Wednesday, September 9, 2020

Important Compliance Before 30th Sep 2020

1. GST Rectifications for FY 2019-20

a) Reconcile and match all your sales for FY 2019-20 with sales reported in GSTR-3B and GSTR-1 for the year. In case of any errors, the GST Return for September 2020 is the last opportunity to pass rectification entries relating to the previous year in the returns as amendment.

b) Reconcile GSTR-2A with Input Credit Register on the basis of which ITC has been claimed in each month's GSTR-3B for FY 2019-20. Bifurcate differences into ITC reflecting in GSTR-2A but not availed, and ITC availed but not reflecting in GSTR-2A. Entries in the former category may be availed (if eligible) in the GSTR-3B of August/September. Errors falling in the latter category may require follow up with the vendor to show it in their GSTR-1 correctly to your credit, or reversal with interest liability @ 24% p.a., as the case may be.

c) GST Debit Notes or GST Credit Notes relating to your supplies for FY 2019-20 may be issued latest up to 30th September 2020.

d) Any ITC apportioned between exempt supplies and taxable supplies on provisional basis monthly, has to be finalized annually latest by the period of September.

e) Check if all expenses/purchases (being input goods or services) on which ITC has been availed, have been paid within 180 days. If not, the ITC on them may have to be reversed with interest payment. In case there is no reason to withhold such amounts as due on 31.03.2020, pay them off to avoid such reversals.

e) Such changes are allowed up to the due date of filing GST returns for September only. In case September GSTR-3B or GSTR-1 are delayed, such changes may not be allowed.

2. GSTR-9 & GSTR-9C for FY 2018-19

a) GSTR-9C (Reconciliation Statement; also called GST Audit) is due to be filed by 30th Sep for every registered person having aggregate turnover as per GST of Rs. 5 crore or more for FY 2018-19.

b) GSTR-9 (Annual Return) for FY 2018-19 for all other registered persons with turnover less than Rs. 5 crore to be filed by 30th Sep.

3. E-Invoicing

a) With effect from 1st October, e-invoicing under GST is mandatory for every person having a aggregate turnover above Rs. 500 crores. Thus, you may want to have your accounting and invoicing software updated through Tally or ERP provider with API integration, so that you can generate them from within your accounting software itself.

b) Such e-invoicing is not applicable to entities in SEZ, NBFCs, banks, insurance companies, financial institutions, goods transport agencies, passenger transport service providers, etc.

4. Preparation for TCS on Sale of Goods

a) In case your turnover for last financial year from domestic sale of goods was over Rs. 10 crore, you must now prepare to collect TCS @0.1% from each customer to whom you make sales of over Rs. 50 lakhs in a year.

b) Such amount will become payable within 7 days from the month in which the amount will be received for such sales after 1st October.

You can read more about these provisions here.

5. Vendor Classification of MSME

a) Obtain vendor MSME classification into Micro, Small or Medium in your accounts database as per the new definitions of MSME.

b) Amounts outstanding to MSME vendors beyond 45 days as on 30th Sep will be due to be reported with reason for such delay in the Form MSME-1.

6. DIR-3 KYC

a) This is an annual compliance by which the Directors in a company need to confirm their phone number and email ID through generation of an OTP on the MCA website in a web based KYC form.

b) In case there is any change in PAN, Adhaar, phone, email, address of any Director, the e-Form DIR-3 KYC will have to be filed.

c) Delay will be charged with late fee of Rs. 5000.

7. Form DPT-3

a) Return of Deposits as on 31st March 2020 as filed in Form DPT-3 to MCA is due by 30th Sep.

b) For more information on this form, refer here.

8. All Pending MCA Forms

a) The Companies Fresh Start Scheme and LLP Settlement Scheme are expiring on 30th September.

b) All pending forms for companies and LLPs which have not been filed so far can be filed without ant late fee.

9. Advance Tax Deposit

The second installment for Advance Tax for AY 2021-22 (FY 2020-21) is due by 15th Sep. At least 45% of the estimated tax liability for the year must be paid by such date to avoid interest.

10. Delayed ITR Filing for AY 2019-20 (FY 2018-19)

ITR for AY 2019-20, if not yet filed, can be filed latest up to 30th September.

The due date for ITR of AY 2020-21 (FY 2019-20) is 30th November.

11. E-Verification of ITRs

If any of your ITRs are pending e-verification from AY 2015-16, this is the last opportunity to either validate them using Adhaar based OTP, bank account linked EVC or by sending a signed copy to CPC Bangalore at the earliest.