Comparing GSTR-3B with GSTR-1 is a much-needed process to be undertaken by every taxpayer in order to ensure that there are no variations or gaps, which could, in turn, lead to a demand notice from the tax authorities or unwanted issues that may arise and hinder the accurate filing of the annual returns.
Latest update as on 30th June 2020
The maximum late fee to be capped at Rs 500 per return, for the tax periods given below, filed after the deadlines given in notification 52/2020 (as listed in the below at sl.no. 2 dated 24th June 2020) but before 30th September 2020, whereas nil return to not be charged any late fee.
1. For turnover more than Rs 5 crore: May 2020 – July 2020
2. For turnover equal to or below Rs 5 crore: February 2020 – July 2020
Latest update as on 24th June 2020
1. The CBIC has waived/reduced late fees for the late filing of GSTR-3B returns for the period July 2017 to January 2020, as follows-
a) If GST liability is Nil, and the GSTR-3B return is filed between 1st July, 2020 and 30th September, 2020, then the amount of late fees stands waived.
b) If the GST liability is not Nil, and the GSTR-3B return is filed between 1st July, 2020 and 30th September, 2020, then the amount of late fees stand waived in excess of Rs.250* under the CGST Act.
*Rs.500 will be the total amount payable, Rs.250 under CGST and Rs.250 under SGST.
- The CBIC has notified the due dates applicable, with regard to interest and late fees for filing GSTR-3B. Here is a list of the notified dates from February to August 2020:
|Annual Turnover in the Previous FY
|| Due date
||Last date without late fee or interest, as applicable
|More than Rs.5 crore
||20th Mar 2020
||24th Jun 2020*
||20th Apr 2020
||20th May 2020
||27th Jun 2020^^
||27th Jun 2020@
||20th Jul 2020
||20th Jul 2020@
||20th Aug 2020
||20th Aug 2020@
||20th Sept 2020
||20th Sept 2020
|Up to Rs. 5 crore in category A# States/UTs
||22nd Mar 2020
||30th Jun 2020^
||22nd Apr 2020
||3rd Jul 2020^
||22nd May 2020
||6th Jul 2020^
||12th Jul 2020
||12th Sept 2020^
||22nd Jul 2020
||23rd Sept 2020^
||22nd Aug 2020
||27th Sept 2020^
||1st Oct 2020**
||1st Oct 2020
|Up to Rs. 5 crore in category B## States/UTs
||24th Mar 2020
||30th Jun 2020^
||24th Apr 2020
||5th July 2020^
||24th May 2020
||9th July 2020^
||14th Jul 2020
||15th Sept 2020^
||24th Jul 2020
||25th Sept 2020^
||24th Aug 2020
||29th Sept 2020^
||3rd Oct 2020**
||3rd Oct 2020
|#Category A: Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union Territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands and Lakshadweep.
##Category B: Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, the Union Territories of Jammu and Kashmir, Ladakh, Chandigarh and Delhi.
*No interest charged if GST dues are paid before 4th Apr, 5th May and 4th Jun for Feb, Mar & Apr respectively. But, interest applies from the 16th day at a reduced rate of 9% p.a. up to the date of actual payment, if paid before 24th Jun 2020. If not, then interest is charged in a staggered manner as given above plus interest at 18% p.a. will apply from the next day after 24th Jun 2020 up to the actual date of filing. In that case, a late fee will apply from the due date until the actual date of filing.
@If filed afterwards but before 30th September 2020, the maximum late fee of Rs 500 per return shall be charged vide CGST notification number 57/2020 dated 30th June 2020.
^^The due date was extended via CGST notification no. 36/2020 dated 3rd Apr 2020.
^Thereafter, a reduced interest rate at 9% p.a. will apply if taxpayer files on or before 30th Sept 2020. If not, then interest applies in a staggered manner as given above plus interest at 18% p.a. will apply from the next day after 30th Sept 2020 up to the actual date of filing. In that case, a late fee will apply from the due date until the actual date of filing.
