Recent developments on New GST Return System

This is to apprise you on recent developments in respect of ‘new GST return system’ (‘new return system’), which has been on cards for quite some time.

The basic design of this new return system was approved by GST Council in its 27th meeting and the key features and formats of returns were discussed in 28th GST Council meeting. The GST Council in its 31st meeting, announced that this new return system would be introduced on a trial basis from April 1, 2019 and will be made mandatory from July 1, 2019. The implementation timeline was however deferred.

In a fresh upsurge to implement the new return system, Government has recently released the draft new return forms. For a large taxpayer (with turnover more than 5 crores), the following forms are relevant:

* FORM GST ANX-1: Capturing outward supplies and inward supplies attracting reverse charge (similar to GSTR-1)
* FORM GST ANX-2: Auto-populated form fetching details from ANX-1. Recipient to take action to accept / reject / pending invoices (similar to GSTR-2A)
* FORM GST RET-1: Auto-populated from the Forms GST ANX-1 and ANX-2, some additional data input and payment of taxes (similar to GSTR-3)

Though the date of implementation of new return system has not been finalised yet, the GST Council through a Press Release dated June 11, 2019 has chalked out an indicative transitional plan. This transition plan has been tabulated below:

Return filing month
GSTR-1
GSTR-3B
GST ANX-1
GST ANX-2
GST RET-1
June 2019 to
September 2019

October 2019 to
November 2019

December 2019
onwards

Notes:

1) Prototype offline tools of FORM GST ANX-1 and FORM GST ANX-2 have already been made available on GST portal w.e.f. May 2019

2) FORM GST ANX-2 will be available for view and download from July 2019. Facility to importpurchase register in offline tool and matching with invoices appearing in ANX-2 will be available from August 2019.

3) New return formats are made operational initially only for trial purposes. Taxpayers will continue to file existing return forms i.e. GSTR-1 and GSTR-3B till September 2019.

4) No instructions have been released on other forms such as ISD return, job-work return etc. Further, for refund applications, specific instructions will be issued between October to December 2019.

NITYA Comments:

* The whole idea behind the new return system is to automatically link the supplier’s data with the recipient’s data. The intention was no different at the time of inception of GST but due to IT glitches, the same could not find its fate. The new system is a fresh try to put in place the fundamental essence of GST compliances. It would be interesting to witness the forthcoming events unfold.

* That said, the taxpayers need to gear up and prepare themselves during this trial period by following the below mentioned steps:

? Analyse the prototypes available on GST portal and align the ERPs basis the data requirements in new forms.

? Once the forms become operational in July 2019, taxpayers should feed the sample data to understand the difficulties.

We will be sharing a separate update containing our detailed views on the new forms.

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