Welcome to the first edition of IRIS GST Times, a fortnightly newsletter to keep you posted about developments related to GST and its compliance.
It has been more than 1 year since GST has been launched in India. Ever since its rollout, it has kept professionals on their feet, making them keep themselves aware of the laws and compliance that keep updating and changing.
We have been sharing updates through emails and update section in our application, IRIS Sapphire. Starting this month, we are also rolling out our newsletter in which we will cover the recent and important updates and help you a what you need to follow to make your life simpler when it comes to filing your GST returns.
As always, we look forward to hearing from you. Let us know your feedback.
Team IRIS GST
Are you subject to GST Audit?
As per notification issued on 13th September 2018, taxpayers whose turnover exceeds ? 2 crores needs to additionally file GSTR 9C.
GSTR 9C is primarily is a reconciliation statement which must be certified by Auditor. Along with the reconciliation, taxpayers will also need to provide audited annual accounts.
GSTR 9C includes reconciliation of many types including the turnover as per accounts and GST, ITC claimed and tax liability rate wise. A separate section is provided where the auditor can recommend additional liability to be charged because of non-reconciliation of turnover and Input Tax Credit. Any liability arising because of unreconciled difference will have to be discharged in cash
It should be note that GSTR 9C is to be submitted GSTIN wise. Hence for companies who have multiple GSTINs, preparing of GSTR 9C could be a daunting task.
The reconciliation of turnover as per audited annual accounts which is for the company as whole, with the turnover reported in GST which is GSTIN wise could be a challenge if the books of accounts are not maintained to record transactions GSTIN wise.
Know if your vendor is GST compliant
Government has been issuing notices for excess ITC claimed using the details filed by suppliers in GSTR 1, which is GSTR 2A for the purchaser.
If your vendor has not been filing GSTR 1, then Government does not have the details about the invoices, even though actual supply already has been affected.
If your vendor is not filing GSTR 3B, then it could imply that the vendor is not discharging the tax liability, even though you have been prudent in paying the vendor full transaction value including the tax.
So how to check, whether the vendor is compliant when it comes to GST Returns filing and paying taxes?
Do you know?
GSTR 6 and GSTR 1 are now de-linked. The ISD Taxpayer will get auto-drafted invoices in GSTR 6A and while filing GSTR 6 all the purchase invocies are to be uplaoded again. No accept, reject and pending actions needed.
Unlike the case earlier, the invoices uploaded by an ISD taxpayer will not be posted back to GSTR 1 for further acceptance or rejection by the supplier
Filing for Sept 2018: Key points to note
The GST returns to be filed for month of September are important because it gives the opportunity to make all the necessary corrections and adjustments pertaining to the previous financial year.
The due date for outward supplies return, i.e. GSTR 1 for Sept 2018 is 31st Oct 2018 and for GSTR 3B, which is a summarised return consisting of ITC details, is 20th Oct 2018.
Some of the common scenarios which could warrant for corrections or adjustments in outward supplies are
- Reporting details of invoices related to FY2017-18 which are missed out while filing GSTR 1 for the months from July 2017 – Mar 2018. It is important to note that interest on late payment of GST for such invoices may apply.
- Making corrections to the invoices filed in earlier returns. If for any invoices, the GSTIN of customer has been wrongly filed, it can be rectified by providing the correct details in amendment section.
- Likewise, if B2B transactions have been reported as B2C or vice-versa, the amendments can be included in GSTR 1 of Sept 2018
In addition to giving the effect of amendments on outward supply details, in GSTR 3B, the corrections and adjustments for ITC are to be reported.
- If for any of the purchase invoices, ITC was not claimed from July 2017 – Mar 2018, it can be claimed in Sept 2018
- If any excess ITC has been claimed, accordingly the amount of ITC claimed needs to be corrected.
- Reconciling the invoice details uploaded by supplier and as per your records so that the differences if any are adjusted.
Some of these corrections and adjustments, such as ITC on missing invoices, also need to be reported in the Annual Return GSTR 9. As the Annual Return is yet to be implemented, Sept 2018 is the last chance for amendments of FY 2017-2018.
GST Annual Return
Overview and analysis of the scope and details required to be filed in the Annual Return
Annual return is a statement of return which is required to be filed annually by each registered person (except few specified categories of persons) under GST giving summarized details of outward supply and taxes paid thereon , input tax credits claimed, taxes paid and refund claimed in the financial year in respect of which such annual return is filed.
The due date for Annual Return of FY 2017-2018, hence is 31st Dec 2018.
Notification dated Sept 4th, 2018 specifies the new format for filing annual returns. The Annual Return consists of various forms applicable to different type of taxpayers
|GSTR 9||Regular taxpayers who file GSTR 1 and GSTR 3B|
|GSTR 9A||Taxpayers who have opted for composition scheme and are filing GSTR 4|
|GSTR 9B||E-commerce operators who are required to file GSTR 8|
Additionally, taxpayers having turnover more than ? 2 cr. during the financial year need to file a reconciliation statement in the form GSTR 9C.
In the Annual return, the taxpayers need to report summary of outward supplies, inward supplies, ITC claimed, tax liability discharges, HSN summary of supplies etc.
