To avoid any error and possibility of fraud, the government is in process of implementing various new features in filing of GST returns. GSTR-3B is a monthly return which is used to furnish summary of sales and purchase made during the month alongwith computation of GST liability. However, Most of the common issues being faced or error made in GSTR-3B filing are as follows:
- Mismatch of Sales information: For the purpose of passing on fake Input Tax Credit, taxpayers furnish detailed sales information in GSTR-1 and do not consider the same while filing GSTR-3B. Similarly, sometimes incorrect information is entered inadvertently.
- Excess ITC Availment: Government has inserted Rule 36(4) to CGST Rules. As per new rule, a taxpayer can claim Input Tax Credit in GSTR-3B subject to a maximum of 110% of ITC appearing in GSTR-2A as on date of filing of GSTR-3B. However, most of the taxpayers failed to claim ITC as per Rule 36(4).
1. Auto Population of outward supplies and inward supplies in GSTR 3B
To avoid above mentioned errors, GSTIN has implemented new features from GSTR-3B of the month of November, 2020. GSTIN has enabled auto-population of following information in GSTR-3B for taxpayers who are liable to file GSTR-1 on monthly basis:
1.1 Auto population of detailed of outward supplies in GSTR 3B from GSTR 1
Under tables-3.1 – Tax on outward and reverse charge inward supplies & Table-3.2-Inter state supplies made to unregistered persons of Form GSTR-3B (except Table-3.1 (d) pertaining to inward supplies liable to reverse charge), are computed by the system on the basis of details of outward supplies entered in Form GSTR-1 for the tax period.
1.2 Auto population of detailed of inwards supplies in GSTR 3B from GSTR 2B
Details of Eligible-Input Tax Credit (ITC) in Table 4 and details of Inward supplies liable to Reverse Charge in Table 3.1(d) are auto-populated based on information appearing in GSTR-2B for the tax period. Form GSTR-2B is an auto-drafted form containing details of Input tax credit. GSTR-2B is auto-populated based on information filed by the supplier in their GSTR-1.
2. Salient features of auto population of GSTR 3B
- Auto population of GSTR 3B is available for downloading in PDF format. Downloaded form contains table wise information. Same can be downloaded by clicking on “System Generated GSTR-3B” tab.
- System generated GSTR-3B is computed only for assisting the taxpayers in filing their Form GSTR 3B. It is the responsibility of Taxpayers to ensure that the correct values are being reported and filed in Form GSTR-3B.
- Taxpayers are allowed to change the auto-populated amounts in GSTR-3B. However, if the variation is in excess of 10% of the amount auto-populated then the system will prompt the taxpayers with an alert by marking such columns as red. However, still taxpayers are permitted to file GSTR-3B with higher variations.
- In case a taxpayer has not filed Form GSTR-1 for the period, the system generated summary will display the respective values as ‘Not filed’. Similarly, if Form GSTR-2B is not generated for the period, the system generated summary will display the respective values as ‘Not generated’.
- If the taxpayer has entered & saved any values in Form GSTR-3B before auto-population by the system, the saved values will not be changed/over-written by the system.
- Table 5-”Exempted, Nil and Non-GST Inward Supplies” and Table 6.2-”TDS & TCS Credit” of FORM GSTR-3B are not part of the PDF & will not be auto-populated by the system.
3. Reference for auto population of GSTR 3B
Information in Form GSTR-3B shall get auto-populated in following manner:
|Information in Form GSTR-3B||Source of auto-population of Information||Remarks|
|Table 3.1(a) Outward taxable supplies (other than zero rated, nil rated and exempted)||Auto-populate based on information entered in FORM GSTR-1: Tables-4, 5, 6C, 7, 9, 10 and 11||Information in GSTR-3B is auto-populated by doing a total of all the values reported by the taxpayer in the corresponding tables of GSTR-1. |
Net positive values shall be reported in respective tables. Net negative values, if any, shall not be considered in the table and system will provide the value as zero.
|Table 3.1(b) Outward taxable supplies (zero rated)||FORM GSTR-1: Tables-6A, 6B and 9|
|Table 3.1(c) Outward taxable supplies (Nil rated, exempted)||FORM GSTR-1: Table-8|
|Table 3.1(e) Non-GST outward supplies||FORM GSTR-1: Table-8|
|Table 3.2 Of the suppliers shown in 3.1(a) above, details of inter-state supplies made to unregistered persons, composition taxable persons and UIN holders||FORM GSTR-1: Place of Supply (PoS)-wise details declared in corresponding tables||Place of Supply (PoS)-wise details of inter-state supplies made to unregistered persons, composition taxable persons and UIN holders.|
|3.1(d) Inward supplies liable to reverse charge||FORM GSTR-2B|
Table 3 Part A Section III Table 4 Part A Section III
|This is auto-populated from FORM GSTR-2B. Positive values shall be reported in respective table. |
Net Negative values, if any, shall not be considered in the table and system will provide the value as zero.
However, If the actual liability is more than the value auto-populated by the system, the taxpayers should edit & report the correct value in FORM GSTR-3B. However, system shall continue to show the red mark if variation is more than specified amount.
|4A (1, 3, 4, 5) ITC Available||FORM GSTR-2B: Table 3 Part A Section I, II, III, IV||This is auto-populated from FORM GSTR-2B. Positive ITC values shall be reported in respective tables. Negative values shall be considered as ITC reversal and would be reported in table 4B(2).|
|4B(2) ITC reversed – (2) Others||FORM GSTR-2B: Table 3 Part B Section I Table 4 Part B Section I||This is auto-populated from FORM GSTR-2B. This covers the following: |
Positive values of all credit notes, on which ITC is available. If this is negative, then credit may be reclaimed subject to reversal of the same on an earlier instance.
Positive values of all credit notes, on which ITC is not available.
In case there are negative values in ITC available table 4A (1,3,4,5), then such negative values shall be reversed and considered in this table.
If Invoice and credit notes are appearing in same month then the same should be reported separately under ITC Available and ITC reversed.
4. Ignore prompt on liability for inward supplies attracting reverse charge in Table-3.1 (d)
It has brought to the notice of the department that the system is giving alert when the taxpayer revises the auto-populated values in table 3.1(d)- inward supplies attracting reverse charge where variation exceeds 10% of the amount auto-populated.
Department has clarified that this alert is erroneous. The technical team is working to resolve the same at the earliest.
Meanwhile, the taxpayers may continue to declare their correct liability under reverse charge in Table-3.1(d) and proceed to file GSTR-3B