Since we are inching towards the end of this Financial Year, here is check-list of GST tasks that should be taken care of before you file February/March 25 GSTR 1 & GSTR 3B:
1. Filing of all the pending GST Returns for April 2024 till January’25 / February’25 to avoid penalty and GST cancellation.
2. Outward Supplies Reconciliation: GSTR 3B v/s GSTR 1 v/s Books
a. In case of outward supplies made, you need to take care of provision of Section 34(2) of the CGST act, which states “Any registered person who issues a credit note in relation to a supply of goods or services or both shall declare the details of such credit note in the return for the month during which such credit note has been issued but not later than November following the end of the financial year in which such supply was made and the tax liability shall be adjusted in such manner as may be prescribed”
b. Similarly, the Proviso to sub-section (3) to Section 37 states “Provided that no rectification of error or omission in respect of the details furnished under sub-section (1) shall be allowed after furnishing of the return under section 39 for the month of November following the end of the financial year to which such details pertain”.
c. Therefore, in case of outward supplies (which includes invoices, debit notes, credit notes and revised invoices issued in relation to outward supplies made during any tax period), kindly make sure that, any reporting / rectification in relation to Outward Supplies of FY 2024-25, are duly reported / corrected in the GSTR-1 of Feb’25 / Mar’25, so that your buyers’ ITC gets reflected correctly in their GSTR-2B within the FY 2024-25.
d. If counter party is not able to find our sales invoice in his GSTR 2B, then there might be chances that you have filed GSTR 1 wherein you have shown sales in B2CS but it was actually B2B sales. In such case amendment of B2CS is required and also you have to upload the bill in B2B afresh.
e. Make sure that the adjustment of Output Tax reported, if any, in Table 10 and Table 11 of GSTR-9 for FY 2023-24 have been duly reconciled vis a vis with the Output Tax of FY 2024-25.
f. If mistakenly Nil or wrong or incomplete GSTR 1 is uploaded where invoices pertaining to some months not uploaded or uploaded to wrong GSTIN of buyer or you have uploaded on some of sheets of GSTR1, then Amendments are required.
g. In case there has been any disposal of Fixed Assets during the period Apr’24 to till date, make sure that the applicable GST is discharged and duly record in Books, GSTR-1 and GSTR-3B.
h. In case there has been any disposal of Scrap during the period Apr’24 to till date, make sure that the applicable GST is discharged and duly record in Books, GSTR-1 and GSTR-3B.
3. ITC Reconciliation: GSTR 3B v/s GSTR 2B v/s Books for Inward credit.
a. Please take a note that as per provision of Section 16(4) of the CGST Act, “A registered person shall not be entitled to take input tax credit in respect of any invoice or debit note for supply of goods or services or both after the due date of furnishing of the return under section 39 for the month of November following the end of financial year to which such invoice or invoice relating to such debit note pertains”
b. Therefore, in case there is a credit which pertains to FY 2024-25 as per your books of account, but the same has not been taken/availed in your GSTR-3B returns filed, kindly make sure to avail this credit in GSTR-3B of Feb’25/Mar’25 and so that it is not required to separately track it for correct reporting in the GST Annual Return (GSTR-9 of FY 2024-25)
c. Make sure to keep a track of ITC reversed and ITC reclaimed during FY 2024-25, in such a way that you have available with you after every return, a list of invoices of Inward Supply, on which ITC has been reversed under Table 4(B)(2) and the reclaim of the same is yet to be made. Kindly make sure that the total ITC pertaining to such Invoices, reconciles with the amount appearing on the GST Portal under “Electronic Credit Reversal and Re-claimed Statement”
d. Kindly reconcile the ITC claimed in FY 2024-25 vis a vis the credits available as per GSTR-2A/ GSTR-2B and in case of discrepancies, kindly follow-up with your relevant vendors for making appropriate correction in their GSTR-1s, so that the Credits correctly reflect in your GSTR-2A/ GSTR-2B within the FY 2024-25.
e. A new feature, the ‘Invoice Management System (IMS)’, has been introduced on the GST Portal, providing taxpayers with the option to either Accept ITC, Reject ITC, or Keep the ITC as Pending against a Tax Invoice. The ITC figures will be automatically populated in GSTR 3B based on the actions taken by the taxpayer. In case no action is taken by the taxpayer, all ITC invoices will be considered as accepted and will auto-populate in GSTR 3B. Currently, the use of IMS is optional.
