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Below are the key points in relation to Goods and Services Tax (‘GST’) in view of the end of Financial Year 2018-19 and finalization of accounts
 

Turnover of previous financial year to be reported in Form GSTR-1 return for April 2019
⭕Turnover for the Financial Year 2018-19 to be reported in Form GSTR-1 for the Financial Year 2019-20.  
⭕As per return instruction, the said turnover should be auto-populated on the GST portal (based on GST returns filed during the Financial Year 2018-19).  In such a scenario, it would be prudent to verify the auto-populated turnover.
⭕Where GST portal does not auto-populate turnover for the Financial Year 2018-19, then the same should be manually entered in the Form GSTR-1 for April 2019.
⭕It is recommended that the said turnover should be computed and kept ready well in advance for the purpose of verifying/ reporting turnover in Form GSTR-1 for the month of April 2019.

Input Tax Credit (‘ITC’) reversal to be recomputed for the Financial Year 2018-19

⭕Rule 42(2) of the CGST Rules, 2017 provides for recalculation of ITC reversal basis the turnover ratio (exempt turnover vs total turnover) for the Financial Year 2018-19. 
⭕Any shortfall in ITC reversal (vis-à-vis ITC reversed previously on a monthly basis) should be added in output tax liability computed for the subsequent months, not later than September 2019.  Interest, as applicable should also be discharged on such shortfall from 1 April 2019 till the date of actual payment.  Hence, it would be prudent to determine such shortfall in reversal and discharge the same at the earliest in order to minimise the interest implication.
⭕Any excess ITC reversal (vis-à-vis ITC reversed previously on a monthly basis) should be availed in Form GSTR-3B filed for the subsequent months, not later than the month of September 2019. 

ITC in respect of input invoices issued during Financial Year 2017-18
⭕Proviso to Section 16(4) of the CGST Act, 2017 inserted vide Order No 02/2018-Central Tax provides an extension for availment of ITC on invoices pertaining to the Financial Year 2017-18 up to due date for filing Form GSTR-3B for the month of March 2019.
⭕Vendor invoices pertaining to the Financial Year 2017-18 should be identified and corresponding ITC (subject to eligibility) should be availed before the aforesaid due date, otherwise ITC would lapse.
⭕ITC on debit notes in relation to invoices issued during Financial Year 2017-18 (irrespective of whether such debit notes are issued in Financial Year 2017-18 or 2018-19) should be availed before the aforesaid due date (ie 20 April 2019).
⭕Accordingly, it may be prudent to co-ordinate with vendors to ensure that all debit notes pertaining to invoices issued in Financial Year 2017-18 are issued and received for timely availment of ITC.

ITC in respect of input invoices issued during Financial Year 2018-19
⭕Section 16(4) of the CGST Act, 2017 states that ITC on any invoice/ debit note (in respect of invoice issued during Financial Year 2018-19) would not be available after the due date for filing return for September 2019 or furnishing Form GSTR-9 for the Financial Year 2018-19; whichever is earlier.
⭕Vendor invoices/ debit notes pertaining to the Financial Year 2018-19 should be identified and corresponding ITC (subject to eligibility) should be availed before the aforesaid due date ie 20 October 2019, otherwise ITC would lapse.
⭕Accordingly, it may be prudent to co-ordinate with vendors to ensure that all debit notes pertaining to invoices issued in Financial Year 2018-19 are issued and received for timely availment of ITC.

Credit notes in respect of invoices raised during Financial Year 2018-19
⭕Section 34(2) of the CGST Act, 2017 prescribes that credit notes issued against invoices pertaining to Financial Year 2018-19 cannot be adjusted in the Form GSTR-1 for the period post after filing the Form GSTR-1 for September 2019 or Form GSTR-9 for the Financial Year 2018-19, whichever is earlier.
⭕Hence, credit notes, if any, pertaining to invoices of Financial Year 2018-19 should be raised and reported in the GST returns before the above prescribed dates.

Rectification of error/ omission in respect of details already furnished in Form GSTR-1 for the Financial Year 2017-18
⭕Proviso to Section 37(3) of the CGST Act, 2017 read with Order No 02/ 2018 – Central Tax provides an extension for rectification of any errors/ omissions in the details furnished in Form GSTR-1 filed for the Financial Year 2017-18 till March 2019
⭕Accordingly, any errors/ omissions in details reported in Form GSTR-1 should be identified and rectified before the aforesaid due date.
 
Rectification of error/ omission in respect of details already furnished in Form GSTR-1 for the Financial Year 2018-19
⭕The GST Legislation permits rectification of any errors/ omissions in the details furnished in Form GSTR-1 for the Financial Year 2018-19 in the returns to be filed for the subsequent months.
⭕The said rectification is however restricted till furnishing Form GSTR-1 for the month of September 2019 or Form GSTR-9 for Financial Year 2018-19, whichever is earlier.
⭕Accordingly, any errors/ omissions in details reported in Form GSTR-1 should be identified and rectified before the aforesaid due date.
 
Annual Return (Financial Year 2017-18) and Reconciliation between GST returns and financial statements
⭕Due date for filing annual return for the Financial Year 2017-18 under Form GSTR-9 and Form GSTR-9C has been extended to 30 June 2019 vide Order No 03/2018-Central Tax.
⭕Accordingly, it is prudent to initiate preparation for filing Form GSTR-9 and Form GSTR-9C ie annual return and reconciliation statement.
⭕Details reported in GST returns for Financial Year 2017-18 should be reconciled with the financial statements/ General Ledgers/ Trial balance for the financial year on a GSTIN level – in order to identify discrepancies (if any) in filing of GST returns.
⭕Any shortfall in payment/ excess payment of GST, if any, to be identified and appropriately adjusted in Form DRC–03.

Reconciliation between GST returns and financial statements (Financial Year 2018-19)
⭕Details reported in GST returns for Financial Year 2018-19 should be reconciled with the financial statements/ General Ledgers/ Trial balance for the financial year on a GSTIN level – in order to identify discrepancies (if any) in filing of GST returns.
⭕Any shortfall in payment/ excess payment of GST, if any, to be identified and appropriately adjusted in GST returns to be filed for the subsequent months.

Distribution of credit by ISD registration
⭕Credit is required to be distributed by ISD registration based on the turnover of previous financial year/ previous quarter – as the case maybe.
⭕For distributing the credit availed by ISD registration from April 2019 onwards, the turnover for distribution of credit (of previous financial year or the previous quarter) should be recomputed.

Invoice Series
⭕In accordance with Rule 46 of the CGST Rules, 2017 a unique document series should be introduced for invoices/debit notes/ credit notes to be issued in Financial Year 2019-20.

Letter of Undertaking (LUT)
⭕For continuous availment of benefit of export with payment of IGST post 31 March 2019, it is required to file LUT for Financial Year 2019-20 at the earliest on the GST portal.

Regards,
C