GST – Initial Return Filing under GSTR 3B

In this article, we will discuss return filed in GSTR-3B, but first, we will try to understand what are the returns that are required to be filed in general course of business. In the normal course of business taxpayers are required to file:

  • For monthly filing in forms GSTR-1, GSTR-2, GSTR-3, GSTR-5, GSTR-6, GSTR-7, GSTR-8, GSTR-11.
  • For quarterly return filing, GSTR-4 is needed,
  • For annual return filing Form GSTR-9 required and
  • Form GSTR-10 is required to be filed as the final return in case of surrender or cancellation of registration.

To gain detailed insights about returns to be filed under GST and their due dates, you can refer to our previous articles on our website.

As with anything new, GST will also have its share of issues and problems in the initial stages. And it would be difficult for the taxpayers to file timely returns that are required to be filed under GST, for the simple reason of unfamiliarity with the procedures. There are many other reasons which make it difficult for taxpayers to file timely compliances, like these returns ask for GSTIN No the taxpayer, any many taxpayers are still not registered under the Act.

In order to ensure the smooth rollout of GST and after considering the recommendations of the key industry players, time limits for furnishing the Returns under GST are extended. After the Council meeting held on Sunday 18th June 2017, Arun Jaitly announced that return filing timelines under GST are to be relaxed and extended up to September.

Relaxations and Extension Granted

Decisions are taken in this council meeting state that for the first two months i.e. for the month of July and August a simplified tax return is to be filed in Form GSTR-3B, containing the summary of Inward and Outward supplies. This form is required to be filed on 20th of the next month.

What is Form GSTR-3B?

Sub-rule 5 of Rule 64 of CGST Rules, specify the provisions relating to Form GSTR-3B. Section 37 and 38 specify the due dates for furnishing details in GSTR-1 and GSTR-2 respectively. These relevant dates are 10th and 15th of every month. This rule states that if the time limit for furnishing these details has been extended and circumstances so warrant, then return is to be filed in GSTR-3B in lieu of GSTR-3 (monthly return) as per the conditions as specified by the Commissioner.

After the extended period when GSTR-1, GSTR-2 and GSTR-3 will be filled, GSTR-3 will be auto populated with the information furnished in the two previous forms. If there are any differences between the information filed in GSTR-3 and GSTR-3B, then such difference will be refunded or paid, as the case may be. However, the taxpayer won’t be liable to pay any interest, late fee or penalty for such excess amount.

Extensions granted for filing these monthly returns

The government has granted extensions for monthly returns that are required to be filed. These returns include:

  • GSTR-1 : For details regarding outward supply.
  • GSTR-2 : For details regarding inward supply.
  • GSTR-3 : it is a monthly return required to be filed.

These extensions are only given for the months of July and August. While 25 days extension is given for the month of July, only 10 days extension is given for the month of August. To understand it more clearly about what will be the due dates of filing of different forms after such extension refers to the table given below.

GSTR-1 GSTR-2 GSTR-3
JULY
Actual Date 10th August 15th August 20th August
Extended Date (+25 days) 5th September 10th September 15th September
AUGUST
Actual Date 10th September 15th September 20th September
Extended Date (+10 days) 20th September 25th September 30th September

This table clearly shows the actual and extended dates for filing of these returns. However, on the other hand, Form GSTR-3B is required to be filed on 20th of the next month. It means that GSTR-3B for the month of July and August will be filed on 20th August and 20th September respectively.