GST Annual Return for the F.Y. 2018-19 : Due date 31.03.2020

[Ganeshan Kalyani]

Vide Order No.08/2019-Central Tax, dated 14.11.2019, CBIC has extended the due date of filing GST Annual return for the Financial Year 2018-19 up to 31.03.2020. As per Sec.44(1) of CGST Act, 2017 the due date for filing annual return for FY.2018-19 was 31.12.2019. So, one extension is already given by the Govt. to file the return for the said period.

The Govt. had extended the due date of filing annual return for FY 2017-18 by seven times. The extension happened because it was first return in newly implemented GST regime. The same may not happen for the second year i.e. FY 2018-19 as the taxpayer is now well versed with the new return format and new modifications in the return format would not be warranted. It is therefore necessary that the taxpayer liable to file GST annual return must start working on the return.

Learning from FY 2017-18

A detailed information was asked in the annual return that we filed for the very first year in the GST regime. The said return was for nine months, starting from 01.07.2017 to 31.03.2018. The return required several informations to be furnished which the taxpayer did not maintained in books. The taxpayer was struggling to collate such data. By looking into the difficulties faced by the taxpayers in collating the information and also the difficulties that GST Auditors faced in ensuring correct data is being furnished in the GST Annual the return Format was simplified several times. The simplified form is applicable to F.Y.2018-19 as well. Say for e.g. HSN summary of inward supplies and for outward supplies is made optional. Thus, it would be easy for the taxpayer to prepare and file annual return for second year.

Auditor's appointment:

GST Auditor's appointment for the audit and preparation of annual return for F.Y.2018-19 need to be concluded. The GST auditor who filed returns for the first year may be appointed again for the second year audit and return filing. Or based on the experience one may choose to select another auditor. Whichever the case may be the taxpayer need to decide on the selection and appointment of the auditor asap as only forty days are left for the due date.

Preparation:

The taxpayer should start preparing for the GST annual Return for the second year. The time left is only 40 days. The taxpayer is aware of the information that need to be furnished  in the annual return. Two main task viz. GSTR-2A reconciliation & outward supplies liability reconciliation is a major and compulsory task. The work must start now to reconcile these two reports at the earliest.

Alignment with the auditor:

Taxpayer must take the appointment of the auditor and select the dates when it is feasible for the auditor to conduct the audit. A company having multiple locations in various States must immediately start talking to regional auditors and take their appointments and start workings. If the same auditor is appointed for the second year's audit then it would be easy for the taxpayer to get the audit completed within ease.

Challenges:

With effect from 01.04.2020, new return and e-invoicing is coming into effect. So, it is better that no extension is being provided by the Govt. for purpose of filing of the GST annual return for FY 2018-19. The taxpayer must file the return on or before the due date i.e. 31.03.2020.