**The due date was extended via CGST notification no. 54/2020 dated 24th Jun 2020.
Update as on 8th June 2020
A nil GSTR-3B can be filed via SMS using the registered mobile number and OTP verification. The CBIC has notified the date of applicability as 8th June 2020, from which nil returns can be filed through SMS.
Update as on 3rd February 2020
The due date to file GSTR-3B for January, February and March 2020 is revised as follows:
|Annual Turnover in Previous Financial Year
||GST Registration in below States and Union Territories
||New Due Date
|More than or equal to Rs 5 Crore
||20th of every month
Less than Rs 5 Crore
|Chhattisgarh, Madhya Pradesh, Gujarat, Daman and Diu, Dadra and Nagar Haveli, Maharashtra, Karnataka, Goa, Lakshadweep, Kerala, Tamil Nadu, Puducherry, Andaman and Nicobar Islands, Telangana and Andhra Pradesh
||22nd of every month
|States/UTs of Jammu and Kashmir, Laddakh, Himachal Pradesh, Punjab, Chandigarh, Uttarakhand, Haryana, Delhi, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand and Odisha
||24th of every month
1. GSTR-3B vs GSTR-1
GSTR – 3B is a monthly summary return filed by a taxpayer by the 20th of the next month. GSTR-3B discloses supplies made during the month along with GST to be paid, input tax credit claimed, purchases on which reverse charge is applicable, etc., and also makes a provision for the payment of taxes, if any, for the relevant month.
GSTR – 1 is a monthly or quarterly return filed by taxpayers to disclose details of their outward supplies for the month – along with their tax liability. Here, invoice-wise details are to be uploaded so that the Government can keep a check on every transaction.; this forms the basis for the recipient of supplies to accept the same and take the eligible input tax credit.
2. Importance for GSTR-3B vs GSTR-1
It is important to reconcile form GSTR – 3B and Form GSTR – 1 on account of the following reasons:
- The total GST collections disclosed at the end of the year 2017-18 showed a mismatch of several thousand crores. GST authorities have issued show cause notices to a large number of taxpayers asking them to reconcile the total of sales disclosed in the GSTR-3B summary return and the detailed GSTR-1 return.
- Reconciliation ensures that no invoice is omitted or recorded more than once in either of the returns.
- This ensures a taxpayer to arrive at an accurate amount of output tax payable on the sales made in a period.
- Any late declaration of GST liability can also attract interest.
- Reconciliation would also help the Government to allocate the right share of tax revenue to the concerned states. This reconciliation is specifically useful to identify any errors that have been made when entering the details of integrated taxes while filing GSTR-3B.
- GSTR-1 forms the base for the recipients of supplies to claim input tax credit while filing their returns. Hence, a timely and accurate declaration in both GSTR-1 and GSTR-3B is necessary, to avoid hassles with recipients at a later date, and also ensure that only genuine input tax credit can be claimed.
Reconciliation at the time of filing of Annual return:
At the time of filing an Annual return in Form GSTR – 9, a reconciliation of outward supplies is a must to ensure that the details disclosed match the details disclosed in GSTR-1 and GSTR-3B, across all months. Details of tax paid during the year need to be mentioned as well and this must tally with the total taxes disclosed and paid in GSTR-3B. Therefore, it is important that GSTR-1 and GSTR-3B match as the return-filing system is integrated and a mismatch between the same could result in improper disclosure in the annual return.
3. Reasons for mismatches in GSTR-3B vs GSTR-1
The details disclosed in Form GSTR – 3B and GSTR – 1 may not reconcile on account of the following reasons:
- Reporting of supplies under the wrong table in GSTR-3B, but correctly reporting the same when declaring it invoice-wise in GSTR-1. For example: Reporting zero-rated sales correctly in Table 6A of GSTR-1, but incorrectly reporting it under Table 3.1(a) in GSTR-3B.
