06/10/2020
Important – GST Input Tax Credit and Credit Notes for F.Y.2019-20
The GSTR-3B for the month of September 2020 is due in October 2020. Section 16(4) of the CGST Act, 2017 provides that in case any ITC pertaining to F.Y.2019-20 is missed out, the same can be claimed up to the time of filing the return for the month of September 2020.
In case of outward supplies, i.e., sales, where any sale invoice pertaining to F.Y.2019-20 is not reported in the GSTR-1 or reported incorrectly, the rectification can be made up to the due date of return for September 2020, i.e., up to October 20, 2020.
The rectification of ITC or outward supplies cannot be made after the due date of the return for the month of September 2020.
Similarly, as provided under sections 34(2) and 16(4), the last chance to consider the impact of any Credit Note or Debit Note pertaining to supplies which occurred in F.Y.2019-20 is the return for the month of September 2020.
In the light of the above legal provisions the following points are relevant –
a) Ascertain from GSTR-2A and books of account as well as GSTR-3B if any ITC has been missing or mis-matched. Your vendors will not be able to rectify their uploading errors after the due date of filing the return for the month of September 2020.
b) In case any outward supplies need reporting or amendments, the supplier will not be able to make amendments in outward supplies after the due date of filing the return for the month of September 2020. Hence, please make sure that all amendments pertaining to F.Y. 2019-20 are reported in the return for the month of September 2020.
c) Any GST reduction on account of a Credit Note for outward or inward supplies related to F.Y.2019-20 cannot be claimed after the due date of return for the month of October 2020. The impact of Debit Notes also cannot be reported after the due date of filing the return for the month of September 2020.
Hence, please make sure that the impact of all Credit and Debit Notes pertaining to F.Y. 2019-20 are considered in the return for the month of September 2020.