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Dear Members,
As you are aware, GST Rules require every registered person to furnish details of outward supplies made in a month in FORM GSTR-1, details of inward supplies received in a month in FORM GSTR-2 and a return in FORM GSTR-3 by the 10th, 15th and 20th of the next month respectively. Since taxpayers may face certain issues in the initial days after the introduction of GST, the GST Council had extended the date for filing of FORM GSTR-1 and FORM GSTR-2 for the months of July and August, 2017 and approved the filing of a simplified return in FORM GSTR-3B for these two months by the notified due dates after making the due payment of tax.
Since GSTR-3B for July 2017 have been filed, CBEC has now issued Circular No. 7/7/2017-Central Tax dated September 1, 2017 on reconciliation of information furnished in FORM GSTR-1 and FORM GSTR-2 with FORM GSTR-3B.
Key Provisions as per above-Circular are as follows:
Correction of erroneous details furnished in FORM GSTR-3B:
In case the registered person intends to amend any details furnished in FORM GSTR- 3B, it may be done in the FORM GSTR-1 or FORM GSTR-2, as the case may be. For example, while preparing and furnishing the details in FORM GSTR-1, if the outward supplies have been under reported or excess reported in FORM GSTR-3B, the same maybe correctly reported in the FORM GSTR-1. Similarly, if the details of inward supplies or the eligible ITC have been reported less or more than what they should have been, the same maybe reported correctly in the FORM GSTR-2. This will get reflected in the revised output tax liability or eligible ITC, as the case may be, of the registered person. The details furnished in FORM GSTR-1 and FORM GSTR-2 will be auto-populated and reflected in the return in FORM GSTR-3 for that particular month.
Additional payment of taxes:
Where Form GSTR-3 reflects additional tax payable in line of Form GSTR-3B, same shall be paid along with interest starting from August 26 till date of debit in cash / credit ledger, whereas in case of excess ITC claimed in Form GSTR-3B, same would be added to output tax liability.
Additional claim of eligible ITC:
In case of reduction in output tax liability, which is not offset by corresponding reduction in eligible ITC, excess shall be carried forward to next month’s Form GSTR-3 to be offset against output tax liability.
Submission of GSTR-3B without payment of taxes:
Where, for some reasons, the registered person has only submitted the return in FORM GSTR-3B and has not made the payment of taxes by debiting the same from his electronic cash or credit ledger, the return shall still be subjected to the reconciliation process as detailed above. Return shall be subjected to reconciliation process even where Form GSTR-3B has been submitted without payment of taxes, whereas in case of non-submission of Form GSTR-3B, details shall be furnished in Forms GSTR-1 & 2 and return in Form GSTR-3 shall be submitted with no late fee, and thereafter, the process of matching will be carried out.
Processing of information furnished:
After submission of the information in FORM GSTR-1 and FORM GSTR-2, the process of matching shall be carried out as if these details were submitted in the regular course. Any amendment in the details furnished in FORM GSTR-1 and GSTR-2 shall be done following the procedure laid down under relevant rules. The return shall be considered to be a valid return when the tax payable as per FORM GSTR-3 has been paid in full after which the return shall be taken up for matching.
Members are requested to kindly take note of above provision. Full details of reconciliation procedure are available in Circular No. 7/7/2017-GST dated 01/09/2017 which can be downloaded using below link-
http://www.cbec.gov.in/resources//htdocs-cbec/gst/circular-systm-based-rconcillation.pdf
Thanking you,
Yours faithfully,
S.G BHARADI
EXECUTIVE DIRECTOR
CHEMEXCIL
Encl : Circular-system-based reconciliation
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