It’s been almost 2 years and 9 months passed since applicability of GST Regime. However, still professionals make silly mistakes while filing GSTR-3B the so called “Summary Return”. Due to such continuing mistakes in GSTR-3B, taxpayers have to suffer following consequences: -
(1) Excess Payment of GST Tax
(2) Unreconciled GSTR-2A Vs GSTR-3B
(3) Claiming Ineligible /Blocked Input
(4) Recovery Proceedings against the registered person, etc.
Therefore, we hereby try to present following 11 key points in tabular form which can give guaranteed Error – Free GSTR-3B:-
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Sl. No.
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Description of Error Committed
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Correct Reflection
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Special Instructions
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1
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Export Sales
(Generally reported alongwith regular sales)
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Under Column 3.1(b)
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2 Kind of Exports Export with Tax Export without Tax - In this case only Taxable Value will be there
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2
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Exempt / Nil Rated / Non Gst Sales
Generally reported alongwith regular sales
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Under Column 3.1(c)
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Exempt sales include Interest Income Sales attracting 0% GST Rate, etc.
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3
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Liability due to Reverse Charge (Generally reported under 3.1(a) along with general taxable sales)
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Under column 3.1(d)
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Inward Supplies attracting RCM are:-
1) Security Guard Service
2) Renting of Motor Vehicle
3) GTA Services, etc.
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4
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Inter-state sales made to URD, Composition, Embassy (Generally not reported)
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Under Column 3.2
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State-wise sales to be shown These are only for reporting purpose Non-Reporting will lead to penal action-as per recent circular
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These figures should also be reported alongwith sales under 3.1(a)
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5
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Import of Goods IGST (Generally reported under all other ITC)
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Strictly under Column 4(A)(1)
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Should not be reported under Other ITC
This will not reflect in GSTR-2A
Hence will lead to unreconciled 2A
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6
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Input of Reverse Charge (Generally reported under all other ITC)
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Under Column 4(A)(3)
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RCM Input will never appear in 2A
Hence it should be shown here to avoid unreconciled 2A
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7
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Reversal of Input Tax Credit
(Generally reversals not done)
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under column 4(B)(2)
under column 4(B)(1)
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Following reversal should be reported here
1) ITC reversal due to Debit Note
2) Reversal due to short in 2A
3) Reversal due to wrong claim made, etc.
Proportionate Reversal due to exempt supplies
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8
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Cross-Utilisation at Payment Stage
(to curb situations which lead to payment of SGST even when there is enough ITC under CGST)
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Table 6.1
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New Rule of cross-utilisation applicable
IGST credit to be used before using CGST & SGST credit
Leftover IGST credit to be utilised 50:50 against CGST & SGST liability
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9
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Missed Cess & Additional Cess
(both in output as well as input)
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Cess column of 3.1 & 4(A)(5)
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This is skipped most of the times
Please note that cess is to be adjusted with cess input only i.e. no cross adjustment
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10
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Generally Interest Not paid on delayed Payments - to be levied on net payable (This is with retrospective 01.07.2017)
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18% p.a. day basis calculation
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As per latest amendment in GST Laws Interest to be paid on net payable basis i.e. after deducting Input from Output
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11
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Sometimes Input of Previous Year claimed in Subsequent Year
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Can be claimed upto due date of Sept 3B following the F.Y.
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While cliaming ITC, one should keep in mind this provision - otherwise penal action will be invoked on violation of Sec. 16(4) of CGST Act
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Please follow these small steps and you will be able to file error free GSTR-3B.
Thanks & Regards
Deepak Gulati, Deepak Arya
Chartered Accountant
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