It is seen that industry, trade and professionals have been facing various issues in filing of GST Returns and transitional forms. Therefore, this article is written to provide as a ready reckoner to those involved in filing of GST returns to understand the issues and also solution to resolve the same. For ease of readers, the issues are provided in FAQ form and the same is also segregated in various sub-heads as given in table below.
General Issues faced:
S.
No.
Sub-Head
Issue
Resolution
1
General issues
Whether returns under GST needs to be filed only within the window of filing allotted or whether the same can also be filed later of prior to that?
No, The returns must be filed within the window allotted. If the return is not filed within the window allotted then the same can be later filed only once the filing window is again enabled for the said return.
2
General issues
Is it mandatory to file a GST Return even if it is Nil?
Yes, GST returns need to be filed every month even if it is Nil. Unlike service tax law there is no any waiver of late filing fee in case of nil returns in the GST law.
3
General issues
Whether returns can be filed for a subsequent period if the same is not filed for the previous period?
No, Returns cannot be filed for the subsequent period if the same is not filed for the previous period.
4
General issues
Can offline utility once downloaded be used for filing of GST returns for various months?
Yes, However GST law is new and the offline portal is getting updated more frequently. Therefore, it is suggested to ensure that returns filing.
5
General issues
Is submission of details of HSN summary mandatory?
Yes, since it is a part of return in GSTR 1 and GSTR 2, therefore submission of HSN summary is mandatory requirement. However, the return does not match details of total tax values as given in the HSN summary with that in the main part of the return.
6
General issues
Whether interest be applicable till the date of debit to the respective ledger or only till the date of deposit of cash in Electronic Cash ledger?
Interest shall be applicable till the date of debit to the respective ledger. In other words, interest needs to be paid till the balance deposited in cash ledger is actually off set against the actual liability.
7
General issues
Whether late filing fee is applicable for each return?
Yes, late filing fee is applicable for each return i.e. separately for GSTR 1, 2, 3 and for GSTR 3B. However, presently the late filing fee has been reduced to Rs.50 per return and Rs.20 per return in case of the Nil Return.
8
General issues
Amount deposited in electronic cash ledger as CGST/ SGST instead of IGST. Now the liability is that of IGST. Can we transfer this balance in Electronic cash ledger from CGST/ SGST to IGST?
No, we cannot transfer this amount. One option could be to pay the correct taxes and file the return and claim back the taxes while filing GSTR-3. Another option can be to pay the taxes as it is and correct the same while filing the actual
GSTR 1, 2 and 3 and simultaneously claim the refund of wrong taxes paid in GSTR 3. Further, one can raise grievance in the GST portal and send mail to GST help desk who can do the appropriate changes at the back end.
9
General issues
What is the difference between xlsx file and CSV file?
There is no any difference, both are the offline tools to file the GST returns. However, it is seen that using CSV file is a better option in case of large data say more than 500 line items.
10
General issues
Can we file the returns even if registration is granted in August 2017 or later?
No, Returns cannot be filed in such a case. Returns can be filed only from the period for which Registration is effective.
11
General issues
In case registration is granted in the month of August 2017, then how to disclose the details of such invoices in respect of July 2017?
Return for the month of July 2017 cannot be filed when registration is granted in August 2017. However, July invoices can be included in the
August Return and tax be paid.
12
General issues
If Cash is deposited under the minor head i.e.
Tax/Interest/Fee/
Penalty/Others in the cash ledger then whether the amount deposited can be utilized only for payment of such Tax/Interest/
Fee/Penalty/Others liabilities or it can be utilised otherwise?
Any amount once deposited as tax, then can be utilised for payment of taxes only and the same cannot be utilised for payment of fee etc. Further, if amount is deposited as CGST, then the same can be utilised only for payment of CGST and not payment of SGST or IGST.
13
General issues
Amount is wrongly deposited as compensation cess instead of in the field of tax. Therefore, assessee is unable to file GSTR 3B. What is the course of action?
