“Time and tide wait for none” quoted Geoffrey Chaucer. With deadline extensions in GST compliance, keeping track of time is essential to avoid penalties. July 2020 has a couple of deadlines that GST registered businesses ought not to miss.
The repercussions of not filing GSTR-3B may look less harmful in the first reading due to the late fee waiver up to 30th September 2020. But then, the catch here is to puzzle out the interest implications. So, let’s check out these compliances, one at a time.
1) CMP-08 for composition dealers
CMP-08 is a quarterly challan-cum-statement for composition dealers to pay taxes on or before 18th of the month succeeding every quarter. Small businesses had to opt into the composition scheme in form CMP-02 freshly for FY 2020-21. This window got closed recently on 30th June 2020.
The due date to file CMP-08 for the quarter ending 31st March 2020 was extended to 7th July 2020. Additionally, the due date for the quarter ending 30th June 2020 in FY 2020-21 is 18th July 2020.
If you happen to miss the above CMP-08 due dates, you will end up paying a late fee of Rs 200 per day from the next day up to the actual date of filing. Moreover, standard interest at the rate of 18% p.a. shall apply on the tax liability.
2) Annual GSTR-4 for composition dealers
Last year, GSTR-4 was converted into an annual return with a new format. The return had to make its debut for FY 2019-20 on or before 30th April 2020 but got extended to 15th July 2020.
However, the return is yet to go live for the users on the GST portal. With roughly a week left for meeting this deadline, it is not hard to predict a further extension for this compliance.
Nevertheless, a late fee of Rs 200 per day shall apply for failure to file within the due date up to the actual date of submission.
3) GSTR-1 for regular taxpayers
Three monthly and one quarterly GSTR-1s are due this month. GSTR-1 for the quarter ending 31st March 2020 must be filed on or before 17th July 2020. The monthly GSTR-1 for March, April and May 2020 fall on 10th, 24th and 28th July 2020 respectively.
As per the GST law, the late fee on any failure would be Rs. 200 per day from the next day onwards up to the actual date of filing.
Also Read: The Rise in GST e-Way Bills Leads to Normalcy of Indian Economy
4) GSTR-3B for regular taxpayers
GSTR-3B return for several months is clogged in July 2020. While this may not be a big concern for individual businesses as their return may fall on one or two dates, but may become unmanageable for the tax professionals who have to file for multiple clients.
The taxpayers are classified based on their aggregate turnover in the previous financial year, i.e. 2019-20 – Above Rs 5 crore and equal to or below Rs 5 crore. The latter is further divided based on the state or Union Territory in which the principal place of business is located, as follows:
Category A: Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Andhra Pradesh, Telangana, the Union Territories of Daman and Diu and Dadra and Nagar Haveli, Lakshadweep, Puducherry, and Andaman and Nicobar Islands.
Category B: Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Arunachal Pradesh, Sikkim, Nagaland, Manipur, Mizoram, Meghalaya, Assam, Tripura, West Bengal, Jharkhand, Odisha, the Union Territories of Jammu and Kashmir, Ladakh, New Delhi, and Chandigarh.
The GSTR-3B dates falling in July 2020 are tabled below.
| Annual Turnover in the Previous FY | Period | Due date | Last date without late fee or interest, as applicable |
| More than Rs.5 crore | Jun 2020 | 20th July 2020 | 20th July 2020 |
| Up to Rs. 5 crore in category A States/UTs | Mar 2020 | 22nd April 2020 | 3rd July 2020 |
| Apr 2020 | 22nd May 2020 | 6th July 2020 | |
| Up to Rs. 5 crore in category B States/UTs | Mar 2020 | 24th April 2020 | 5th July 2020 |
| Apr 2020 | 24th May 2020 | 9th July 2020 |
20th July 2020 is the actual due date for filing GSTR-3B of June 2020 by large taxpayers. Hence, failure to file by this date will attract a late fee from the next day onwards up to the actual date of filing. However, the maximum late fee cannot exceed Rs 500 if the return is filed on or before 30th September 2020. In this case, the interest for any delay shall be charged at 18% p.a. till the actual date of filing.
For the rest, the original due dates were not extended, but the late fee was relaxed. If the taxpayer misses the above dates, a late fee shall apply with a maximum cap of Rs 500 if filed on or before 30th September 2020. Interest will be charged in a staggered manner- nil up to the above date, 9% p.a. from the next day onwards up to 30th September 2020 and 18% p.a. thereafter.
5) Form ITC-03 for taxpayers switching to composition scheme in FY 2020-21
Every composition dealer who newly switched into the scheme for FY 2020-21 must reverse any input tax credit availed on the closing stock as on 31st March 2020. The details must be declared in form ITC-03 and filed within one month from the date of filing form CMP-02.
It was pushed to 31st July 2020 through an extension to form CMP-02 filing. Any failure to file this form by the due date will attract penal interest at 24% p.a.
Hence, manage your schedule, and beat the clock to avoid hefty interest and late fee levy.
For any clarifications/feedback on the topic, please contact the writer at annapoorna.m@cleartax.in
Annapoorna, popularly known as Anna, is an aspiring Chartered Accountant with a flair for GST. She spends most of her day Singing hymns to the tune of jee-es-tee! Well, not most of her day, just now and then.
