GST Updates – Extension of due dates and other reliefs

In order to tackle compliance-related issues faced by public at large in view of the spread of the COVID-19 pandemic, CBIC has issued various notifications dated 3rd April, 2020 wherein they have notified revised due dates and has provided certain reliefs for various GST compliances.

The key highlights of these notifications are provided here under for your ready reference:

1) Vide Notification No. 33/2020 dated 3rd April 2020, due date for filling GSTR 1 has been relaxed and late fee has been waived off.

Return Period	Due Date	Revised Due Date	Remarks
March, 2020	11-April-2020	30-June-2020	No late fee shall be levied if the return is filed up to 30th June, 2020
April, 2020	11-May-2020
May, 2020	11-June-2020

2) Vide Notification No. 31/2020, Notification No. 32/2020 & Notification No. 36/2020 dated 3rd April 2020, CBIC has waived/ lowered the interest payable & waived the Late Fees payable for furnishing of Returns in form GSTR 3B.

i) Taxpayers having an aggregate turnover up to INR 5 crores in the preceding financial year:

Return Period	Actual Due Date*	Revised Due date		Remarks
Return Period	Actual Due Date*	Turnover up to 1.5 Crore in preceding F.Y.	Turnover of more than 1.5 Crore but up to 5 Crore in preceding F.Y.	Remarks
February, 2020	20th March, 2020	30th June, 2020	29th June, 2020	No late fee shall be levied if the return is filed up to specified revised due date. No interest obligation will arise if the return is filed within the respective revised due dates. However, in case the return is filed after the respective due dates, then interest at the rate 18% p.a. shall be levied from the actual due date till the date of filing of return.
March, 2020	20th April, 2020	03rd July, 2020	29th June, 2020
April, 2020	20th May, 2020	06th July, 2020	30th June, 2020
May, 2020	*Staggered Manner*			Revised due dates would be 12^th and 14^th July 2020 depending upon the state of registration.

* Due dates of GSTR-3B for taxpayers having turnover up to INR 5 Crore are different for different states. Therefore, for the sake of brevity, it is assumed that the said due date for all the states is 20^th day of the subsequent month.

ii) Taxpayers having an aggregate turnover of more than INR 5 crores in the preceding financial year:

Return period	Actual Due date	Effective revised Due date	Remarks
February, 2020	20th March, 2020	04th April, 2020	Though the due date for GSTR 3B has not been extended, however, due to relaxation on account of no late fee and no interest, there is effective revision of Due dates of GSTR 3B. No late fee shall be levied if the return is filed up-to 24^th June, 2020. No interest obligation will arise if the return is filed within the respective revised due dates. In case the return is not filed within the respective revised due dates but filed on or before 24^th June 2020, a reduced rate of interest at the rate 9% p.a. shall be levied from the revised due date till the date of filling of return. However, in case the return is filed after 24^th June, 2020 then interest at the rate 18% p.a. shall be levied from the actual due date till the date of filing of return.
March, 2020	20th April, 2020	05th May, 2020
April, 2020	20th May, 2020	04th June, 2020
May, 2020	20th June, 2020	27th June, 2020	Due Date Extended by 7 Days.

3) Vide Notification No. 30/2020 dated 03rd April, 2020, a proviso has been inserted in order to relax condition as specified in Rule 36(4) i.e. matching of Purchases with GSTR-2A and claiming input tax credit (ITC):

* The condition of capping of Input tax credit (ITC) on the basis of supplies reflecting in Form GSTR-2A, shall not apply to the ITC availed in GSTR-3B filed for the month of February, March, April, May, June, July and August, 2020. However, the said condition would be required to be complied with cumulatively in the return furnished for the month of September, 2020.

* Therefore, the GSTR-3B to be furnished for the aforesaid 7 months, ITC may be claimed irrespective of whether the same is reflected in Form GSTR-2A of the respective tax period. However, form GSTR-3B for the month of September, 2020 shall be furnished taking into account, cumulative adjustment of ITC for the period February, 2020 to September, 2020.

4) Vide Notification No. 35/2020, dated 3rd April, 2020, Time Limit for completion of below activities extended up to 30th June, 2020, if the prescribed time limit falls during the period 20th March to 29th June, 2020:

* Completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, or

* Filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called, under the provisions of the GST Acts.

However, the aforesaid extension would not apply, inter alia, to any compliance's related to the following, and the same shall continue as per the normal course:

*        Determination of time of supply and value of supply
*        GST registration
*        Issue of invoices, credit and debit notes by taxpayers within prescribed time limits
*        Power of search, seizure and arrest operations by the tax authorities
*        Inspection of goods in transit

5) Vide Notification No. 35/2020 dated 3rd April, 2020, Validity of E-way bill extended

In order to provide relief to the industry grappling with issues of supplies and goods stuck in transit, government has extended the validity period of e-way bills till 30th April 2020, in case the same expires during the period 20th March 2020 to 15th April 2020.