Relief in GST Compliances

Notification 30/2020, Notification 31/2020, Notification 32/2020, Notification 33/2020, Notification 34/2020, Notification 35/2020 and Notification 36/2020

The Government announced certain relief measures in GST and other laws in order to provide relief to the trade and industry amidst lockdown due to the ongoing pandemic. Accordingly, certain notifications were issued on 3rd April 2020 under the Central Goods and Services Tax Act, 2017 (CGST) and similar notifications under the Integrated Goods and Services Tax Act, 2017 (IGST) & Union Territory Goods and Services Tax Act, 2017 (UTGST).

1. Extension of time limit for filing GSTR 3B (no due date extension for Feb, March and April 2020)

As explained in the table below, due dates have not changed however, an extension is provided in terms of filing GSTR 3B for Feb, March and April 2020 if certain conditions are satisfied.

Further, for the month of May 2020 the due date of filing GSTR 3B has extended as follows:

Turnover limits	Registered in the State of	Due date as extended
> 5 crores	Any State	27th June 2020
Up to 5 crores	Specified States*	12th July 2020
Up to 5 crores	Specified States$	14th July 2020

* Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the Union territories of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands or Lakshadweep

$ Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha, the Union territories of Jammu and Kashmir, Ladakh, Chandigarh or Delhi

2. Extension of time limit for filing GSTR 1

For the months of March, April and May 2020, and also for the quarter ended 31st March 2020, no late fee will be payable, if GSTR 1 for the said period is filed on or before 30th June 2020.

3. Relief provided to composition taxpayers

a. Statement containing details of payment of self-assessed tax in FORM CMP-08 for the quarter ending 31st March 2020, has been extended from 18th April 2020 to 7th July 2020.

b. Due date of GSTR 4 for FY 2019-20 has been extended from 30th April 2020 to 15th July 2020.

c. For anyone wanting to opt for composition scheme for FY 2020-21, intimation is required to be filed in FORM GST CMP-02. The last date for opting for such intimation has been extended to 30th June 2020.

Also, when shifting from regular taxpayer to composition taxpayer, a statement in FORM ITC-03 is required to be submitted, thereby declaring the stock as on 31st March 2020 and reversing credit/ paying tax on such stock. The due date of this statement has also been extended to 31st July 2020.

4. Cumulative application of Rule 36(4) relating to availment of credit up to 110% of eligible credit appearing in GSTR 2A

The condition of availing credit of up to 110% of eligible credit appearing in GSTR 2A will not be applicable cumulatively for the months of Feb, March, April, May, June, July and August 2020. The return in FORM GSTR 3B for September 2020 will be furnished with cumulative adjustment of this condition for the said months.

5. Extension of time for completion or compliances of any action, validity under the CGST Act, IGST Act, UTGST Act

Completion of action or compliance of action	Extended due date
Orders passed, notices issued, intimations, notifications, sanctions or approval of action, etc. by any authority, commission or tribunal	30th June 2020
Appeals to be filed, reply or application to be furnished under the provisions of the acts	30th June 2020

However, this will not apply for provisions of the law that have already been extended vide other notifications discussed above for instance in case of filing of forms GSTR 3B, GSTR 1, CMP-02, CMP-08, etc. Also, it will not apply in case of some other provisions:

(a) Chapter IV;

(b) Sub-section (3) of section 10, sections 25, 27, 31, 37, 47, 50, 69, 90, 122, 129;

(c) Section 39, except sub-section (3), (4) and (5);

(d) Section 68, in so far as e-way bill is concerned; and

(e) Rules made under the provisions specified at clause (a) to (d) above