This is the time where everyone is busy in GST Audit of financial year 2017-18, Statutory Audit and Tax Audit of financial year 2018-19. Though, one must not miss the vital compliance relating to Input Tax Credit (ITC) for financial year 2018-19.
The important due dates for the Financial Year 2018-19:
According to the first proviso relating to section 37(3) of the CGST Act, any amendments towards the disclosures made in the returns or disclosure of additional details, for Financial Year 2018-19 is required to be done by the due date of providing of the return for the month of September 2019, that is 20th October 2019, or the date of providing of the annual return for Financial Year 2018-19, which one is earlier.
Also relating to section 16 (4) of the CGST Act, 2017, the due date for availing input tax credit (ITC) with regard to any invoice or debit note pertaining towards Financial Year 2018-19 shall be earliest of the following the due date of providing of the return for the month of September 2019 that is 20th October 2019, or the date of providing of the annual return for Financial Year 2018-19.
According to section 34(2) of the CGST Act, any adjustments through a credit note regarding a supply made during Financial Year 2018-19 could be disclosed in a return filed up to 30th September 2019, or the date of providing of the annual return for Financial Year 2018-19, whichever is earlier.
The credit re-computation relating to rule 42 and 43 (for construction industry) of the CGST Rules, 2017 is applicable for businesses making taxable as well as exempted supplies. Comparison of the credit availed during Financial Year 2018-19 with the recomputed credit to make out any credit reversals or availability requisite. For the Financial Year 2018-19, this is to be completed by the due date of September 2019 return, which is 20th October 2019.
Thus, it could be recommended to carry out the following in order to avail any missed credit or towards disclosing any credit notes or make any corrections in the disclosures in the returns, etc. for the Financial Year 2018-19.
• Reconcile Input Tax Credit (ITC) as per books and the ITC in accordance with Form GSTR-3B towards checking for any missed credits.
• Reconcile Input Tax Credit (ITC) availed in Form GSTR-3B and the entries in Form GSTR-2A towards checking any missed credits.
• Re-computation of the credit eligibility in accordance with rule 42 and 43 of the Rules, as applicable.
• Reconcile the turnover in accordance with Form GSTR-3B and Form GSTR-1 towards rectifying any differences between the two.
• Reviewing of the expenses (most importantly the foreign currency payments) towards ensuring that payment of tax under RCM is completed and eligible Input Tax Credit (ITC) is claimed.
• Reconciling the credit notes issued in accordance with books and the credit notes disclosed in returns to check if any disclosures are missed in the returns regarding GST credit notes.
• Reviewing of the contract terms or agreed clauses regarding supplies made during Financial Year 2018-19 towards identifying any agreed downward revision in prices or discounts, that necessitate the issue of a GST credit note as well as issue and disclose the same.
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