Comparison Analysis: Old vs New GST Return System – Reporting of Exports, Zero-rated Supplies & Deemed Exports

The new GST return system will be rolled-out in phases from 1st October 2019. The main reason the old system got revamped is because of the need for a single, simple and concise return form, as compared to multiple return forms of complex nature that are currently being filed. Under the new system, there will be only one main return called the GST RET-1, which will comprise of 2 annexures – GST ANX-1 and GST ANX-2.

What are the forms under the new return System?

The main return GST RET-1 will contain all details of outward and inward supplies, along with taxes paid. The first annexure GST ANX-1 (Annexure of Supplies), is for reporting details of outward supplies, inward supplies liable to reverse-charge, and import of goods and services. The second annexure GST ANX-2 (Annexure of Inward Supplies) will contain details of inward supplies.

Reporting of the exports, the deemed exports and the supplies to SEZ will be done in GST ANX-1. From here, the information gets auto-populated in the main return GST RET-1 return. GST RET-2 (Sahaj) and GST RET-3 (Sugam) are the simplified returns which can be opted by B2C and B2B taxpayers with turnover less than Rs.5 crore in the previous FY. However, these returns do not support the declaration of export-oriented transactions, hence taxpayers having export transactions or its counterparts must use GST RET-1 only, which can be filed either monthly or quarterly. 

Where were exports, supplies to SEZ and deemed exports declared in the old return system?

Under the old return system, all data relating to exports, supplies to SEZ and deemed exports were declared under table 6 of the GSTR-1 return as follows:

Amendments, debit/credit notes and refund vouchers were to be reported under table 9 in the GSTR-1.

Where are exports, supplies to SEZ and deemed exports to be declared in the new return formats?

Exports, supplies to SEZ units/developers and deemed exports need to be reported in the following tables of form GST ANX-1: 

From GST ANX-1, the data gets auto-populated in the main return GST RET-1, in the following table:

What are the key differences in the reporting of exports under the new return system?

• No separate table for amendments: In GSTR-1, under the present return filing system, there was a separate table (table 9) for the reporting of amendments made. However, in the new return system, any edits and amendments can be reported in the same original tables in which the exports, supplies to SEZ or deemed exports were made (as mentioned above).

• Bifurcation of data based on payment made: Under the present system, exports, supplies to SEZ and deemed exports were to be bifurcated based on payments made i.e. with/without payment of IGST and reported under separate tables. Under the new system, this requirement has been consolidated to a single table.

• A functionality to update Shipping Bill details: There will be a separate functionality under the new return system to report bill of entry/shipping bill details, which was not available under the current return system. The same can now be reported under the relevant sub-tables under table 3.

• A new column introduced to intimate on refund claims: A new column titled “Would You Claim Refund?” has been introduced in GST ANX-1 for a supplier to intimate the authorities on whether he will be claiming an IGST refund. If he is not claiming a refund, he should mark the same in this column, so that the SEZ units/developers shall be eligible to avail input tax credit, and allow the refund claims for such credit, after export.

• Reporting of export transactions under Bond/Letter of Undertaking (LUT): In the present GSTR-1 return, export transactions effected without the payment of IGST (under  Bond/ Letter of Undertaking (LUT)) needs to be reported under “0” tax amount heading in tables 6A and 6B of GSTR-1. Under the new GST return system, no such requirement has been specified.