impact On Death of A Proprietor – Law and Procedure

If you wish to know all about the Composition Scheme, please read our Presentation @ All about Composition Scheme

D. Re-calculation of Aggregate Turnover as per F.Y. 2020-21 for criteria for F.Y. 2021-22

Various decision making and compliances in GST are dependent upon threshold as per Aggregate Turnover like GST registration, Composition Scheme, QRMP Scheme, E-Invoicing, Rule 86B etc. For F.Y. 2021-22, please make sure that recalculation is done for each of the relevant compliances as per aggregate turnover in F.Y. 2020-21 wherever applicable.

Related Topic:
RESTAURANT AND OUTDOOR CATERING SERVICE

E. Year-end reconciliation of Outward Supplies and Inward Supplies

It is the right time to do stock-taking of what you’ve earned from books of accounts, GST, Income tax and ROC point of view to ensure that Turnover reported is duly reconciled for all statutory reports and financial statements. Any additional liability, if missed should be reported in the GST return of March 2021.

Similarly, you should undertake a detailed reco of the Input tax credit as per books of accounts vs. GSTR-3B vs. GSTR-2A vs. GSTR-2B vs. Rule 36(4). In the case of hits and misses, all adjustments (claim or reversals) should be reported in the GST return of March 2021.

Note: In case of RCM liability, it is suggested to also look for entries appearing in GSTR-2A ticked as ‘RCM’ by Suppliers and ensure that RCM liability has been paid. Further, please report exempted supplies like interest income in GST returns as well.

F. Yearly calculation of reversal of ITC as per Rule 42

In case of any reversal of common Input Tax Credit on account of exempted supplies as per Rule 42, after having undertaken monthly reversal, the annual calculation is required to be done and any excess reversal or short reversal should be duly accounted for in GST returns for March 2021. In case of delay in reporting of additional reversal, if any, Interest would apply from 1st April 2021 onward for common ITC reversals to be done in F.Y. 2020-21

Note: The value of exempted supplies for the purpose of reversal includes the value of the sale of immovable property, a transaction in securities, outward supplies subject to RCM, Restaurant services/outdoor catering services taxable @5%

II. Changes effective from 1st April 2021

G. Applicability of E-Invoicing in case of B2C supplies from 1st April 2021

The Government has notified by Notification No. 14/2020– Central Tax dated 21.03.2020 that an invoice issued by a registered person, whose aggregate turnover in any preceding financial year from F.Y. 2017-18 onwards exceeds INR 500 crs. to an unregistered person (‘B2C invoice’), shall have Dynamic Quick Response (QR) code w.e.f. 1st December 2020.

It was further provided that where such registered person makes a Dynamic Quick Response (QR) code available to the recipient through a digital display, such B2C invoice issued by such registered person containing cross-reference of the payment using a Dynamic Quick Response (QR) code, shall be deemed to be having Quick Response (QR) code.

However, vide Notification No. 89/2020–CGST dated 29.11.2020 Government has waived off the amount of penalty payable by any registered person under section 125 of the said Act for non-compliance of the aforementioned provision, for the period between 1st December 2020 to 31st March 2021, subject to the condition that the said person complies
with the provisions of the said notification from 1st April 2021.

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