Filing of mid-year GST Return, i.e., return for the month of September, is crucial mainly because it marks as the last return for reconciliation/ rectification of any mistakes/ omission of any data relating to the preceding Financial Year.

Simplifying thereof, various mistakes/ errors, if any, done while filing returns for the Financial Year 2020-2021 needs to be reconciled/ rectified on or before the filing of return for the month of September 2021.

The present article covers the gist of such actionable items which one needs to clear/ go through before filing the GST return for September 2021.

gst return filing

Actionable items relating to
Input Tax Credit

Input Tax Credit is very crucial, so is the GST return filing for the month of September. The points to be taken care of before furnishing return for the month of September is highlighted hereunder:

Availment of pending Input Tax Credit for the Financial Year 2020-21

Provisions of section 16(4) of the CGST Act, states as under:

  • The registered person will not be eligible to avail any of the pending ITC in respect of any invoice/ debit note after the date specified hereunder.
  • After the due date of filing of return for the month of September following the end of the Financial Year to which the pending invoice/ debit note relates.

    Accordingly, the following is important:
  • Before filing a return for the month of September 2021, all the registered person needs to verify whether the ITC of all the invoice/ debit notes for the Financial Year 2020-2021 is availed.
  • In case any ITC is missed out, the registered person has the last chance to avail the same while filing the return for the month of September 2021.
  • Apportionment of ITC as prescribed under rule 42 and rule 43 of the CGST Rules

    The registered person either:

    • Engaged in supplying both exempted as well as taxable supply; or
    • Using inputs/ input services/ capital goods for both business as well as other purposes.

    are required to reverse the ITC in accordance with the provisions of rule 42 and rule 43.

    Notably, the reversal is to be done on a periodical basis. However, as per provisions of sub-rule (2) to rule 42 and rule 43-

    • The reversal for the respective Financial Year should be computed definitively before furnishing the return for the month of September following the end of the Financial Year.

    Accordingly, the registered person to whom the provisions of rule 42 and rule 43 are applicable are required to do a final calculation of the reversal of ITC for the Financial Year 2020-2021 before filing a return for the month of September 2021.

    The situation and action to be taken by the registered person, on final calculation are summarized hereunder:

    Situation

    Action

    Actual ITC reversed = Finally calculated reversal figure

    No action to be taken

    Actual ITC reversed < Finally calculated reversal figure

    • The registered person is required to reverse/ pay the short fall ITC along with interest.
    • The short fall ITC is to be paid before the end of the month of September.

    Actual ITC reversed > Finally calculated reversal figure

    • The excess amount should be claimed as a credit. 
    • The claim of excess amount needs to be done before the end of the month of September.

    Reversal of ITC as per rule 37 of the CGST Rules

    Rule 37 states that after availing of ITC relating to the inward supply of goods or services if the registered person fails to pay the value of supply (fully/ partly) within 180 days from the date of invoice. Then, full/ proportionate credit is required to be reversed.

    Accordingly, while filing the return for the month of September 2021, partial or full reversal of ITC is to be done in case of non-payment of any invoice amount vis-à-vis completion of 180 days.

    gst to do list

    Actionable items relating to supply

    Outward supply reconciliation

    Before filing the return for the month of September 2021, the registered person is required to reconcile the outward supply for the Financial Year 2020-2021 as per books of accounts and as reflected in the returns filed for that Financial Year.

    Underreported/ misreported outward supplies, if any, for the Financial Year 2020-2021 needs to be correctly disclosed while filing returns in Form GSTR-1 and Form GSTR-3B filed for the month of September 2021 in the following manner

    Particulars

    Action


    Rectification in domestic taxable outward supply


    Return

    Tables in which amendment is to be done

    Form GSTR-1

    4A, 4B, 4C, 6B, 6C – B2B

    5A, 5B – B2CL

    7 – B2CS

    Form GSTR-3B

    3.1(a) – Outward Taxable Supplies (other than NIL, Zero Rated and Exempted)


    Rectification in outward supply relating to export


    Return

    Tables in which amendment is to be done

    Form GSTR-1

    6A – Exports

    9A – B2B, B2CL and Exports Amendments

    Form GSTR-3B

    3.1(b) – Outward Taxable Supplies (Zero-rated)


    Rectification in outward supply relating to NIL-rated, exempted and non-GST supply


    Return

    Tables in which amendment is to be done

    Form GSTR-1

    8A, 8B, 8C & 8D – Nil Rated, Exempt & Non-GST Supply

    Form GSTR-3B

    3.1(c) and 3.1(e)

    Issuance of credit notes as per section 34(2) of the CGST Act

    According to section 34(2), the issuance of the credit notes is to be reflected in the return filed for the month in which the credit note is issued.

    In case of failure, the same is to be reflected while filing a return for the month of September following the end of the Financial Year in which the supply was done.

    Referring the same to the Financial Year 2020-2021, any pending reflection of credit note needs to be reflected while filing a return for the month of September 2021.

    Summary of important points to be taken care of before filing a return for the month of September 2021-

    1. Verify and confirm availment of ITC of all the tax invoice/ debit notes received during the Financial Year 2020-2021. Avail ITC of any left-out invoice/ debit note while filing a return for the month of September 2021.
    2. Compare the outward supply as per books of accounts and as per returns filed for the Financial Year 2020-2021. In case of any rectification, do the same while filing the return for the month of September 2021.
    3. In case of applicability of provisions of rule 42 and rule 43, do a final calculation of reversal of ITC to be done for the Financial Year 2020-2021. Excess reversal/ claim, if any, needs to be given effect while furnishing September 2021 return.
    4. Any pending reflection of credit notes, issued during the Financial Year 2020-2021, needs to be taken care of while filing September 2021 return.

    Your GST
    Super-Audit Tool 
    Is Here!

    Power to pinpoint every single GST risk exposure and potential loss in the future, right now


    CA Poonam Gandhi

    About the author

    Poonam Gandhi is a Chartered Accountant and a Lawyer. She is a Professional Freelance Content Writer/ Editor and an Educator. She masters in creating result-oriented as well as Search Engine Oriented Content. Currently, she is associated with some of the topmost leading sites of India. She holds more than 3 years of experience in the content field. Before entering the content writing field, she possessed a wide practice experience of more than 9 years, specifically, in the field of Indirect Taxation.

    Follow us:

    Leave a Reply

    Your email address will not be published. Required fields are marked

    {"email":"Email address invalid","url":"Website address invalid","required":"Required field missing"}