GSTR-3B: CHANGES IN REPORTING AND FILING
CBIC has notified a series of changes in filing of its existing return in Form GSTR-3B. Form GSTR-3B is the return through which the Government collects tax from its taxpayers.
1) CBIC has introduced a new table 3.1.1 in which taxpayers will be required to provide details about supplies made through e-commerce operators (ECO), where such ECO pays tax on reverse charge basis.
2) Part B and part D of table 4 has also been amended. Part B deals with reversal of ITC and part D deals with reporting of ITC which does not affect ITC eligibility.
3) Part B and part D of table 4 now reads as –
(B) ITC reversed
(i) As per rules 38, 42 and 43 of CGST Rules and sub-section (5) of section 17
(ii) Others
(D) Other details
(i) ITC reclaimed which was reversed under Table 4(B)(2) in earlier tax period
(ii) Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions
4) Further CBIC has also issued a circular directing the taxpayers to file returns correctly and properly.
Tables of Form GSTR-1 and Form GSTR-3B shall furnish correct and proper information of inter-state supplies and amount of ineligible/blocked ITC and reversal thereof.
5) The guidelines stated in the circular are –
a) Inter-state supplies made to unregistered person shall be reported place of supply wise in Table 3.2 of Form GSTR-3B and Table-7B or Table 5 or Table 9/10 of Form GSTR-1.
b) Inter-state supplies made to composite dealers shall be reported place of supply wise in Table 3.2 of Form GSTR-3B and Table-4A or Table 4C or Table 9 of Form GSTR-1.
c) Registered person shall update their customer database properly with correct state name and ensure that correct POS is declared in tax invoice and relevant returns.
d) Total ITC – eligible as well as ineligible, as per Form GSTR-2B, shall be reported in different fields of table 4A in Form GSTR-3B.
e) Reversal of ITC which are absolute in nature and non-reclaimable shall be reported in table 4 (B) (1) of Form GSTR-3B.
The following ITC shall be reported –
i) Rule 38 (reversal of credit by a banking company or a financial institution)
ii) Rule 42 (reversal on input and input services on account of supply of exempted goods or services)
iii) Rule 43 (reversal on capital goods on account of supply of exempted goods or services)
iv) Ineligible / blocked ITC under section 17(5) of the CGST Act
f) Reversal of ITC which are not permanent and can be reclaimed, subject to specific conditions, shall be reported in table 4 (B) (2) of Form GSTR-3B. The following ITC shall be reported-
i) Rule 37 (non-payment of consideration to supplier within 180 days)
ii) Section 16(2)(b) (non-receipt of goods or services in relevant tax period)
iii) Section 16(2)(c) (tax has not been paid by the supplier)
iv) Reversal of any ITC availed in previous tax periods because of some inadvertent mistake
g) In part D of table 4, the taxpayer shall disclose such details which do not have bearing on the ITC that will be credited to the Electronic Credit Ledger. The following shall be reported in part D of table 4 of Form GSTR-3B-
i) ITC reclaimed which was reversed under Table 4(B)(2) in earlier tax periods as mentioned in point (f) above.
ii) Ineligible ITC under section 16(4) – where ITC becomes ineligible on account of limitation of time period (30th September of the subsequent year)
iii) ITC restricted due to PoS provisions (where recipient of intra-state supply is located in different state / UT than that of place of supply)