f. Further, take note that Table 8A of GSTR-9 is auto populated on the basis of ITC reflecting in GSTR-2A, hence so far as rectification pertaining to FY 2024-25 are done on or before filing GST Returns for Mar’25, it would have as much less discrepancies to reconcile.
g. Make sure that the adjustment of ITC reported in Table 12 and Table 13 of GSTR-9 for FY 2023-24 have been duly reconciled vis a vis the ITC of FY 2024-25.
h. Make sure that in case of vendors invoices against which ITC has been availed during the FY 2024-25 have been either paid with-in 180 days of the booking of the Invoice or the ITC is reversed and accounted for in control account, which shall be re-availed upon payment to the vendor.
i. Make sure that in case of RCM is applicable for Inward supplies availed during the FY 2024-25 has been paid and eligible ITC against the same has been claimed. You may kindly refer our RCM Circular for details on this link –
https://njjain.com/gst-alerts/gst-alert-on-reverse-charge-on-goods-under-gst/
https://njjain.com/gst-alerts/gst-alert-on-reverse-charge-on-services-under-gst/
j. Also reconcile the RCM reflected in GSTR 2B with Books of Accounts, in case the RCM Invoices are uploaded by mistake or under wrong GSTIN (of our own), by your vendor, then kindly follow-up with your relevant vendors for making appropriate correction in their GSTR-1s to rectify the situation for avoiding any adverse tax implication or further notice seeking payment under RCM from your jurisdictional officer.
k. Kindly check the POS along with the GSTIN of vendor for purpose of availing correct ITC under the head IGST or CGST and SGST head.
4. Kindly take into consideration, the impact of Circular No.170/02/2022-GST dated 6th July, 2022 which deals with reconciliation of ITC reflected in GSTR 2B with ITC availed in GSTR-3B/Books. Kindly refer to the mail subjected “Recommendations for complying with Circular 170 – Update GSTR-3B Format” dated 14th June 2023 which explains the entire process for availing ITC in accordance with the circular 170.
5. An Amnesty Scheme has been introduced for FY 2017-18, 2018-19, and FY 2019-20, offering a waiver of Interest and Penalty for any Notice/Order issued under Section 73 of the CGST Act, 2017, provided the taxpayer pays the full tax demand on or before 31st March 2025. Therefore, it is important to ensure that tax payments are made before the deadline of 31st March 2025.
You may kindly refer our article on the scheme for details on this link –
https://njjain.com/articles/gst-amnesty-scheme-for-section-73-cases/
6. Starting from 1st April 2025, businesses with multiple GST registrations under the same PAN will be required to obtain an ISD (Input Service Distributor) registration for the purpose of distributing ITC related to “Common Input Services” incurred by the Head Office (HO) or any other branch for or on behalf of branches located in different states. This ITC distribution will cover eligible, ineligible, and RCM ITC. – You may kindly refer our alert for details on this link –
https://njjain.com/gst-alerts/gst-alert-on-input-service-distributor-isd-vs-cross-charge/
7. As per the recent advisory issued on 22nd January 2025, the GST department is set to implement mandatory reporting of HSN/SAC codes under GSTR-1/GSTR-1A in Table 12 of GSTR-1. Taxpayers will be required to select the HSN/SAC code from a predefined drop-down list. Under this system, HSN/SAC reporting for B2B and B2C transactions will be handled separately and verified against the figures provided in the relevant tables in GSTR-1. Please note, after this change, manual entry of HSN/SAC codes will no longer be allowed. This is not mandatory yet on the portal but might get in near future.
8. As per Circular 212/6/2024 dated 26th June 2024, when a supplier issues a credit note to the recipient, the supplier must obtain a certificate from the recipient confirming that the recipient has reversed the corresponding ITC. If the tax amount of the credit note issued to a recipient exceeds Rs. 5 lakhs in a financial year, a certificate from a Chartered Accountant must be obtained from the recipient. In other cases, the supplier must obtain an undertaking or declaration from the recipient confirming the reversal of ITC as per the credit notes issued by the supplier.