In this case, one can send an email to GSTN to make the changes in the back end. Government has recently enabled the revise option, wherein GSTRB submitted but not filed can be revised and such errors can be corrected before filing. Further, there is form PMT 04 which can be submitted to make this correction. Presently, form PMT 04 is not made online, therefore one can submit the same manually.
14
General issues
Late fee for July & Aug is waived. Therefore, if an assessee has already paid any such late fee then whether it will be again be credited as late fees only?
As per the recent clarification issues, late fee will be credited back as tax so that asseessee can utilise these funds for payment of their tax liability.
15
General issues
Whether late filing fee will be also calculated for the days when the filing window is disabled by the GSTN?
Yes, late filing fee will be applicable and same will be calculated upto the date of actual filing of the GST returns.
16
General issues
In case of services, what shall be the unit of measurement to be given in HSN summary?
Ideally, there should not be any unit of measurement in case of services. However, reasonable measurement can be given based on type of service such as each no. of invoice can be one unit of measurement.
17
General issues
What precautions need to be taken while applying Digital Signature Certificate (DSC)?
DSC should be Class II or Class III, PAN-based DSC
The DSC must not be
expired
The DSC must be registered on the GST Portal
EM Signer version 2.6 must be installed on the computer
The DSC Dongle must be connected to the computer.
Issues faced in filing GSTR 1
18
Issues
GSTR 1
in
Whether any changes pertaining to earlier return needs to be updated in subsequent GSTR 3B or in actual GSTR 1?
As per governments earlier circular, any aspect not covered in GSTR 3B i.e. missed invoices etc then the same needs to be considered in the final GSTR 1/ 2 and 3. However, since there is no any mechanism for filing of GSTR 2 and 3, therefore one can do the changes in subsequent GSTR 3B. It is expected that government will come up with a detailed clarification in this regard.
19
Issues
GSTR 1
in
In case of supply of goods by SEZ, whether the details of supply of such goods needs to be disclosed in GSTR 1?
No, since the liability to pay is in the hands of the recipient. The recipient needs to file a Bill of entry and remove the goods from SEZ premises. Therefore, the recipient shall declare the details of such goods in its GST return as imports.
20
Issues
GSTR 1
in
Where we need to disclose the details in respect of supply of services by SEZ?
In case of supply of services by SEZ, the same is covered under forward charge and the SEZ shall be collecting and paying GST on the same. Hence, it should be treated as an outward supply for the SEZ and accordingly disclosed in the returns.
21
Issues
GSTR 1
in
Where to disclose the details in respect of supply of goods or services to SEZ?
Supplies amounting to deemed exports must be disclosed in sl no.4 and not under sl no. 6A i.e. exports.
22
Issues
GSTR 1
in
Where to disclose the details in respect of supply of deemed exports?
Supply of goods/ services to SEZ amounts to Zero rated supply and it must be disclosed in sl no.4 and not under sl no. 6A i.e. exports.
23
Issues
GSTR 1
in
How to disclose the details of credit note in case of B2C small supplies?
In case of supplies to consumers are to be reported in a consolidated manner (intra-state supplies to consumer and interstate supplies of invoice value less than INR 2.5 lakhs), the credit/debit notes are not required to be reported separately. Such supplies have to be reported in a consolidated manner net off the values of credit and debit notes.
24
Issues
GSTR 1
in
What if the GSTIN of customer is incorrect or if the same is not provided. How to upload the GST returns?
Such details can be submitted in B2C for the time being and once the recipient provides the proper GSTIN. The entries for the past entered in B2C can be revered and a contra entry be entered in B2B supplies and accordingly credit can be passed on.
25
Issues
GSTR 1
in
How to enter the details in case where there are multiple tax rates for the same invoice?
In case where there are multiple tax rates for the same invoice, then GSTR 1 shall accept multiple tax rates only when the invoice value is kept same and not splitted to various tax rates.
