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Compare Old vs New GST Return Filing System

New Filing System for filing Simplified Returns under GST has been the fiery topic since past few months. The government notified the launch of the new system for trial purpose to make the taxpayers on board with the same. However after many postpone, the new system for trial is finally going to set in motion from July 2019, whereas the ultimate implementation of the system will be from October 2019.

Key Points About New GST Return Filing System

Under the new filing system, An important and main return is proposed, known as GST RET 1 return form to represent all supplies made, ITC claimed, and all tax or interest paid. GST RET 1 will take place of the GSTR 3B and ANX 1 will take place of GSTR 1 return, both which are being filed under the current system.

This form consists of two Annexures, namely –Annexure of SuppliesandAnnexure of Inward Supplies. These annexures will be linked to the main return.

Annexure of Supplies (FORM GST ANX-1) will include details of :

  • Outward Supplies,
  • Inward Supplies Subject to Reverse Charge,
  • Import of Goods and Services.

Note: These details have to be reported invoice-wise on a real-time basis.(except B2C supplies).

Annexure of Inward Supplies (FORM GST ANX-2) will include the details of :

  • Inward Supplies

Note: Here the recipient can act on the auto-drafted documents which are uploaded by the supplier (as documents are available on a real-time basis).

  • The Form GST RET-1 will be filed on a monthly basis. However, the small taxpayers whose turnover of previous F.Y. is up to INR 5 crore, can file this return on a quarterly basis. But in this case as well they will need to pay the taxes on a monthly basis in FORM GST PMT-08.
  • The New Filing System demands supplier to upload invoices on a real-time basis which will enable recipients to take instant action. This will lead to a genuine claim of ITC.
  • In cases when a supplier fails to upload invoices or file his return, the recipient will be able to claim ITC on a provisional basis, which will not exceed the 20% of the value mentioned. The current system does not allow any provisional credit.

Timeline Comparison of New GST Filing System vs Old

For the Period from July to September 2019, small as well as large taxpayers will file Form GSTR-1, GSTR-3B under the current filing system. While under the new filing system, only Annexures will be available for upload and view on a trial basis for both types of taxpayers.

For the Period from October to December 2019, the small taxpayer will have to file the monthly return of GST PMT 08 and large taxpayers will have to file GSTR-3B for the month of October and November and monthly GST ANX – 1 as per the current system.

Under the new system, a small taxpayer will have to GST ANX-1 (quarterly), GST RET-01 (quarterly) and GST PMT-08 (monthly) and large taxpayers will have to file monthly GST ANX-1 and GST RET 01 form ( only from Dec’19 onwards)

GST Return: Compare Old vs New GST Return Filing System

The objective of the New Simplified GST Returns is to completely knock off the tax evasion pan India so that the transparency and equality can be attained under the indirect tax mechanism. Lets us check how a new system quick fixes the failings of the current systems :

Tax Payment: In the current system, Full Tax liability must be paid for a tax period while filing monthly return GSTR-3B. In the new system, complete Tax liability must be paid for a tax period in monthly PMT-08, regardless of monthly or quarterly filing of GST returns.

Number of Returns: Present System demands the filing of two returns while the new system demands the filing of just one return.

Reporting of Invoice Details in Returns: In the current filing system, invoice details can be reported while filing GSTR 1 form but can be viewed afterwards in GSTR-2A. In the new filing system, filing and viewing go simultaneously so that instant action can be taken on that.

The changeover period from the current filing system to the new filing mechanism is very important and worth taking care. C.A. professionals also need to give all their attention to the mutation resulting out of the launch of the new system even if is also under the prevailing GST Law.

Few Noteworthy Points:

  • The three months trial period for the new filing system will begin from July and will last till September 2019.
  • In the trial period, the filing of GSTR-1 and GSTR-3B can be continued.
  • After the trial period, from October to December, taxpayers whose total turnover exceeds INR 5 crores will need to adopt the new filing system and so start filing only GSTR-3B.
  • From January 2020, all taxpayers will have to file the new GST returns and annexures mandatorily.
  • The new filling completely snuffs out the Form GSTR-3B.