‘Auto Population- a boon or a bane?’

[Navjot Singh]

Volumn-1 ; 16.12.2020

Exordium

Auto Populated details in Form GSTR 3B: Now, auto-population of system computed details in Form GSTR-3B, has been enabled for taxpayers (filing their Form GSTR-1 on monthly basis), from November 2020 Tax Period onwards.

The same will be done based on the following: -

Liabilities in tables-3.1 & 3.2 of Form GSTR-3B (except Table-3.1 (d) about inward supplies liable to reverse charge) are computed by the system based on details of outward supplies as filed in Form GSTR-1 for the tax period.

Input Tax Credit (ITC) details and details of inward supplies liable to reverse charge, to be reported in Tables-4 and 3.1 (d) respectively, are computed as per system-generated Form GSTR-2B for the tax period.

What is this ‘GSTR-2B’ all about?

1. GSTR-2B provides eligible and ineligible Input Tax Credit (ITC) for each month, similar to GSTR-2A but remains constant for a period.

Section	Level	Scope
ITC Summary	Aggregated category wise similar to ITC Table in GSTR-3B	ITC available and not available. Further categorized section-wise – B2B, CDN, Imports, RCM and ISD.
Supplier wise Summary	Aggregated supplier GSTIN wise within every category	Within every category such as B2B, CDN, ISD etc. then aggregated at supplier GSTIN level. So no net or total wise of supplier. For every supplier, filing status period and filing status is given which implies even within a category there could be more than one record of a supplier, if filing is done for multiple periods by supplier but falling in the same month for recipient. For imports, only from SEZ (as it has GSTIN)
Invoice details	Invoice level details category wise	Similar to GSTR-2A invoice details. Additionally available, flag of ITC availability and reason if ITC is not available. Filing status also available at invoice level

2. GSTR-2B is available to all the regular taxpayers. Every recipient can generate it based on the GSTR-1, GSTR-5, and GSTR-6 furnished by their suppliers. The statement will clearly show document-wise details of ITC eligibility.

3. ITC information will be covered from the filing date of GSTR-1 for the preceding month (M-1) up to the filing date of GSTR-1 for the current month (M). For instance, GSTR-2B generated for July 2020 will contain documents filed by their suppliers from midnight on 12th July 2020 up to 11:59 p.m. on 11th August 2020. The statement for July 2020 will be generated on 12th August 2020.

System Generated GSTR-3B: - The table-wise computation of the values, auto-populated in Form GSTR-3B, is made available in PDF format also on the Form GSTR-3B dashboard. The same can be downloaded by clicking on the “System Generated GSTR-3B” tab.

Salient features of ‘System Generated GSTR-3B’:

1. Taxpayers who have filed GSTR-1 for August 2020 on or after September 4, 2020, can view a statement in PDF format on the GSTR-3B dashboard and the same information will be auto-populated in Table 3 of GSTR-3B. These details are:

Details	A column in GSTR-3B
Outward taxable supplies	3.1(a)
Zero-rated supplies	3.1(b)
Nil rated, exempted supplies	3.1(c)
Non-GST outward supplies	3.1(e)

2. These systems computed auto-populated values are only for assisting the taxpayers in filing their Form GSTR 3B.
3. The system will prompt the taxpayers with an alert (Red) in cases where the variance of the edited values from the auto-populated values is higher than a particular threshold. Taxpayers can change/ edit the auto-populated values in Form GSTR-3B.
4. In case the taxpayer has not filed Form GSTR-1 for the period, the system-generated summary will display the respective values as ‘Not filed’.
5. Similarly, if Form GSTR-2B is not generated for the period, the system-generated summary will display the respective values as ‘Not generated’.
6. 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.
7. Table 5 and 6.2 of FORM GSTR-3B is not part of the PDF & will not be auto-populated by the system.

The relevant extract of the

‘Advisory on the Auto population of details in Form GSTR-3B from Form GSTR 1 & 2B’

1. The auto-populated values are generated in the following manner:

GSTR-3B table	GSTR-1/ GSTR-2B table	Reference
Table 3.1(a) Outward taxable supplies (other than zero-rated, nil rated, and exempted)	FORM GSTR-1: Tables-4, 5, 6C, 7, 9, 10 and 11	Values in these tables are computed by doing a total of all the values reported by the taxpayer in the corresponding tables of GSTR-1. This is auto-populated from FORM GSTR-1. Net positive values shall be reported in respective tables. Net negative values, if any, shall not be considered in the table, and the 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 the respective table. Net Negative values, if any, shall not be considered in the table, and the system will provide the value as zero. 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.
		The system computed values do not contain the values about the supplies received from unregistered persons liable to reverse charge, and tax to be paid on reverse charge basis on account of Import of Services. Therefore, these details have to be included by the taxpayer by editing the auto-populated value.
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: a. 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. b. Positive values of all credit notes, on which ITC is not available. c. 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.

2. If any invoice and credit note has been issued in the same month, then both have to be reported separately.

3. In case the net ITC available in table 4C is negative, then such a negative value shall be considered as a liability.

4. Table 5 and 6.2 of FORM GSTR-3B is not part of the PDF & will not be auto-populated by the system.

Author’s Comment

1. The CBIC released an important notification on 9 October 2019, inserting a new sub-rule (4) under rule 36 of the CGST Rules, 2017. The rule states that the provisional tax credit (without invoices on GSTR-2A) can be claimed in the GSTR-3B only to the extent of 10% of eligible ITC reflected in the GSTR-2A.

2. Understanding the need of the hour, CBIC has provided relaxation in compliance with Rule 36(4) of CGST Rules vide Notification No. 30/2020 – CT, dated 3^rd April 2020 as under: –

“Provided that the said condition shall apply cumulatively for the period February, March, April, May, June, July and August 2020 and the return in FORM GSTR-3B for the tax period September 2020 shall be furnished with the cumulative adjustment of the input tax credit for the said months following the condition above.”.

3. Thus, the government required a registered person to make cumulative adjustments on account of 36(4) for February, March, April, May, June, July, August 2020 in the month of the return of September 2020. 

4. Now with this auto-population facility with an intention of ease of business and to facilitate the taxpayer regarding the output liability mapped with GSTR 1 duly filled by him. We are hoping that the history of technical glitches will not be repeated and the advisory issued by the department will be interpreted positively by the revenue.

5. As far as GSTR-2B is concerned the same has not been yet notified as per law and also the Rule 36(4) restriction is concerning the information flowing from GSTR-2A and hence this disconnect has to be well addressed by the department else it will again lead to a new area of litigation.

6. As per our view, this auto-population is a welcome and positive change provided the same should not be used as a mode of inquiry, also there is no restriction in the law to file belated return further as the flow of data from GSTR 2 (inward supplies return as incepted earlier) is not here hence restricting the data on the due date of GSTR 1 is also not justified, at least the data till the due date of the GSTR-3B should be considered.

7. Therefore, still there are some gaps in the prescribed format and proper education to the taxpayer as well as the department should be there to keep track of these large numbers of the form. It is practically not feasible for any taxpayer to keep track of all these new changes as the economy is yet in the revival mode that too at a very slow speed.

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CA Archana Jain & CA Navjot Singh

TaxTru Business Advisors LLP

Feel free to contact the authors at [email protected]/9953357999