Summary of important GST amendments in last couple of months
Summary of important GST updates published via the advisories in the GSTN portal are provided below:
Introduction of RCM Liability/ITC Statement
A new statement, titled ‘RCM Liability / ITC Statement,’ has been introduced on the GSTN portal to help GST authorities track RCM liabilities reported in Table 3.1(d) of GSTR-3B and ITC claimed in Table 4(A)(2) and Table 4(A)(3) of GSTR-3B. GSTN has requested the taxpayers to report the amount of ITC that is yet to be claimed on tax discharged (in Table 3.1(d) of GSTR-3B) on RCM basis.
As per the said advisory, the taxpayer is required to report an opening balance in the said ledger considering RCM ITC till the July 2024 return period.
Further, in case the taxpayer has temporarily reversed certain eligible RCM ITC in the earlier periods [through Table 4(B)(2) of GSTR-3B], such ITC can be reclaimed through ‘All other ITC’ i.e., Table 4(A)(5). The taxpayer shall report the opening balance within 31-10-2024. Further, in case of any errors committed while reporting the opening balance, the same can be amended thrice on or before 30-11-2024.
Extension of due dates for reporting opening balance of Electronic Credit Reversal and Re-claimed Statement
This has reference to the advisory issued by the GSTN portal with regard to introduction of a new ledger named ‘Electronic Credit Reversal and Re-claimed Statement’ during the month of August 2023. GSTN has requested the taxpayers to report the amount of input tax credit that they would like to claim. This was introduced to have a track on the ITC temporarily reversed [through Table 4(B)(2)] and ITC reclaimed through Table 4(D)(1). The said balance was supposed to be reported within 31-01-2024. Since, some of the taxpayers did not report the opening balance within specified time, GSTN has provided an opportunity to report the same. The opening balance shall be calculated by considering the ITC reversal made till July 2023. The functionality to report the opening balance shall be available till 31-10-2024 and the same can be amended thrice till 30-11-2024.
Archival of GST returns data on GST portal
Increasing data in the GST portal on account of increase in the taxpayer base, improved compliance, etc are leading to GST System performance issues. In this regard, GST Council recommended a data archival policy.
In view of above, data of returns filed for the month of July 2017 has been archived on 01-08-2024 and for August 2017 has been archived on 01-09-2024. This data archival is a monthly activity. Accordingly, data of returns filed for the month of September 2017 shall be archived on 01-10-2024. In this regard, advisory recommends taxpayers to download the relevant data from the GST portal. The last date to download the data pertaining to returns filed for September 2017 is 30-09-2024, for October 2017 is 31-10-2024 and so on.
Invoice Management System
Invoice Management System (IMS) is a facility in the GST system, where the invoices / records saved / filed by the supplier in GSTR-1/1A/IFF, can be accepted, rejected or kept pending by recipients in order to correctly avail ITC. Only those invoices which are accepted by the recipient shall appear in their GSTR-2B.
The aforesaid facility shall be available to recipients as soon as it is saved by the supplier in the subsequent month and the recipient shall accept / reject / keep the invoices in pending until the GSTR-3B is filed. Accepted records shall be auto populated in GSTR-2B on 14th of subsequent month. However, in case where there is a change in the action previously taken or action taken after 14th of the subsequent month, GSTR-2B has to be regenerated and such updated values shall flow to GSTR-3B. This facility would be made available to taxpayers from 14-10-2024 for taking actions on invoices received in their login.