GST To do list for September 2020

GST To do list for September 2020

The month of September is quite important in GST. This term is used 7 times in the CGST Act. Out of those 7 times, one is covered in definition. Other 6 times it creates a timeline for one or other activity. 

Restriction for taking ITCRestriction for disclosure of Credit notesRestriction on the amendment of GSTR 1Restriction on the amendment of GSTR 2Restriction on the amendment of GSTR 3Restriction on ECO return

As you can see at 6 places it provides a restriction to some activity. Let us discuss them one by one.

Restriction on taking ITC-

• Section 16(4) imposes a timeline for taking the Input tax credit. A taxpayer can avail of the ITC for the invoices or debit notes for the previous financial year. But then the time limit to avail is the due date of filing return for the September Month. While filing the return for the month of September, detailed scrutiny of all purchases shall be done. Any input tax credit, if left to date shall be taken in the return of September month itself. Also, the return should be filed by the due date. The limitation is not of date of filing the return but the due date for filing the return. At present we claim an input tax credit in GSTR 3b. The general due date for filing of GSTR 3b is the 20th of next month.

Section 34(2) imposes a restriction on disclosure of credit notes. The last date is September itself. It is important to note that here the last date is not linked to the date of filing of any return. September itself is the last date. Thus the credit notes should be entered in the return filed in September month. Any credit issued after that can’t be entered in GST return. It will have a negative impact. The tax reversal for credit notes will lose. When a supplier issues a credit note, he reduces his output. The tax already paid on such output is reversed when we enter a credit note. But after this prescribed timeline, GSTN will not allow a credit note. Thus all of the credit notes shall be reviewed, missed credit notes shall be entered. We show credit notes in GSTR 1.

Amendment in various returns-

• GSR 2 is not available on the GSTN portal. But GSTR 1 and GSTR 3b can be amended till the last date provided in section 37 & 39. The date given in these sections is furnishing of return. Once the relevant return for September month is filed. No amendment for any error or omission is possible for the previous year. 
• Rule 36(IV) of CGST Rules provides for the restriction on the input tax credit. A taxpayer can avail the ITC of invoices reflecting in GSTR 2A. An additional amount of 10% of eligible ITC reflecting in GSTR 2A is also allowed. During the time of lockdown, the provisions of the rule were relaxed. A clubbing from the month of February to August was allowed. It means that a taxpayer can take the ITC of the amount reflecting in GSTR 2b from February to August, in any month. Let us have a look at the provision in this regard.

Thus in the month of September, while filing the return we will have to take care of input tax credit received and availed. The reconciliation shall be done for all the purchases from the month of February to August is required.