GST Updates

Series 3: How to deal with Issue of Credit Notes in Annual Return for the Year 2017-18

Series 3: How to deal with Issue of Credit Notes in Annual Return for the Year 2017-18

Mr A had made an original Supply in the month of October 2017. There might be three different situations wherein he may issue a credit note to the Recipient. The same are as follows with the relevant year for the purpose of reporting for the purpose of Annual Return.

Section 34 provides that any registered person who issues a credit note in relation to a supply of goods or services or both shall declare the details of such credit note in the return for the month during which such credit note has been issued but not later than September following the end of the financial year in which such supply was made, or the date of furnishing of the relevant annual return, whichever is earlier.

Keeping in the Hindsight, above provision, lets discuss various scenarios relating to Issue and Reporting of Credit Notes in GSTR-3B.

 

  1. Date of Original Supply and Date of Issue of Credit Note 

 

Date of Original Supply Date of Issue of Credit Note
15th October 2017 15th March 2018
15th October 2017 15th April 2018
15th October 2017 15th October 2018

 

  1. Proposed Reporting in Annual Return

 

  • Date of Issue of Credit Note 15th March 2018
Date of Original Supply Date of Issue of Credit Note Shown in GSTR-3B Table
15th October 2017 15th March 2018 March 2018 Table 4 (2017-18)
15th October 2017 15th March 2018 September 2018 Table 11 (2017-18)
15th October 2017 15th March 2018 November 2018 Not allowed to be adjusted against liability under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2018-19

 

  • Date of Issue of Credit Note 15th April 2018

 

Date of Original Supply Date of Issue of Credit Note Shown in GSTR-3B Treatment
15th October 2017 15th April 2018 April 2018 Table 4 (2018-19)
15th October 2017 15th April 2018 August 2019 Not allowed to be adjusted against liability under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2019-20
15th October 2017 15th April 2018 November 2019 Not allowed under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2019-20

 

  • Date of Issue of Credit Note 15th October 2018

 

Date of Original Supply Date of Issue of Credit Note Shown in GSTR-3B Treatment
15th October 2017 15th October 2018 October 2018 Not allowed to be adjusted against liability under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2018-19
15th October 2017 15th October 2018 September 2019 Not allowed to be adjusted against liability under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2019-20
15th October 2017 15th October 2018 February 2020 Not allowed to be adjusted against liability under Section 34 and if Liability reduced then would have to pay additional liability for the Year 2019-20

 

The links to the earlier articles on issue of reporting and other aspects in GSTR-9 and GSTR-9C for the year 2017-18 are as follows:

a) Series-1-Case Studies in Presentation of Input Tax Credit in Annual Return

b) Series-2-Case Studies on Reporting of Input Tax Credit in Annual Return on Credit Availed in Wrong Head, RCM and Transitional Credit

c) Whether Auto-populated Data in Table 4 of GSTR-9 can be used for preparation of Annual Return and possible treatment of Difference between GSTR-1 and GSTR-3B??

d) Details of Books of Accounts, Records and Documents to be maintained in GST (Other than persons covered under Composition Scheme)-Tough Road ahead in GSTR-9C

e) Comparative Analysis of Scope and Reporting Requirements in Part B of GSTR-9C – Why the difference in Scope and Responsibilities and what purpose would submission of Cash Flow Statement suffice

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