Important task to be completed in October month's GST Return for F.Y.23-24 invoices

[Ganeshan Kalyani]

As per section 34 of CGST Act, 2017, any changes in the outward supply liability can be done in the return to be filed in the month of November. The return filed in November pertains to the period October. Thus, any amendment or furnishing of credit note issued against invoices pertaining to FY 2023-24 can be corrected in the October 2024 month's return viz. GSTR-1/3B.

GST Liability

1. Outward GST Liability as per books to reconcile with liability furnished in GSTR-1/3B and if any liability is missed out to be reported in the return then the same has to be furnished in October month return.
2. On the flip side if any outward GST Liability furnished in GSTR-1/3B but missed out to be accounted in books then the same has to be accounted in books.
3. Compare the GST liability in GSTR-1 and GTR-3B and identify the difference, if any and pass necessary entry in books or if any liability not furnished in return then furnish the same. Or if the difference is genuine then keep reconciliation.
4. Analyse the transaction recorded in ‘Miscellaneous Income’ at P&L credit side. If any GST liability is not accounted then account it in books and also consider in October month return.
5. If there is no liability on transaction at above point 4 then keep proper write up or your stand as to why liability is not payable for future audit purpose. For e.g. liquidated damage recovered from your supplier or customer.
6. Any liability paid in GSTR-1/3B but missed to record the payment entry or utilisation entry in books then account the same.
7. If any short payment or excess payment was done like 5% GST paid instead of 12% or vice-versa then account/reverse the difference in books. Also arrange to deposit or adjust in the October month return.
8. Any capital asset sold but GST is not accounted then analyse whether GST is applicable or not. If applicable then account the liability in books. If not then keep calculation as to why GST is not payable in record for future audit purpose. E.g. like sale of car by a person not in car business.
9. Transfer of capital asset like laptop, car, machine parts etc. within company but outside state units need to be offered for GST. If not offered to tax then pass necessary entry to account the liability in book and consider it in October month GST return.
10. Reconcile expense accounts/ ledgers like Freight account, Legal consultancy, security service, rental income, director sitting fees, import of service etc. and ensure that applicable RCM is paid. If any liability is missed to be accounted then pass necessary entry and consider in October month return
11. Raise Self invoice for RCM transaction and keep it on record.
12. Check if any goods sent for job work or capital asset sent for repair purpose is received within prescribed time period. If not received within timeline then create liability in books and consider payment in October month return.
13. Ensure that Credit notes are actually issued to the customer. Also it is furnished in GSTR-1 so that the customer reverses the input tax credit claimed earlier based on underlying invoice.
14. In case the customer has informed you about the discrepancy in the invoices appearing in his GSTR-2B which is a replica of the invoice uploaded by you then make necessary correction in October month returns. Never miss to correct it in October month return as post October month return corrections cannot be made.
15. Send an email communication to all B2B customers alerting them to report any discrepancy in the invoice issued by you during FY 2023-24. Specifically inform that once the due date of 11^th November is crossed then correction in the invoices /credit note pertaining to FY 2023-24 is not possible.
16. Ensure all the liability ledgers viz. CGST Payable account, SGST payable account, IGST payable account, RCM CGST liability, RCM SGST liability, RCM IGST liability account are correct in books of account in the sense that only October month liability appear in these ledgers. If any previous period liability exists in these ledgers or unreconciled item is there then pass necessary entry and consider them in the compliance of October month return.
17. Compare outward supply in GSTR-1/3B with E-way bill generated. In case you find any transaction for which e-way bill was generated but that particular transaction is not there in books of account then account it and consider them in October month return.
18. Similarly, compare GSTR-1/3B outward supply with e-invoice details. Ideally there should not be any taxable supply which was not reported to IRP (Invoice registration portal) and also not accounted in books. But still if it happen then consider the missed transaction in books in the month of October.
19. In case of the Cross charge invoice on inter-company is missed to offer for tax. Consider those transaction and account GST liability on them.
20. Common expenses borne by parent company for an event or conference where sister concerns employees also attended, the cost need to be apportioned to respective company. GST is applicable on those recovery of expense from sister concerns. If GST is not accounted on those expenses then create liability and furnish in October month return.

Input Tax Credit (ITC)

As per Section 16(4) the time limit to claim Input tax credit on invoices pertaining to FY 2023-24 is October 2024 month’s return to be filed on or before 30.11.2024. According, following task need to be performed.

1. Check the pending ITC pertaining to FY 2023-24 and in case any incorrect ITC is there in the unclaimed ITC list then reverse them by passing necessary entry in books. And, if any ITC is pending for claim then consider them while filing GSTR-3B of October month.
2. If any ITC not accounted due to invoice not received then check with concern department internally and then account the ITC.
3. If the ITC is not appearing in GSTR-2B then inform the supplier to furnish it in his GSTR-1 to be filed for October month on or before 11.11.2024
4. Reconcile the ITC ledgers in books and the ITC claimed through GSTR-3B. Though monthly reconciliation would have been carried out, but for FY 2023-24 as a whole one reconciliation is must as correction can be done only at last in the October month return.
5. Compare the Electronic Credit Ledgers with the ITC taken through GSTR-3B. ideally the ITC balance in books should be same as the Electronic credit ledger. But still any open items is there, then reconcile it and close.
6. Any ITC kept unclaimed due to doubt on its eligibility for credit then consult with advisor and take necessary action of claiming it or reversing it.
7. Any reversal of ITC u/s 42, 43 to be done for F.Y 23-24 considering turnover of fy 2023-24 then same need to be calculated to give impact in GSTR-3B of October month.

Other liability

1. Any interest paid for delay payment of GST, vide GSTR-3B, then pass necessary entry in books.
2. Any penalty paid for vehicle detention case but entry not passed, account it in books.
3. Any late fee for delay filing of GST return is pending then account it and also discharge the late fee.