Off
late at the end of the financial year 2017-18 it has been seen that most of the
taxpayers have committed two mistakes 1) either they have not declared the
invoice in their returns filed during previous financial year or 2) they have failed
to claim Input Tax Credit with respect to invoices received by them in last
financial year i.e. 2017-18. Most of them are worried about the consequences.
In
the first case where the taxpayer has not discharged any tax liability pertaining
to the previous year, they can do so anytime after the end of the financial
year and pay GST along with interest. Even in case where the taxpayer has issued
a debit note and tax liability is still to be discharged, there is no outward
time limit for paying the tax on such debit notes. The liability can be
discharged any time along with the interest. But this might have negative
consequences as well. Not discharging the tax liability would mean that the
customer of such taxpayer shall not be able to avail the input tax credit. Also
the GST Star Rating of the taxpayer shall fall. But since it is the very first
year, no taxpayer can be expected to be perfect in his compliance, hence forth
nothing to worry most of the taxpayers are sailing in the same boat along with
you.
In
the second case where the taxpayer has forgotten to claim input tax credit or any
invoice is detected at the later stage for claim of input tax credit, the taxpayer
should immediately claim such input tax credit in his next GSTR 3B returns. Such
input tax credit can be claimed maximum in GSTR 3B return pertaining to September
succeeding after the end of financial year or the date of filing of annual
return whichever is earlier. For instance input tax credit with respect to an
invoice received in Financial Year 2017-18 can be claimed maximum in GSTR 3B
return filed for the month of September 2018. Where the taxpayer fails to claim,
such input tax credit shall lapse and would be treated as loss for the
business. Although despite not eligible as input tax credit under GST, the taxpayer
can claim the said loss of ITC as a deduction under business head while filing
his income tax return.
The
other prominent question which arises is that whether such adjustments after
the end of Financial Year would be reported anywhere or not? Let us remind the
readers that there is an annual return as well as per section 44 of CGST Act
2017. Any adjustments made after the financial year shall be reported in such
annual return whose due date is 31st December 2018. Also for
taxpayers whose aggregate turnover in the preceding financial year 2017-18
exceeds Rs. 2 crores their books of accounts shall be separately audited as per
GST Act. The post financial year adjustments shall be reported by the professional
conducting such audit.
The taxpayer should ensure that he makes all such
adjustments before he files his annual return. The auditor will reconcile his financial
statements and the monthly returns filed by the taxpayer and deviations (if
any) found would be reported along with the month in which such deviation has
been rectified.
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