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The next 20 days are going to be very hectic for finance and tax professionals in various companies as many Goods & Services Tax (GST) related compliances need to be completed before or on September 30. Some of these include preparing for new e-invoice mechanism, full utilisation of Input Tax Credit (ITC) of last fiscal, and rectification of invoices.
Experts call for utmost care in preparing records to avoid any kind of coercive action by Tax Departments. Harpreet Singh, Indirect Tax Partner at KPMG in India said September is a busy month for finance and tax professionals as deadlines for many critical compliances like claiming GST credit for last financial year, issuing credit notes, rectification of invoices, reversal of GST credit on account of non-payment to suppliers etc. falls during this month. “Implementation of e-invoicing from 1 October 2022, for dealers with sales exceeding ₹10 crores could also impact input GST credit and compliances for multinationals who deal with small vendors,” added Singh.
Oumesh Sauba, Founder of NuBook suggested preparations like filing the GST returns on time with all details uploaded accurately in GSTR-1, maintaining proper documentation and getting accounts audited by a CA or CMA is always a wise option. “This could mean purchase and sale registers, fixed asset registers, payment challans, e-way bills, etc. In the event of a notice of scrutiny, or even at the time of closure of books of accounts, the reconciliation process will be much smoother if proper documentation is maintained. Additionally, reconciling your returns with your book of accounts is also important. Understanding the provisions of Reverse-Charge Mechanism and informing the GST authorities regarding the changes in business are also some basic steps that one should keep in mind,” he said.
With assistance from tax experts, BusinessLine prepared list of important compliances to be completed on or by September.
E-invoicing has been made mandatory for taxpayers having aggregate turnover exceeding ₹10 crores effective from October 1. Therefore, the eligible taxpayers are required to evaluate their business scenarios, undertake the changes in IT systems and get prepared to generate invoices as prescribed. The Company may also consider identifying and tracking its vendors on whom e-invoicing provisions may be made applicable to ensure that the Company receives GST compliant invoices for availing input tax credit.
Section 16 of Central Goods & Services Tax Act 2017 provides that ITC in respect of invoices pertaining to Financial Year (FY) 2021-22 can be availed till September 2022. Accordingly, an assessee is required to perform/ update reconciliation of ITC available in GSTR-2A/2B (till date) with ITC claimed in GSTR-3B and take corrective action for ITC mismatch in order to avoid any loss of ITC for invoices pertaining to FY 2021-22.
Every e-commerce operator (other than the supplier of services notified under Section 9(5) of CGST Act, 2017) is required to collect tax on the net value of supplies made through it by various suppliers and deposit the same by furnishing a return under Form GSTR-8 within ten days of the end of the month. Accordingly, an error or omission in GSTR-8 furnished for FY 2021-22 can be rectified till the due date of furnishing the GSTR-8 of September 2022.
In terms of Section 34 of CGST Act 2017, Credit Notes pertaining to any supply of FY 2021-22 can be reported till the due date of GSTR-3B for the month of September 2022. Therefore, Credit Notes in relation to the said period should be issued on or before 30 September 2022 and duly reported in GSTR-1 in order to claim the requisite adjustment of GST. Also, if there are any credit notes which are issued against output invoices but not declared in GST Returns, the same has to be reported in GSTR-1 for the period not later than September 2022.
Any amendment in the invoices issued for outward supplies pertaining to FY 2021-22 can be made till the due date of furnishing the return for the month of September 2022. In other words, invoices uploaded in the GST returns for FY 2021-22 can be amended till the filing of GSTR-1 of September 2022. Accordingly, the Company should perform reconciliation of data declared in GST returns and recorded in the books of accounts. Once reconciled, the differences should be rectified in the GSTR-1 for the month not later than September 2022.
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