Post amendments in GST law (effective October 1, 2022), November has become an important month for GST compliances. Taxpayers need to close several activities of preceding FY in GSTR-1 / GSTR-3B being filed till November 30.

Vide this Outlook, we intend to highlight key action points required to be undertaken till November 30, 2023 for FY 2022-23:

• Reconciliation of GSTR-1, GSTR-3B and books of accounts for FY 2022-23 and making necessary adjustments / corrections.

• Issuance of GST credit notes for transactions like sales return, price reduction etc. relating to invoices issued in FY 2022-23.

NITYA Comments: It is pertinent to note that Commercial credit notes can be issued without any time limit except for sales return cases. Notably, issuance of debit notes is delinked from date of invoice and can be issued any time.

• Availment of ITC pertaining to FY 2022-23 after keeping in mind overall compliance of Section 16 of the CGST Act read with Rule 36 of the CGST Rules. Taxpayers need to undertake all reconciliations of ITC as appearing in GSTR-2B and books of accounts, make necessary adjustments / corrections etc.

• Reversal of ITC where supplier furnished invoices or debit notes in GSTR-1 but not filed GSTR-3B till September 30, 2023. 

NITYA Comments: This reversal is only applicable on ITC availed post December 26, 2022 i.e. on ITC availed in GSTR-3B of December 2022, January 2023 and February 2023.

• Reporting of opening balance of ITC reversed and pending re-claim in Electronic Credit Reversal and Re-Claimed Statement (‘ECRS’) [For detailed understanding, refer our update NITYA Outlook | Issue 152 | Introduction of Electronic Credit Reversal and Re-claimed Statement Ledger]. 

NITYA Comments: Taxpayers need to undertake multiple activities till November 2023. Taxpayers can consider undertaking ITC review activity on priority to make sure that ITC on disputed expenses like residential accommodation of expats, lease of land, outdoor catering (where mandated by law) etc. is not missed.