19/06/2017
At the end of 17th GST council meeting it is almost certain that GST is coming on 1st July 2017. In fact the same message is conveyed in many official communications. First we will quickly see what are the major decisions had taken in 17th GST council meeting:
1) GST Council decided that for 1st two months of GST, tax would be payable on a simple return
2) Return will contains summary of outward, inward supplies which will be submitted before 20th of succeeding month
3) No late fees & penalties will be levied for interim period
4) GST network to take 4-5 months to prepare E-way Bill. Till then alternative or transient rule will prevail
5) 28% limit in hotels will start from Rs. 7,500. Between Rs 2,500- Rs 7,500 rate will be 18%.
Now, in this article we will only talk about point number (1) & (2) above. Yes, about the initial return. What is simplified return? Is it required to declare all the details of first two months afterwards? Worry not, sit back, relax & enjoy the write up!
Firstly Govt. of India in no mood to compromise with GST at any cost, so forget about relaxation of not giving any data for the interim period. You need to provide all the details, if not in July or August but in September.
Simplified summary return (GSTR 3B) for the first 2 Months:
For the first two months of GST implementation, the tax would be payable based on a simple return (Form GSTR-3B)[See Draft Return Rule 3(5) for reference] containing summary of outward and inward supplies which will be submitted before 20th of the succeeding month. It means, all the supplies need to filed up anyway as expected, but the things are bit simpler. But don’t get relaxed, you need to record each & every transaction for future disclosure.
GSTR 1 in September!
The invoice-wise details in regular GSTR – 1 would have to be filed for the month of July and August, 2017 as per the timelines given below:
| Month | GSTR – 3B | GSTR – 1 | GSTR – 2 (auto populated from GSTR-1) |
| July, 2017 | 20th August | 1st – 5th September* | 6th – 10th September |
| August, 2017 | 20th September | 16th – 20thSeptember | 21st – 25th September |
* Facility for uploading of outward supplies for July, 2017 will be available from 15th July, 2017.
It means, the month of September will be too hectic. One needs to prepare the data for September return. Also, return related to July & August 2017 needs to filed. That is why, it is better to perfectly record each & every transaction (not only a summary) of July & August for quick uploading in September.
No late fees and penalty would be levied for the interim period.
With the objective of ensuring smooth rollout of GST and taking into account the concerns expressed by the trade and industry, Govt of India decided to not to levy any ate fees and penalty for the interim period. his is intended to provide a sense of comfort to the taxpayers and give them an elbow room to attune themselves with the requirements of the changed system. This not only underlines the government’s commitment towards ensuring that all the stakeholders are on board but also provides an opportunity to the taxpayers to be ready for this historic reform.
Conclusion: Though GOI is providing some relaxation to file simplified summary return in GSTR 3B for the initial 2 months, but beware! GSTR 1 of the initial two months still needs to be filed, and that too after two months into GST regime where you may start facing new issues! Also during September you need to prepare the data for filling return which will be due in Oct. So please don’t get relaxed by getting the news of simplified return, rather it is recommended to take extra cautions in the initial period.
Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or a formal recommendation. While due care has been taken in preparing this document, the existence of mistakes and omissions herein is not ruled out. The author does not accept any liabilities for any loss or damage of any kind arising out of any inaccurate or incomplete information in this document nor for any actions taken in reliance thereon. No part of this document should be distributed or copied without express written permission of the author.
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About the author
HIMANSHU TIWARI
CHARTERED ACCOUNTANT
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