Form GSTR-3B has been made the soul of the GST Act, 2017 vide Notification No.56/2017-Central Tax, dt. 15-11-2017 that seeks to mandate the furnishing of return in FORM GSTR-3B till March, 2018. So, it becomes very important to correctly file GSTR Form-3B.
Vide Circular No. 07/2017 dated 01-09-2017 the detailed procedure for reconciliation of information furnished in FORM GSTR-3 and FORM GSTR-3B was explained.
After the registered person has filed his return in FORM GSTR-3B and the statement of outward supplies in FORM GSTR-1, the inward supplies shall be auto drafted for all registered persons and made available to them in FORM GSTR-2A. Based on the details communicated in FORM GSTR-2A, the registered person shall prepare the statement of inward supplies in FORM GSTR-2.
If the registered person intends to amend any details furnished in FORM GSTR- 3B, it may be done in the FORM GSTR-1 or FORM GSTR-2.
After the registered person has furnished the statement of inward supplies in FORM GSTR-2 by the extended date, the common portal shall auto-draft Part-A of the return in FORM GSTR-3 for the said month based on the information furnished in FORM GSTR-1 and FORM GSTR-2. Based on the revised figures of output tax liability and eligible input tax credit, Table 12 of Part B of FORM GSTR-3 shall be made available. The common portal would populate the correct figures of tax payable in column (2) of Table 12 of FORM GSTR- 3, based on the information furnished in FORM GSTR-1 and FORM GSTR-2.
The tax paid through the electronic cash ledger and electronic credit ledger in the return in FORM GSTR- 3B shall be displayed by the system in column (3) to (7) of the Table 12 of Part B of FORM GSTR-3. Where there is no difference between the details of output tax liability and eligible input tax credit furnished in FORM GSTR-3B and the details furnished in FORM GSTR-1 and FORM GSTR-2, the amount of tax payable and tax paid shall be the same in FORM GSTR-3B and FORM GSTR-3. The person can sign and submit FORM GSTR-3 without any additional payment of tax.
Where the tax payable by a registered person as per FORM GSTR-3 is more than what has been paid as per FORM GSTR-3B, the common portal would show another instance of Table 12 for making additional payment of taxes which can be paid by debiting the electronic cash or credit ledger along with applicable interest on delayed payment of tax starting from 26th day of August, 2017 till the date of debit in the electronic cash or credit ledger.
If the eligible ITC claimed by the person in FORM GSTR-2 is less than the ITC claimed and utilised by the registered person in FORM GSTR-3B, the same would be added to his output tax liability and shall have to be paid by him along with interest by debiting the electronic cash or credit ledger the transitional credit as declared in FORM GST TRAN-1 is credited to the electronic credit ledger, the same can be utilised for the payment of the said additional tax liability. Where the eligible ITC claimed by the taxpayer in FORM GSTR-3B is less that the ITC eligible as per the details furnished in FORM GSTR-2, the additional amount of ITC shall be credited to the electronic credit ledger of the registered person when he submits the return in FORM GSTR-3.
Where the output tax liability of the registered person as per the details furnished in FORM GSTR-1 and FORM GSTR-2 is less than the output tax liability as per the details furnished in the FORM GSTR-3B and the same is not offset by a corresponding reduction in the input tax credit to which he is entitled, the excess shall be carried forward to the next month’s return to be offset against the output liability of the next month by the taxpayer when he signs and submits the return in FORM GSTR-3.
However, simultaneously, if there is a decrease in the eligible input tax credit, the same will be adjusted against the above mentioned reduction in output tax liability and the balance, if any, of the reduction in output tax liability shall be carried forward to the next month’s return to be offset against the output liability of the next month. But will not be liable to pay any late fee provided the requisite return in FORM GSTR-3B was submitted on or before the due date. The return shall be considered to be a valid return when the tax payable as per FORM GSTR-3 has been paid in full after which the return shall be taken up for matching.
For the very first month of GST Regime i.e. July 2017, only “SAVE GSTR3B” button and “Submit” button was available on the GST Portal where we could edit and “Save GSTR-3B” any number of times, but once we “SUBMIT”, the input details got freezed.
There was no way to revise GSTR-3B, once it has been submitted.
As many taxpayers as we as professionals faced hardships due to this freezing of the figures after clicking on the “Submit” button, Govt. consequently from August 2017. brought out with another option to “Preview and Submit GSTR 3B” to provide ease to the taxpayers wherein we can preview the data input by us and then “Confirm and Submit”.
So, in the nutshell we conclude that though till now there is not revision facility available for GSTR-3B and the only possible resolution to correct it is via GSTR-1 and GSTR-2 in case the figures got wrongly input by us while submitting the GSTR-3B. However, it is expected by GST Network to operationalize editing facility for GSTR-3B returns by 21st November.