The following points need to be taken under consideration while filing GSTR-3B for the month of September'19 in order to ensure proper GST Compliance:
1. Credit Notes: As per Section 34(2) of CGST Act, 2017, a registered person is entitled to adjust the output liability in respect of credit note(s) issued for the outward supply of goods or services or both pertaining to the Financial year 2018-19, before September'19 or date of filing of annual return of the said financial year, whichever is earlier. Thus, all credit notes for the Financial year 2018-19 may be issued up-to September'19 otherwise the adjustment of output liability will not be allowed.
2. Last date to make amendment in GSTR-1: As per proviso to Section 37(3) of CGST Act, 2017, no rectification of error or omission in respect of the details furnished under sub-section (1) shall be allowed after furnishing of the return under section 39 for the month of September following the end of the financial year to which such details pertain, or furnishing of the relevant annual return, whichever is earlier.
Hence, in view of above provisions it is suggested to make necessary reconciliations between GST returns and books for financial year 2018-19. If error/omission is discovered in such returns, then Assessee should make necessary amendments in the return of September, 2019.
3. Last date to avail ITC: As per Section 16(4) of CGST Act, 2017 Credit of all the invoices or Debit notes pertaining to goods or services which have been issued by the supplier for the Financial Year 2018-19 can be availed by the registered person till the due date of furnishing the return u/s 39 for the month of September following the end of financial year or furnishing of the Annual return whichever is earlier i.e. GSTR – 3B for the period of September' 2019. Thus, unclaimed input tax credit after September 2019, pertaining to invoices or debit notes of Financial Year 2018-19 may lapse.
It is advised to prepare a reconciliation between books vis-Ã -vis GSTR 2A as well as GSTR 3B so that any missing credit can be taken in GSTR 3B of September.
Further, if while preparing reconciliation between ITC register and GSTR-2A if any person finds a mistake/error in GSTR-1 filed by the supplier then he should approach to such supplier for making necessary amendment because after filing of return for month of September 2019, no adjustment/rectification of matters pertaining to FY 2018-19 would be allowed.
4. Final reversal under Rule 42(2): In case a person is engaged in supplying taxable as well as exempt supplies, common ITC has to be provisionally reversed in proportion to exempt turnover on a monthly basis as per Rule 42(1). Further, as per Rule 42(2), such reversal of ITC shall be calculated finally for whole financial year before the due date of furnishing of return of September of following financial year. In case amount of final reversal is higher than provisional reversal, such difference needs to be paid (along with interest @18% from 01.04.2019) and in case amount of final reversal is lower than provisional reversal, the difference needs to claimed as ITC. Time limit for declaring such payment/availing such ITC is in return of any month up to return of September of following financial year.