26
Issues
GSTR 1
in
In case where quantity discount is given by way of a single credit note against multiple invoices. How to disclose the same?
Presently, system is not accepting allowing a single credit note against multiple invoices. Therefore, one has to either issue multiple credit notes and match it with each invoice or as an temporary solution identify any invoice which can cover the entire discount/incentive, and raise the CN in relation to that invoice. Internal communication to be documented for computation of discount/ incentive.
27
Issues
GSTR 1
in
What is the distinction between invoice value and taxable value?
The taxable value shall be the value as per the GST law in accordance with the GST valuation. The ‘Total Invoice Value’ means the invoice value inclusive of taxes.
28
Issues
GSTR 1
in
If invoice and advances received both fall in the same month, then whether
Such details need to be disclosed in invoices and details of advances are not required to be
such details need to be disclosed under the head of advances or as invoice?
disclosed again.
29
Issues
GSTR 1
in
Where to disclose the details of cross border transaction on which tax is paid as 'intermediary'?
Although, it is a cross border transaction, still it is liable for GST as the place of supply is in taxable territory. It must be treated as a B2C transaction as the recipient is not having GST No. and accordingly details must be disclosed in the returns.
30
Issues
GSTR 1
in
Upon entering GST No. of SEZ. System does not recognise the recipient as SEZ?
The respective SEZ while registering must not have updated the details properly. Therefore, we need to ask the recipient SEZ to update its GST registration and send a mail to GSTN to enable the flag of SEZ.
31
Issues
GSTR 1
in
Whether all the details submitted in GSTR 1 amendable/ rectified, if wrongly submitted?
No, certain details are nonamendable and the same needs to be properly entered at the first time itself, such as - Aggregate Turnover for
Preceding FY / First Quarter
(Table 3)
Nil/Exempted /Non GST Outward Supplies (Table 8)
HSN Summary (Table 12) - Documents issued during the
tax period (Table 13)
32
Issues
GSTR 1
in
Whether liability to pay tax under RCM needs to be disclosed in GSTR 1 or in GSTR 2?
Liability of tax payment under RCM needs to be disclosed in GSTR 2 and do not use Table 4B of GSTR 1 to fill in Liability under RCM on Inward Supplies.
33
Issues
GSTR 1
in
How to report the transactions through Ecommerce operators
All supplies to be reported through “other than E-
commerce” tab without E-Comm GSTIN since the provisions relating to TCS have been deferred for now.
34
Issues
GSTR 1
in
Is shipping bill number mandatory while declaring export invoices in GSTR-1?
No, a taxpayer can furnish details of the export invoices in GSTR-1 and file the return without mentioning the shipping bill number and date, if the shipping bill details are not readily available with him. However, refund of tax paid on
exports will be processed on the basis on shipping bill no.
Therefore, person claiming rebate must enter the details of shipping bill.
35
Issues
GSTR 1
in
Whether purchases from unregistered person, which are subject to reverse charge, for which the recipient issues a tax invoice, is required to be reported?
All the purchases from unregistered person, which are subject to reverse charge, for which the recipients issues a tax invoice are to be reported in GSTR-2 (and not in GSTR-1).
Further, if a consolidated invoice is raised then the same must be raised separately for intra - state RCM and inter-state RCM since system will not accept otherwise.
36
Issues
GSTR 1
in
We are unable to view the invoices uploaded and the same is not reflected on the summary tab?
Scroll down to the bottom of the GSTR-1, Details of outward supplies of goods or services page and click the GENERATE GSTR1 SUMMARY button. This will include the auto drafted details pending for action from recipients. Also the invoices you have added will start reflecting in the relevant section of the GSTR1.
37
Issues
GSTR 1
in
If assessee has opted for composition scheme in middle. Do they need to file GSTR 1,2, 3 or they have to file GSTR 4?
