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Transition to New GST Returns

This article explains the transition to the new GST Return Forms from the current filing system. The first aspect of the transition is the phased introduction of the new forms.

Phased introduction of new return forms

In order to ensure a smooth transition to the new return forms, the GST Council has introduced these forms in a phased manner. Firstly, tax payers are grouped into two classes -- taxpayers with annual aggregate turnover above Rs 5 Crores considered as large taxpayers and others considered as small taxpayers.

Taxpayer Type Type of Reporting Oct 2019 Nov 2019 Dec 2019 Jan 2020 Feb 2020 Mar 2020
Large Reporting Invoices ANX-1ANX-1ANX-1ANX-1ANX-1ANX-1
Main Return GSTR-3BGSTR-3BRET-1RET-1RET-1RET-1
Payment of Tax GSTR-3BGSTR-3BRET-1RET-1RET-1RET-1
Small Reporting Invoices ANX-1ANX-1ANX-1ANX-1ANX-1ANX-1
Main Return RET-1RET-1
Payment of Tax PMT-08PMT-08RET-1PMT-08PMT-08RET-1

The second aspect of transition concerns how to report old invoices, pay liability, or claim ITC on invoices issued prior to the introduction of the new return forms. The table below lists various scenarios where a tax payer could have missed reporting Invoices in their GSTR-1 or missed reporting liability in their GSTR-3B. The table explains how the tax payer shall remedy such instances.

Document Type Document reported in GSTR-1 Liability reported in GSTR-3B Action to be taken
Invoice or
Credit Note
No No Add Invoice to GST ANX-1.
GST RET-1 Table 3A will automatically include the liability.
GST RET-1 Table 6(1) will automatically include interest on the liability.
Invoice Yes No Report liability in Table 3 A(8) of GST RET-1.
Report interest in Table 6(4) of GST RET-1.
Invoice No Yes Add Invoice to GST ANX-1.
GST RET-1 Table 3A will automatically include the liability.
Reduce liability in Table 3 C(5) of GST RET-1.
GST RET-1 Table 6(1) will automatically include interest on the liability.
Forgo the interest since there is no way to reduce it.
Credit Note Yes No Reduce liability in Table 3 C(5) of GST RET-1.
Credit Note No Yes Add Credit Note to GST ANX-1.
GST RET-1 Table 3C will automatically reduce the liability.
Correspondingly increase liability in Table 3 A(8) of GST RET-1.

A similar issue arises when

  • A recipient has not claimed ITC for Invoices issued prior to the introduction of the new return forms
  • The supplier reports invoices pertaining to Tax Period prior to the introduction of the new returns format in their GST ANX-1.

The table below shows what action the tax payer can take in such instances.

Document Type Reporting of Document ITC Claim Status Action to be taken
Invoice Seen in GSTR-2A Not claimed in GSTR-3B Claim ITC in Table 4 A(4) of GST RET-1.
Credit Note Seen in GSTR-2A Not reversed in GSTR-3B Reduce ITC in Table 4 B(5) of GST RET-1.
Report interest in Table 6(4) of GST RET-1.
Invoice Not seen in GSTR-2A
Seen in GST ANX-2
Not claimed in GSTR-3B Accept the Invoice in GST ANX-2.
GST RET-1 Table 4 A(3) will automatically include the ITC.
Credit Note Not seen in GSTR-2A
Seen in GST ANX-2
Not reversed in GSTR-3B Accept the Credit Note in GST ANX-2.
GST RET-1 Table 4 A(3) will automatically reduce the ITC.
Report interest in Table 6(4) of GST RET-1.
Invoice Not seen in GSTR-2A
Seen in GST ANX-2
ITC claimed in GSTR-3B Accept the Invoice in GST ANX-2.
GST RET-1 Table 4 A(3) will automatically include the ITC.
Reduce ITC in Table 4 B(5) of GST RET-1.
Credit Note Not seen in GSTR-2A
Seen in GST ANX-2
ITC reversed in GSTR-3B Accept the Credit Note in GST ANX-2.
GST RET-1 Table 4 A(3) will automatically reduce the ITC.
Re-Claim ITC in Table 4 A(4) of GST RET-1.