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The GST Council in its 31st meeting decided that a new GST return system will be introduced to facilitate taxpayers. In May 2019 a prototype of the offline tool has been shared on the GST Portal to give users a look and feel of the tool. The look and feel of the offline tool would be the same as that of the online portal.
14th March 2020*
The new GST return system will be implemented from October 2020.
The present return filing system (GSTR-1, 2A & 3B) will continue until September 2020.
*Subject to CBIC notification
The invoices which are uploaded by the supplier on the portal are called Uploaded Invoices. These invoices would be a valid document for availing input tax credit by the corresponding recipient. The invoices will be allowed to be uploaded continuously by the supplier and viewed by the recipients through ‘Viewing Facility’.
Accepted or Locked Invoice
The invoices which the recipients confirm after viewing are called Accepted Invoices. These invoices are the base for the input tax credit . The invoice which were not explicitly ‘rejected’ or marked as ‘pending’ shall be treated as an Accepted invoice.
For instance, When the supplier wrongly enters a GSTIN in the invoice then the invoice is available on the viewing facility of the taxpayer who is not allowed to take the credit. In such cases, the recipient rejects those invoices. Those are known as Rejected Invoice
The invoices which have been uploaded in the portal but falls under these categories :
The invoices which were not uploaded by the supplier but the recipient has claimed input tax credit are called Missing Invoices. The supplier shall report these invoices in the main return of any tax period with interest or penalty if applicable.
Any invoice can be amended by the supplier if the recipient has not availed the input tax credit on it and also the recipient has not accepted or locked it. No amendment of the invoice will be done if the above conditions are contradicted.
Amendment return is different from a regular return. If the taxpayer has made wrong entries in the return, he can amend the same in the Amendment return. The format will be very similar to Table 9A of the GSTR-1.
All the taxpayers registered under GST laws are required to file GSTR-monthly except the following :
The above taxpayers may either have to continue filing the existing returns prevalent under the current system or may fall under the category of taxpayers required to file the quarterly GSTR.
All the Taxpayers except the ones specified above are required to file monthly GST returns. Due Date for filing the same will be 20th of next month.
Example: Recipient received the goods in the month of July and also took the credit of the same, but the supplier has not uploaded the same, shall be reported by the recipient not later than return for the month of September filed in October.
|New Return||Old Return|
|Monthly Return has to be filed by taxpayers having turnover more than 5 crore in the last financial year||Monthly Return filed by taxpayer having turnover more than 1.5 crore in the last financial year|
|Only Uploaded Invoices by Supplier would be valid document for availing ITC||There is no matching concept present in current system, it is written in law but recipient could take credit for all such Invoices in GSTR-3B even not reported by supplier on self declaration basis|
|Recipient could also see the current filing status of Supplier||In GSTR-2A Recipient could see filed or not filed status for each uploaded Invoices by Supplier|
|Document summary is NOT required||Document Summary is required|
|Taxpayer can AMEND the main return 2 times in any tax period||Taxpayer only can amend the Invoices and CDN’s which has already been filed in earlier months|
|Amendment of Invoices can be possible only in these cases:|
>> Where ITC has not been availed
>> Invoices has not been reported as locked by recipient
|Amendment of Invoices can be possible for all type of supply which has been filed in earlier month returns|
|HSN Summary shall be captured at four digit or more in a separate table, similar as per old return||HSN Summary shall be captured at four digit or more in a separate table|
|Return format also includes “Annexure”of Invoices which shall auto populate the output liability table in the main return||In Return format data is populating with the Invoices uploaded by Supplier, no “Annexure” is required|
|For change in liability of more than 10% through an Amendment Return, a HIGHER LATE FEE may be prescribed||NA|
|For Export of goods taxpayer can fill “Shipping Bill” information at the time of filing of return or after filing the return at his option||For Export of Goods taxpayer will have to fill shipping bill details at the time of filing the return|
|Separate facility for uploading shipping bill details at a later date shall be provided to the Exporters||No separate facility for exporter is available|
|Profile base return is possible||No concept of Profile base return in present System|
|Taxpayer will have to submit all outward supplies including Inward supplies, with payment of taxes in SINGLE return||GSTR-3B (Summary Information for all sales and purchase)
GSTR-1 (For Outward Supplies)
GSTR-2 (For Purchases)
GSTR-3 (For settlement of liability)
|An IT tool/facility for matching of the Invoices downloaded in XL format will be available from the “Viewing facility”||No IT tool for matching of the Invoices is present|
|Missing Invoices shall be reported by the Supplier which has not been reported earlier, in the main return for any tax period with Interest and penalty as applicable||Where the input tax credit claimed by a recipient in respect of an inward supply is in excess of the tax declared by the supplier or the outward supply is not declared by the supplier in his valid returns, the discrepancy shall be communicated to both such persons|
|Reporting of missing Invoices can be delayed by the recipient upto TWO tax periods, taxpayer filing quarterly return shall report missing invoices in the next quarter||NA|
|Facility for locking the Invoice by recipient shall be available before filing the return||NA|
|Where GSTIN of the recipient has been wrongly entered by the supplier while uploading invoice details, such invoices will be reflected on the ‘viewing facility’ of a wrong taxpayer. Such taxpayers will be able to take action by accepting or rejecting the particular invoice.||Where GSTIN of the recipient has wrongly entered by supplier while filing GSTR-1, such invoices will appear in the auto-generated returns GSTR-2A of a wrong taxpayer. At present, the taxpayers are unable to take actions on GSTR-2A.|
|Recipient can also unlock the Invoices which have been locked earlier||NA|
|Facility for payment of tax is available through amendment return as it will save Interest liability||NA|
|Negative Liability arising from the Amendment Return shall be C/F to the next return||NA|