GSTR-3B : Return Filing, Format, Eligibility & Rules

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20th December is the deadline to file GSTR-3B for November
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What is GSTR 3B?

GSTR-3B is a monthly self-declaration that has to be filed a registered dealer from July 2017 till March 2018. Points to Note:

  • You must file a separate GSTR-3B for each GSTIN you have
  • Tax liability of GSTR-3B must be paid by the last date of filing GSTR-3B for that month
  • GSTR-3B cannot be revised
 

Who should file GSTR 3B?

Every person who has registered for GST must file the return GSTR-3B including nill returns.

However, the following registrants do not have to file GSTR-3B
  • Input Service Distributors & Composition Dealers
  • Suppliers of OIDAR
  • Non-resident taxable person
 

Late Fee & Penalty

Filing GSTR-3B is mandatory even for nill returns. Late Fee for filing GSTR-3B after the due date is as follows:

  • Rs. 50 per day of delay
  • Rs. 20 per day of delay for taxpayers having Nil tax liability for the month
Interest @ 18% per annum is payable on the amount of outstanding tax to be paid.
**Late fee for July, August, and September has been waived

Comparison between GSTR – 2A and GSTR – 3B: Importance and Procedure

Form GSTR – 3B is a monthly summary return filed by the taxpayer by the 20th of the next month. Taxpayers are allowed to take the input tax credit (ITC) based on the details declared by the taxpayer in Table 4 of Form GSTR – 3B:

  1. Eligible ITC
Details Integrated tax Central tax State/ UT tax Cess
A) ITC available
B) ITC reversed
C) Net ITC available [A-B]
D) INELIGIBLE ITC
GSTR – 2A is an auto-populated form generated in the recipient’s login, covering all the outward supplies (Form GSTR – 1) declared by his suppliers.

Matching GSTR – 3B and GSTR – 2A:

When the supplier files GSTR – 1 in any particular month disclosing his sales, the corresponding details are captured in GSTR – 2A of the recipient.

While the filing of Form GSTR – 2 has been kept in abeyance, it is still important under the GST framework for the taxpayers to reconcile the ITC claimed in Form GSTR – 3B and Form GSTR – 2A.

GSTR – 3B is a summary return. Hence, the amount of ITC available as disclosed in Table 4(a) must match with tax details disclosed in Form GSTR – 2A.  

It is important to reconcile Form GSTR – 3B and Form GSTR – 2A on account of the following reasons:

  • GST authorities have issued notices to a large number of taxpayers asking them to reconcile the ITC claimed in a self-declared summary return Form GSTR – 3B and auto-generated Form GSTR – 2A. Such notices are issued in Form GST ASMT – 10.  The taxpayer would be required to reply to such notices or pay the differential amount.
  • Action has also been taken against evaders claiming ITC on basis of fake invoices.  
  • Reconciliation ensures that credit is being claimed only in respect of the tax which has been actually paid to the supplier.
  • Ensures that no invoices have been missed/ recorded more than once etc.  
  • In case the supplier has not recorded the outward supplies in Form GSTR – 1, communication can be sent out to the supplier to ensure that the discrepancies are corrected.
  • Errors committed while reporting details in GSTR-1 by suppliers or GSTR-3B by recipients can be rectified.
Reasons for non-reconciliation of GSTR – 2A and GSTR – 3B:

The details disclosed in Form GSTR – 2A and Form GSTR – 3B may not reconcile on account of the following reasons:

  • Credit of IGST claimed on the import of goods
  • Credit of IGST on the import of services
  • Credit of GST paid on reverse charge mechanism etc.
  • Transitional credit claimed in TRAN – I and TRAN – II.  
  • ITC for goods and services received in FY 2017 – 18 but availed in FY 2018 – 19.
In the cases mentioned above, the figures will not reconcile as no corresponding Form GSTR – 1 is being filed by the supplier or the ITC is being claimed at a later date.

Discrepancies in GSTR – 2A and GSTR – 3B:

After considering the situations mentioned above, if any discrepancies are found in Form GSTR – 1 and GSTR -3B leading to any excess ITC claimed by the recipient, the same must be paid by the taxpayer along with interest.

It is, therefore, necessary that this reconcile exercise is done on a regular basis to ensure that only bonafide input tax credit is claimed.   

Reconciliation at the time of filing of Annual return:

Even at the time of filing an Annual return in Form GSTR – 9, reconciliation of ITC as per GSTR – 3B and GSTR – 2A is required to be done in Table 6 and Table 8.   

 

How to File GSTR-3B on ClearTax GST Software?

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General GSTR-3B Queries
  • I have no sales or purchase in a month. Should I still file GSTR-3B?
    Yes, GSTR-3B has to be filed by every registered person even if there are no transactions in a month.
  • Should I provide invoice wise details on the return?
    Only consolidated numbers are required in GSTR-3B. Invoice wise breakup is not required.
  • I have 2 GSTIN’s. One in Delhi and other in Assam. Can I file 1 GSTR-3B for both registrations?
    No. GSTR-3B has to be filed for every GSTIN separately. The returns cannot be clubbed.
  • Can I file the return using ClearTax GST Software?
    You can prepare and upload your GSTR-3B using ClearTax GST Software. But the final submission and filing have to be done on GST portal/GSTN.
  • Will there be any invoice matching in GSTR-3B?
    Invoice matching is not done in GSTR-3B. This return is more of a self-declaration.
  • Do i have to file GSTR-1, GSTR-2 and GSTR-3 even after filing GSTR-3B?
    GSTR-1 has to be filed on a monthly or a quarterly basis depending on the turnover. Due dates and filing of GSTR-2 and GSTR-3 will be worked out by the GST Council soon. You have to file GSTR-3B every month.