Most of the details required in the Annual return should be summation of details filed in GSTR-1 and GSTR-3B for the period July 2017 to Mar 2018.
Here is quick overview of the key additional sections and details which the taxpayers will need to prepare and report in GSTR 9
- Taxpayers have to disclose total Input tax credit claimed on capital goods and input services in table 6 of GSTR-9.
- Taxpayers need to report the reconciliation between the credit claimed in GSTR-3B and as per GSTR-2A
- Taxpayers now have to report HSN wise details of inward supplies
- Taxpayers now also have to disclose details of any transaction between Apr 2018 to September 2018, which pertains to FY 2017-2018, in part 5 of GSTR-9.
- Inward supplies from composition dealers, deemed supply from job workers etc. are required to be reported separately.
- Taxpayers now have to separately disclose the Input Tax Credit reclaimed in FY 2017-2018, which is to be reported in table 6H of GSTR-9.
- Details of GST demands and refunds
- Taxpayers will also need to separately report the impact of amendments on tax liability and ITC claimed.
The implementation of GSTR 9 in GST system is in progress and once available for taxpayers and GSPs, we’ll endeavor to make the filing of GSTR 9 hassle-free for you.
Reconciliation Reports and Insights
At IRIS, we have always thrived to ensure that our clients have a comfortable experience whenever using any of our offerings. We endeavor to enhance the user experience and focus on providing solutions that make the life of our clients more comfortable. Keeping this in mind, we are launching new reconciliation reports and insights in reconciliation that will make your reconciliation job efficient and enjoyable.
Indicative availability of ITC
It gives a summary of invoices, after you have reviewed it and you get a view of the tax amount after you have accepted and rejected invoices, which makes it easier for you to claim your ITC
ITC of invoices reported in next FY
A report of all invoices where the F.Y is different from the F.Y in which it is uploaded
Reports on missing invoices
For an entity having more than 1 GSTINs, it is crucial to get a view of all the invoices to identify scenarios where the vendors have raised invoices to a different GSTIN using your PAN
Consolidated view on missing invoices (supplier only & purchaser only) for the F.Y
Comparable invoices from the missing invoices category across F.Y
Check out our Smart Reconciliation
Our Smart Reconciliation comes handy for managing the reconciliation tasks in a timely, efficient, and easy manner. The Smart Reconciliation runs on the invoices uploaded by you and the auto-drafted details of GSTR 2A and categorises the results as per the next actions required.
In IRIS GST, reconciliation is auto-triggered. Thus, whenever GSTR 2A is downloaded from GSTN or GSTR 2 data is uploaded in IRIS application, the invoices are compared and the results of the comparison are displayed.
Key features of Reconciliation in IRIS Sapphire
- Bulk upload of your invoices for all your GSTINs
- Bulk fetch of GSTR 2A for all your GSTINs
- Auto-triggered reconciliation process
- Vendor-wise summary and Overall status dashboard gets updated on real-time basis
- Smart search to pair and match comparable invoices
- Spectrum of filters to drill down deep into invoice level details
- Send emails to your vendors
Key changes in Eway Bill System
With effect from 1st Oct 2018, new features and enhancements are implemented in the E-way Bill system.
Here is a quick overview of the changes in the E-way Bill generation process
- Display of only relevant document types in “Document Type” drop down list based on the selected Transaction “Supply Type” and “Sub Type” by the tax payers.
- Validation of pin-code with the state. So, when pin-code is entered on NIC portal, the state code of consignor and consignee address will be auto-populated
- Fixed values allowed for tax rates. Only pre-defined tax rates as currently existing in GST, will need to be used while generating E-way Bill
- Additional fields for “CESS Non Advol Amount” & “Other Value” have been introduced to enter CESS Non Advol amount and any other charges (+/-) written in invoice.
- Person generating the E-way bill will get an alert via a message in case the total invoice value is more than Rs. 10 crores.
- Transporter ID is made compulsory for generating Part-A slip.
To read further about the enhancements, please click here.
IRIS Topaz, is an end-to-end E-way Bill solution. Try our MS Excel® based desktop utility which helps you to manage all your E-way Bill tasks easily. Read more.
TDS and TCS effective from 1st Oct 2018
Tax Deducted at Source (TDS)
The notified entities will need to comply with the TDS provisions starting 1st Oct 2018.
As per the provisions, the taxpayers registered as TDS deductors need to deduct tax while making payments to vendors/suppliers towards the inward supplies received where total value of supply under a contract exceeds ? 2.5 lakhs.
TDS rates are set at 1% CGST and 1% SGST (2% for IGST).
Tax Collected at Source (TCS)
Ecommerce Operators who collect the supply consideration on behalf of the suppliers, for the sales affected through them, need to comply with provisions of TCS from 1st Oct 2018.
Supplies made on own account are not subject to TCS provisions
Ecommerce Operator to collect at 0.5% CGST and 0.5% SGST (1% for IGST) of the net value of taxable supplies.
GSTR-8 is the return to be filed by the 10th day of the subsequent month.
Disclaimer: IRIS Business Services has taken due care and caution in compilation of data. Information has been obtained by IRIS from sources which it considers reliable. However, IRIS does not guarantee the accuracy, adequacy or completeness of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. IRIS especially states that it has no financial liability whatsoever to any user on account of the use of information provided.