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The return filing system under GST has been revamped in many ways.

In this article, we will focus on those changes which may not immediately attract our attention relating to details like HSN summary, non-GST supply details, advances received, details relating to e-commerce supplies, TDS, TCS, etc.

Comparison of New GST returns with Present GST returns

A comparison between new returns and old/present returns system for the rest of the GST return elements are as follows:

Particulars Old/Present System of Return Filing New System of Return filing
HSN Reporting HSN level data was not required to be disclosed for each invoice. However, Central Tax notification number 12/2017 dated 28-06-2017 requires disclosure of HSN data as follows:

– Annual turnover in preceding FY up to Rs 1 crore: No HSN required

– Annual turnover in preceding FY between Rs 1 crore and Rs 5 crore: HSN of 2 digits

– Annual turnover in preceding FY more than Rs 5 crore: HSN of 4 digits.
The Annual Return (Form GSTR 9) also contains a section in Table 17, for HSN-wise summary of outward supplies. Similarly, a summary of inward supplies should be reported in Table 18 only where turnover under a specific HSN code exceeds by 10%.

Suppliers with annual aggregate turnover more than Rs. 5 crore and in relation to exports, imports and SEZ supplies will upload HSN level data of 6 digits. Other suppliers may declare HSN optionally. However, notification number 12/2017-Central Tax dated 28-06-2017 stands effective until cancelled by CBIC. The reporting under GSTR-9 will continue until further changes are notified.
Exempt, Nil rated and Non-GST Supplies The reporting with regards to Nil-rated supplies, exempted and non-GST outward supplies were done in Table 8A, 8B, 8C and 8D of GSTR-1 and also in Table 3.1(b),(c) and (d) of GSTR-3B. Table 3D(1) and (2) of RET-1 allows reporting of those supplies which are exempted from payment of tax/are nil-rated, and supplies made, but which are not covered under GST law (non-GST supplies) respectively. The form ANX-1 will not have any provision for reporting this.
Additionally, Table 3D(2) of RET-1 covers supplies made which fall under Schedule III -activities that are neither supply of goods or services.
Advances Received 1. Table 11A(1) & Table 11A(2) of Form GSTR-1 was used for reporting of details of intrastate and interstate transactions that attracted tax liability at the time of receipt, respectively. Hence, advances received were declared in this table.
2. Table 11B(1) & 11B(2) of Form GSTR-1 was used to add details of advance received in a prior period and adjust them against supplies shown in the current period.
1. Table 3C(3) of RET-1 allows for reporting of advances received that were taxable at the time of receiving them. The same should be net of refund vouchers issued. The table can also be used to make the adjustments for wrong reporting of advances in a prior period.
2. Table 3C(4) of RET-1 allows for recording of invoices which were issued in the current period in respect of advances received in a prior period on which tax was paid by a declaration in Table 3C(3) of that period. 
E-commerce supplies/TDS/TCS 1. When entering details of large invoices (greater than Rs. 2.5 lakhs) relating to taxable inter-state supplies, Table 5 of Form GSTR-1 is used. In this table, in case the supplies were made through E-Commerce Operators (ECO), the checkbox in relation to the same needs to be selected and GSTIN of the E-Commerce Operator (ECO) would need to be entered thereafter. 1. Table 3 (3A to 3L) of ANX-1 required a declaration of various types of outward supplies, inward supplies liable to reverse charge, imports and Missing documents based on which credit is claimed. Out of the supplies declared in Table 3, details of those supplies which were made through E-Commerce operators (who is required to collect tax at source). Some details need to be provided in Table 4, such as GSTIN of ECO, the value of supplies made, the value of supplies returned, the net value of supplies and tax amount. 

 

Implications of the changes

  • HSN Reporting: The new returns enforce only narrow criteria concerning supplies where the HSN code needs to be reported. The turnover limit has been raised to Rs 5 crore, which serves as a major relief. However, the legal provision in relation to reporting of the HSN remains the same.

 

  • Exempt, Nil Rated and Non-GST Supplies: The old return filing system required reporting in relation to exempt, nil rated and non-GST supplies in 2 forms – GSTR-1 and GSTR-3B. The new system only requires one-time reporting of these details in Form GST RET-1.

 

  • Advances Received: The details relating to advances were reported in the earlier Form GSTR 1. However, in the new system, reporting of advances is not required in Form GST ANX-1 but will directly need to be reported in Form GST RET-1.

 

  • E-commerce Supplies/TDS/TCS: The reporting of supplies made through E-commerce operators is more or less similar across both the old and new reporting systems by providing a separate indication for this type of supply.
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