Last date to amend sales/CDN and claim ITC of FY 2021-22 changed

The government has notified the Budget 2022 decision to move the annual GST deadline for reconciliation to the 30th of November 2022, giving more time to taxpayers to complete annual GST reconciliations. The Central Board of Indirect Taxes and Customs (CBIC) issued Central Tax notification no. 18/2022 on the 28th of September 2022. 

The notification mentions that the 1st of October 2022 shall be the date from when Sections 100 to 114 shall be implemented, except Sections 110(c) and 111 of the Finance Act 2022. The major update that industry and tax professionals were waiting for falls under Sections 100, 102, and 103. These amend Sections 16(4), 34 and 37 of the Central Goods and Services Tax (CGST) Act.

Earlier, the taxpayers could reconcile and make amendments to sales invoices and Credit/Debit Notes (CDN) or claim any previously missed Input Tax Credit (ITC) belonging to FY 2021-22 earlier of two dates. Firstly, the due date of filing GSTR-1/3B of September 2022 and, secondly, the date of filing Form GSTR-9. Hence, the window was the GSTR-1/3B for monthly filers and the Invoice Furnishing Facility (IFF)/GSTR-1/GSTR-3B for quarterly filers.

With this notification that applies after the 1st of October 2022, the due date stands revised from FY 2021-22 onwards for disclosing such yearly amendments or previously missed reporting to earlier of the 30th of November 2022 or the date of filing Form GSTR-9.

Many may wonder if a new window will be introduced for making the new annual reporting deadline since GST returns have always been the facility for the same. It can be interpreted that the due date to file IFF/GSTR-1/GSTR-3B for October 2022 will practically be the deadline for finishing annual reconciliations for FY 2021-22 and reporting. 

Hence, note the annual reconciliation deadline as the 11th/13th of November 2022 for GSTR-1 and the 20th of November 2022 for GSTR-3B.

It creates another issue for quarterly filers currently opted into the Quarterly Return filing and Monthly Payment (QRMP) scheme 22-23. They had to finish annual reconciliations for FY 2021-22 by the due date of GST returns for the second quarter of FY 2022-23, i.e., July-September 2022. 

But with the revision, they do not have a window in November 2022 (middle of the third quarter) to submit missed ITC claims. Nevertheless, they can still amend Business-to-Business (B2B) invoices or CDNs of FY 2021-22 while reporting these in the IFF of October 2022.

One must wait and watch if the GST Network plans to introduce a special window to make missed ITC submissions of the previous year between 20th to 30th November 2022. It will help all the taxpayers if the government relaxes any late fee levy on any delay in the submission of GSTR-1/GSTR-3B/IFF for October 2022 until the 30th of November 2022.

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