Presently, a registered person under GST shall have to file the different returns at different times which make it more complicated. Also, different returns were specified for different category of customers. For Example, a person who has taken a normal registration shall have to file GSTR-1, GSTR-3B, GSTR-9 and the person who has registered under composition scheme shall have to file GSTR-5. Due to this complication, it has been recommended in the 32nd GST Council Meeting, that the filing of returns should be easy and new forms have It has been decided to be issued from October 2019. However, the applicability of these returns has been extended until April 2020.
So, from April 2020, the main return would be required to be filed GST-RET-01. This forms shall contain the annexure ANX-01 and ANX-02. Although, there are other forms like Sahaj and sugar would also be applicable for the small taxpayer but the annexure shall be the same.
In this article, we will discuss the matters to be entered in these annexures.
GST-ANX-01:
In this annexure following details shall be entered:
- Details of Outward Supply
- Details of Inward supply under which the concept of Reverse charge Mechanism.
- Details of import of goods or services
- Zero Rated supplies without payment of GST
In this annexure, the supplier shall enter the invoice details and the recipient would approve it on a real-time basis.
For those suppliers which attract the reverse charge mechanism, the details of such invoices shall be reported by the only recipient.
Now, there is an option also available for reporting of amendment transactions.
If the supplier has taken an advance for the purpose of supply then such advance shall not be included in annexure GST ANX-01, but this would directly require to be reported in table 3C of GST RET-1.
This annexure is somehow different from GSTR-1. Let’s take an example, in case of RCM, Mr. A is providing the arbitral services to Mr. B. Currently, Mr. A (Advocate) would be required to report the amount of those services in form GSTR-1. However, from April 2020, those services shall be required to report only by the recipient which is Mr. B in our example.
The reporting can be done throughout the month except on the following dates:
Those persons who will be required to file Monthly Return: 18th To 20th of the Month
Those persons who will be required to file Quarterly Return: 23rd To 25th of the Month.
If there is any transaction could not be reported by the registered person or there was any amendment would require to be made then he may report those transactions earlier of the following time limit:
Due date of furnishing of next year September month return
Or
The actual date of filing of Annual Return
Such changes shall be reported by the supplier in form GST ANX-1A.
After reporting of details of supplies by the supplier, these would be confirmed by the recipient and he would have the option to lock such transaction. Here lock means, once the recipient has confirmed the transaction and lock it then it would not be possible for the supplier to make any changes in such transaction. This may be possible only if the recipient has unlocked it.
Those transactions which been rejected by the recipient shall be communicated to the supplier.
GST ANX-2
The details reported by the supplier in his GST ANX-1 would be automatically shown in the GST ANX-2 of the recipient on a real-time basis. The recipient shall be eligible for the credit only when such credit would be shown in his GST ANX-2. Once these shown in the recipient GST ANX-2, the recipient has the option to accept or reject such transaction. As we have already discussed above, the accepted transactions by the recipient would not be available to the supplier for any amendment unless the recipient has unlocked it.
If the recipient has taken the credit on certain supplies as per GST ANX-2 against which supplier has not shown its outward supplies in GST ANX-1, the government shall disallow such credit to the recipient and shall be added in the output liability of the recipient. Hence, if the supplier has not filed his return then the recipient shall not be able to take the credit. This system makes it compulsory for both parties to file their returns.
The time period for the supplier to enter the details of invoices is the 10th of Next month in which he has made the supply. However, If he has reported certain transactions after the end of such a period, then the recipient shall be able to look such invoices but he would not be able to take the credit for such month.