Last opportunity to rectify the GST errors of FY 2017-18:

It is Last opportunity to rectify the GST errors of FY 2017-18.That as per the provisions of the GST, 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 March 2019. Therefore, it is very crucial to identify the mistakes and to take care of such mistakes.
 Details of outward supplies (sales) can be modified on or before 11.04.2019 (being due date has extended for filing GSTR 1 monthly) and details of inward supplies (purchases) on or before 20.04.2019 (being due date for filing GSTR 3B).
 In this article it is focused on most probable errors in the returns and way to correct them on a timely manner.

Regarding Errors in respect of the Outward Supplies (Sales/ services) :-

1. Invoice / Credit Note pertaining to FY 2017-18 missed in GSTR 1: The invoice/Credit Note may be added in GSTR 1 along with invoices/Credit Note of March 2019 return 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 March, 2019 and pay the tax along with interest from due date of payment of tax till date of actual payment.
2. B2B Invoice details wrongly entered in GSTR: Here is a case where the invoice details are entered in GSTR 1 but some fields are wrongly mentioned. Some of the situations are:-
 Error in GSTIN i.e. Invoice is in name of Mr. X but GSTR 1 is filed mentioning GSTIN of Mr. Y.
 Error in taxable value.
 Error in tax rate, etc.
 These details may be modified in March, 2019 return.

3. B2C details wrongly entered in GSTR 1:

There will be again 2 types of errors in B2C details.
a) B2B invoice entered as B2C: If a 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 March 2019 along with March B2B invoices and amending the B2C supplies of January 2018 GSTR 1.

b) B2C Intra-state supplies entered as Inter-state: If B2C supplies of an assessee from the state of Maharashtra entered as B2C supplies of Andhra Pradesh i.e. Intra state entered as inter-state, the same may be rectified in 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.

c) B2C Inter-State supplies wrongly entered as different state: If B2C supplies made to Andhra Pradesh was entered as B2C supplies to Telangana by a supplier registered in Chhatisgarh; the tax liability doesn’t change but the state mentioned is wrong. This also doesn’t affect the liability but the wrong details needs to be rectified for correct disclosure.

Regarding Errors in respect of the Inward Supplies (Purchases):

1. Failed to avail ITC / Debit Note: Did you miss claiming ITC on any invoice/Debit Note pertaining to FY 2017-18, No worries; the same can be claimed upto the month of March 2019. Include the same in GSTR 3B of March 2019 and the ITC can be availed and utilised.

2. GSTR 2A Vs GSTR 3B: We have already informed you the availability of monthly comparison data of GSTR 2A & 3B which can be downloaded in Excel format from GST Portal. Many have been ignoring the reconciliation of ITC as per GSTR 3B with details available in GSTR 2A. This reconciliation exercise should be a continuous process since it is a time consuming one but major outcomes are as under:-

 Unearthing any missed credits i.e. supplies on which ITC is available but not availed will come into light 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 March 2019 is filed.
 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 2A. This exercise helps us to follow up with the supplier and intimating/educating them to file their GSTR 1.

3. RCM payable not shown or less shown in GSTR 3B returns filed for the period 2017-18 should be reconcile & consider now & pay the Tax on RCM in March-2019 return to avail ITC of same.

4. Excess ITC claimed / Debit Note not accounted: 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 GSTR 3B for the month of March 2019.

The situations discussed above are the most common issues which are required to be addressed in this March’19 return. Now, one may agree that March’19 month return is made crucial and hence please be cautious and re-visit all the returns filed, reconcile with books of accounts and GSTR-3B, GSTR 2A & GSTR 1 and claim/reverse the missed ITC and also rectify any errors that were made while filing the returns for FY 2017-18.

Remember: 30.06.2019 is the due date for filing Annual Return & Reconciliation Statement (GST Audit) for FY 2017-18. If the above errors won’t get timely rectified it will definetly affect the ITC reconciliations.

For any clarification please contact: gst@mrca.in Rashi Agrawal/ Arpit singh/ Shardesh Agrawal – 0771-4062170

CA Ashish Agrawal

Last opportunity to rectify the GST errors of FY 2017-18