GST Compliance Checklist before Filing GST Returns


Few weeks ago we discussed about To Do List for accountants before 31st March. In this article we are going to focus on GST related compliance requirements to be fulfilled till 31st March 2019. Every accountant must keep in mind certain things before filing GST Return for March 2019 including GSTR 1 and GSTR 3B. This is critically important because of some compliance deadlines. In this article we have tries to cover these points.

Input Tax Credit (ITC) for Invoices pertaining to FY 17-18:

  • If ITC for any invoices / debit notes for FY 2017-18 is not availed earlier, it must be availed by 31st March 2019, for which return in GSTR 3B is to be filed up to 20th April 2019.
  • If ITC for such invoices / Debit Notes are not claimed in the GSTR 3B of March, the same can not be availed later on. Following needs to be done:
    • Reconciliation of Purchase register with GSTR 2A.
    • Ledger Scrutiny for all expenses where ITC may have been missed.

Debit Notes Pertaining to Invoices of FY 17-18:

  • All Dr. Notes under GST pertaining to invoices of FY 17-18 must be raised before 31st March 2019.
  • The Counter Party must mandatorily be informed so that he takes the ITC of the GST amount in his GSTR 3B of March 2019.

Amendment/Addition for Outward Supply Invoices and Debit/Credit Issued in FY 2017-18:

  • Amendment/addition for outward supply invoices and debit/credit issued in FY 2017-18 should be done by 31st March 2019 and reflected in GSTR 1 by 11.04.2019.
  • If the GSTR 1 for March 2019 is not filed by the said due date AND amendment is not done up to 11th April 2019, assessee will not be able to amend the details in future.

Avail all ITC in Input Service Distributor (ISD) Registration:

  • ISD should avail the ITC for FY 2017-18, not availed earlier, up to 31st March 2019. If not availed in the return filed by 13th April 2019, then the same shall Lapse.
  • Also, all the ITC availed by ISD should be distributed in the month of March 2019.

Documentation Series:

  • Series of documents issued should be unique for each financial year. Hence all GST documents like Invoice, Dr/Cr notes, Delivery Challans, Self Invoices, Receipt Voucher, etc. should be issued under new series from 1st April 2019.
  • It is pertinent to note that particular document (say invoice) may have ‘n’ no. of series’.

Application for “Letter of Undertaking” (LUT):

Assessee is required to apply for LUT prior to making exports. Hence, LUT for FY 2019-20 should be applied online before 31st March 2019.

Other Important Points:

  • Some goods may be in Transit as on 31st March 2019. In such case while the Supplier will show the supply in his GSTR 1 for March 2019, the Customer shall avail the ITC only in April 2019, i.e. FY 2019-20. The same will show as a reconciliation item in GSTR 9.
  • Even if delivery of goods is know to happen on or after 1st April 2019, As per Sec 31 of The CGST Act 2017, Invoices may be made before supply. Hence, even if delivery is known to happen on 1st April or thereafter, Invoices may be made on or before 31st March 2019.
  • Where Goods are received by The Transporter on 31st March 2019 or before but delivery is made to the consignee on or after 1st April 2019 Purchase should be booked only on receipt of the materials by the consignee or person acting on behalf, i.e. on or after 1st April 2019.

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