Due date to file annual GSTR-4 for FY 2019-20 gets further extended

The government has further pushed the deadline to file the brand new GSTR-4 annual return for businesses registered under the composition scheme for FY 2019-20. The last date is now 31st August 2020 extended from the earlier due date of 15th July 2020. 

Until FY 2018-19, GSTR-4 was a quarterly return which was converted into an annual frequency from FY 2019-20 onwards. The CBIC issued the CGST Notification number 59/2020 on 13th July 2020 amidst taxpayers’ uproar. Businesses claimed that the filing facility of GSTR-4 is yet to be made available on the GST portal while the deadline was fast approaching. The matter of extension to the annual GSTR-4 filing was taken up for deliberation during the first week of July 2020 by the GST implementation committee. 

The composition dealers under GST can pay a nominal tax along with a statement-cum-challan known as CMP-08 once in every quarter. Only the summary of turnover in the state along with tax amounts was required to be reported. Once the financial year ends, they must file return in form GSTR-4 annually by summing up the details declared in all the four quarterly statements in form CMP-08. 

It is relevant to note that, except for table 5 of the GSTR-4, rest of the details are to be manually reported by the taxpayer. Table 5 of GSTR-4 is to be auto-populated from previously submitted statements in form CMP-08. The rest of the details include rate-wise and GSTIN-level classified information of sales, purchases falling under reverse charge, refunds, TCS or TDS credits received, and interest or late fee payable during the financial year.

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These developments may indicate a dilatory slant of the Goods and Services Tax Network (GSTN). The governing body manages the IT system of GST in India. The delay in building the annual GSTR-4 filing facility and the extension in the last minute also shows lack of regular monitoring by the authorities of the system.

Moreover, even if the GSTR-4 utility is made available now, a month and a half may still be insufficient for the composition taxpayers and tax professionals to complete the filing. Any delay in filing the return beyond the due date will attract a late fee of Rs 200 per day of delay. It is recommended that such late fee be waived off or reduced for filing done till 30th September 2020, similar to the rest of the taxpayer base.

There is another matter yet to be settled amongst the tax professionals. The annual return for composition dealers in form GSTR-9A was earlier waived off for the first two financial years of GST implementation. However, this return is not scrapped for any later years as yet. Hence, whether or not two returns in GSTR-4 and GSTR-9A must be filed annually from FY 2019-20 onwards bearing the same information, is not clarified either by the CBIC or the GST Council.

The annual GSTR-4 filing was previously extended from its original due date of 30th April 2020 to 15th July 2020 to address the COVID-19 crisis. 

For any clarifications/feedback on the topic, please contact the writer at annapoorna.m@cleartax.in