- Issue of an invoice in a particular month, and issue of a debit or credit note at a later date could lead to mismatches.
- Inter-state supplies made to unregistered persons omitted in GSTR-3B but declared in GSTR-1.
- Value of supplies correctly shown but tax paid under the wrong head. For example, IGST instead of CGST & SGST or vice- versa.
- Supplies that may have been amended after GSTR-1 has been filed. In other words, any change of tax liability between the time of filing GSTR-1 and GSTR-3B.
- The time difference in reporting of invoices in GSTR-1 and GSTR-3B.
Due to the reasons mentioned above, the Government noticed a difference for the year 2017-18 running into tens of thousands of crores; this has resulted in notices being sent to taxpayers asking for an explanation for these differences.
4. Action to be taken on Reconciliation of GSTR-3B vs GSTR-1
After considering the situations mentioned above, if any discrepancies are found in Form GSTR – 1 and GSTR -3B across months leading to any shortage of tax paid by the supplier, the same must be paid along with interest. It is, therefore, necessary to conduct this reconciliation for every filing period to ensure that both the returns match, which wouldn’t give rise to any interest that may become payable at a later date.
5. How can ClearTax GST help you?
ClearTax GST offers easy imports and downloads of GST data for preparation of GST returns.
It provides various options for a user to ingest data to prepare the GSTR-1, GSTR-3B or GSTR-4 in under minutes. Options like excel ingestion or direct integration with ERP are available for importing sales or purchase data into ClearTax GST software.
A user has to import the sales data for GSTR-1 just once. Based on this, the software auto-populates the details into GSTR-3B in a click of a button. Thus, one can avoid errors and ensure 100% accuracy in reporting of data with minimal manual intervention.
Cleartax GST also provides useful insights under the Health Check Report Tool, so you can now speed through the journey of GST compliance in a hassle-free way!
One such report that helps you compare GSTR-1 with GSTR-3B is the ‘GSTR-3B vs GSTR-1 Comparison Report’. The comparison report can be obtained for any time period. Even if the user has not filed the return on the Cleartax GST software in the past, the report section will allow the user to download this data from the GST Portal, and compare the same.
This report will help the user compare the supplies reported in GSTR-1 along with the data reported in GSTR-3B, before filing GSTR-3B thus avoiding any evident errors.
Further, you can compare the data month-wise or for every financial year. You can also compare data at a GSTIN level or cumulatively at a PAN level.
6. Advantages of GSTR-3B vs GSTR-1 Tax Comparison Report
- Download GSTR-1 and GSTR-3B anytime across months to start comparing data. Verify GST login once using OTP, and continue to easily update data in a click, anytime and anywhere.
- Check the difference for every field such as outward tax, outward taxable value, supplies under RCM in both returns, etc.
- Data comparison at a PAN and GSTIN level is available.
- Know the differences instantly at a monthly, quarterly, or annual level, to take further action.
7. How to use the GSTR-3B vs GSTR-1 Tax Comparison Report
-Login to the Cleartax GST Account. Go to the ‘Reports’ section, click on view ‘Health Check Report’, click ‘Generate Report’.
Enter GSTN credentials and get the detailed GSTR-3B v/s GSTR-1 Report in Excel format.
– You can alternatively download the ‘GSTR-3B vs GSTR-1 Tax Comparison Report’ to get the graphical comparison of data at a glance. You can easily identify and reconcile mismatches using this report.
If GSTR-1 and GSTR-3B are both filed using Cleartax’s GST software, then the report is automatically displayed. However, if the Cleartax software hasn’t been used before, then click on the button “Refresh data from GSTN” appearing on the right-hand side of the report section. The yearly data from the GSTN will be fetched after verification via OTP-based login credentials.
You can also download the report in excel format by clicking on “Download report in excel” to use and share the report in excel form.
The Health Check Report also gives you the following results-
Try out the GST health check tool and check your GSTIN’s health now!