Taxpayers who have opted for composition from beginning will be able to file GSTR-4 on the portal. Those who have opted in for composition later and have to file GSTR-1,2,3 for part period may wait till the facility is enabled on the portal in some time.
38
Issues
GSTR 1
in
In case tax is paid under under wrong head (i.e. CGST/ SGST instead of IGST). How to correct the same?
Any amount if it is lying excess in the cash ledger then by using Table 14 of GSTR 3 - Column 7. Once debit entry is filed the refund will be filed. Once GSTR 3 is filed it will get credited to the bank account given during registration. Further, one can raise grievance in the GST portal and send mail to GST help desk who can do the appropriate changes at the back end.
39
Issues
GSTR 1
in
What are the available modes of preparing GSTR1?
GSTR-1 can be prepared using the following modes through: 1. Online entry on the GST Portal
Uploading of invoice and other GSTR-1 data using Returns
Offline Tool
Using third party application of Application Software Provider (ASPs) through GST Suvidha
Providers (GSPs)
40
Issues
GSTR 1
in
Who is not required to file the GSTR-1?
The following taxpayers are not required to file GSTR-1:
Taxpayers under the Composition Scheme
(Return to be filled by them in GSTR 4)
Non-resident foreign tax payers (Return to be filled by them in GSTR 5)
Online information database and access retrieval service provider (Return to be filled by them in GSTR 5A)
Input Service Distributors (ISD) (Return to be filled by them in GSTR-6)
Tax Deducted at Source (TDS) deductors (Return to be filled by them in GSTR 7)
E-commerce operators deducting TCS (Return to be filled by them in GSTR 8)
41
Issues
GSTR 1
in
Whether DSC is mandatory for filing returns?
DSC is mandatory only in case of all Public & Private Limited Companies, Limited Liability Partnerships (LLPs), and Foreign Limited Liability Partnerships (FLLPs).
42
Issues
GSTR 1
in
When are Credit Notes to be reported in the return?
Credit Notes are to be reported in the return of the month in which they are issued but not later than the return of the September month following the end of the financial year in which such supply was made, or the date of furnishing of the relevant annual return, whichever is earlier.
43
Issues
GSTR 1
in
How is the tax paid on advance payments adjusted against the invoice(s) issued in the subsequent tax period(s)?
The taxpayer has to declare the advance that has to be adjusted in the tax period in which advance is received.
Subsequently when invoice is issued, then taxpayer can adjust the tax liability of the invoice issued of that tax period, in the GSTR-1 of that period. This can be shown in the advance adjustment table of GSTR-1.
44
Issues
GSTR 1
in
Can a registered taxpayer have multiple series of tax invoices?
Yes, a tax payer can have multiple series of tax invoices in a financial year. There is no limit on the number of series of tax invoices that one can have in a financial year.
45
Issues
GSTR 1
in
Up to how many decimal digits do different values need to be declared in GSTR-1?
Values like invoice value, taxable value and tax amounts are to be declared up to 2 decimal digits. The rounding off of the selfdeclared tax liability to the nearest rupee will be done in
GSTR-3.
46
Issues
GSTR 1
in
If a taxpayer is unable to view the invoices, then what should be done?
Scroll down to the bottom of the GSTR-1 – Details of outward supplies of goods or services page and click the GENERATE GSTR1 SUMMARY button. This will include the auto drafted details pending for action from recipients. Also the invoices you have added will start reflecting in the relevant section of the GSTR1. In case you want to see the summary instantly, after you have added the invoices, you can also generate the summary by clicking the GENERATE GSTR1 SUMMARY button. However, summary can be generated only at interval of 10 minutes. In case you attempt to generate summary again (within 10 minutes of earlier generated summary), you may get an error message on top of the page. The summary is generated by the
GST Portal automatically at an interval of every <30>. You can also check if any error file has been generated on upload of JSON generated from Offline Tool. If any error file is generated, you can download the error
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