9. Reversal of ITC in case of non-payment to vendors within 180 days
- The taxpayer shall revisit the trade payable and if the payment has not been made to the supplier within 180 days, ITC shall be reversed (the same is reclaimable on payment to supplier)
10. Reversal of ITC in case of exempted and taxable supplies
- In case of taxable as well as exempted supplies, the taxpayer shall perform the annual calculation for reversal of common ITC as per rule 42 of the CGST Rules, 2017 and effect of any excess reversal or short reversal shall be duly accounted for in GST returns for the month of March 2025.
11. File GST TDS Returns if applicable u/s 51 for Apr’24 to March’25.
12. Kindly make sure to claim refund of period Feb’23 onward (if any) before the due date of filing GSTR-3B for the month of Feb’25 (i.e. 20th March 2025). (Note: relevant date for calculating two years’ time-limit shall differ for different categories of refund)
13. Do check if your supplier is government organization and whether deducting TDS under GST and if yes do reconcile TDS deducted by them April 2024 till February 2025 with TDS reflected on your account and accepted and filed.
14. Do apply for LUT for F. Y. 2025-26 if you wish to do zero rated supplies without payment of tax.
15. Apply if you wish to opt for composition scheme for F. Y. 2025-26. Now, the same is live on GSTN portal.
16. Check status of Inputs Goods (1 year) / Capital Goods (3 years) sent to Job Worker for purpose of ITC reversal where the timelines have been exceeded
17. Check status of Goods sent on approval basis
18. Reconciliation of E-way bill data with GSTR-1 for FY 2024-25
19. Reconciliation of E-Invoice data with GSTR-1 / Books for FY 2024-25 and making sure that IRN is generated for every B2B Invoice/ B2B Credit Note/ B2B Debit Note/Export Invoice for the period applicable.
20. Applicability of E-Invoicing : Kindly take a note that E-invoice system for B2B transactions is made mandatory for businesses having Turnover above 5 Cr from 1st August 2023. (Prior to August 2023, the said threshold limit was 10 Crore). As per Rule 48(5) of the CGST Rules, any vendor who is eligible to issue E-invoices but issues normal tax invoices, then such normal invoices shall not be treated as Tax Invoices and the recipient will not be eligible to avail of Input Tax Credit. The recipient may also have to pay interest as well as a penalty if charged.
Hence, it is important to check the turnover of FY 24-25 for E-Invoice applicability. If turnover during FY 24-25 is above 5 Cr, E-Invoice is mandatory from April 25.
You may kindly refer our E-Invoice alert for details on this link
https://njjain.com/gst-alert-14-e-invoicing-for-fy-2023-24/
21. Incomes appearing in Form 26AS (where applicable) for the FY 2024-25 (Up to Dec’24) would also be now available and hence in case there is any income / TDS recognized in 26AS/Books of FY 2024-25 (Up to Dec’24), which has been missed to be reported in GSTR-1 / GSTR-3B, kindly ensure that the same is duly reported, to match with the Annual Accounts for the FY 2024-25.
22. Kindly verify Principal place of business & additional place of business as currently reflect on GSTN portal are correct OR any changes / amendment is required. In case there are any changes required, make sure that the relevant amendments done on the portal.
a. Further, may I draw your attention to Rule 18 of the CGST Rules 2017, which reads as under: –
“18. Display of registration certificate and Goods and Services Tax Identification Number on the name board-
- Every registered person shall display his certificate of registration in a prominent location at his principal place of business and at every additional place or places of business
- Every registered person shall display his Goods and Services Tax Identification Number on the name board exhibited at the entry of his principal place of business and at every additional place or places of business.”
b. Therefore, kindly ensure that GSTIN RC is properly display at all the registered place of business.
23. Please ensure to update the GST Portal if there are any changes to the Authorized Signatory, Director, or Partner details as applicable.
24. New Document series for issuance of tax invoices, credit notes, etc – If the taxpayer wish to change the document series, the same may be changed from April 25.
25. Updating details for Importer Exporter Code –
- IEC shall be updated electronically every year between 1 April 2025 to 30 June 2025. If no change, the same shall be confirmed online before the due date, otherwise IEC shall be de-activated.
Various decision making and compliances under GST are dependent upon Aggregate Turnover during the previous year such as GST registration, opting for composition scheme, QRMP Schemes, filing of ITC-04, applicability of E-Invoicing, QR Code for B2C Supply and Rule 86B etc. Therefore, please check the applicable points and stay compliant.