Normal Vs Composition Scheme under GST

While conceptualizing concept of GST, a 3600 view of business and economy was considered specially the nature of business and requirements of almost five crore Micro, Small and Medium Enterprises (MSMEs) and small traders who account for 25% of employment, 40% of industrial output and 45% of exports of the country.To boosting the cost competitiveness of MSMEs and small traders and for simple compliance, Composition scheme a simple and easy scheme was introduced. The scheme helps small taxpayers get rid of complex GST formalities and pay GST at a fixed rate of turnover.Getting registered under composition scheme is optional and voluntary. As per Sec 10. (1) of CGST, a Registered Person, whose aggregate turnover in the preceding financial year did not exceed Seventy Five Lakh Rupees, (Vide notification No. 8/2017-Central Tax, dated 27.6.2017, the limit of Rs. 50 lakhs has been raised to Rs. 75 lakhs for all states except for taxable person in the north eastern states and Himachal Pradesh) may opt to pay, in lieu of the tax, a levy at a fixed rate of turnover. Though the scheme is very beneficial for small tax payers, not may are enthused to opt for the same because of some restrictive provisions.Let us discuss in this article comparison between Normal Scheme and Composition Scheme.Registration:In the normal case registration is required once threshold limit of Rs 20 L (Rs 10 L in case of Special Category States) crosses as per Sec 22 of CGST Act. However under composition scheme the limit of Rs. 75 lakhs has been fixed vide notification No. 8/2017- Central Tax, dated 27.6.2017, whereas for the states of Assam, Arunachal Pradesh, Manipur, Meghalaya, Mizoram, Nagaland, Tripura, Sikkim and Himachal Pradesh, the limit is restricted to Rs. 50 lakhs. But on any given day, if turnover crosses the above-mentioned limit, then it becomes ineligible under composition scheme and has to fall under the regular scheme.Easy Compliance:Under the normal scenario, a taxpayer under GST has to file minimum 3 returns monthly and one annual return, totaling 37 returns per annum. Whereas under composition scheme only 5 returns to be filed per year. (Return to be filed on Quarterly basis in Format GSTR-4 by 18th day after the end of each quarter [by 18th April, 18th July, 18th Oct., and 18th January- Section 39 (2) of CGST Act, 2017 and Rule 62 of CGST Rules. Annual Return to be filed in Format GSTR-9A – Section 44(1) of the CGST Act, 2017 and Rule 80 of GST Return Rules).This is a greatest relief to the small tax payers and reduces their compliance related complexities and cost. Comparative Cost Advantage:Let us now discuss comparative cost advantages of both the schemes. For simplicity of comparison let us take two scenarios as below but operating under similar assumptions of receipts, tax rates and value addition.Supplier is Registered under Composition Scheme and supplying to registered business (B2B) and to the consumer (B2C).Supplier is Registered under Normal Scheme and supplying to registered business (B2B) and to the consumer (B2C).The calculations are shown below separately. From the calculations it is very clear that composition scheme is beneficial when supplying to final consumer (B2C) (Cost Value is Rs 171.36 compared to Rs 177 in case of Normal registered supplier). Where as in case of supplying to another business (B2B) it is not advantageous (Cost Value is Rs 171.36 verses Rs 150).Finally we may conclude thatFor B2B transactions, Composition Scheme is not AdvisableHowever in case of B2C, it is advantageousLimitations of Composition SchemeUnder Composition Scheme, GST should not be collected on outward supply and supplied against Bill of Supply instead of Tax Invoice. Since the outward supply is not taxed, input tax credit is not allowed. That is Composition dealers are not allowed to collect tax from the recipient of supplies, and are not allowed to take Input Tax Credit.However there is no restrictions on inward supplies. The person registered under the scheme is allowed to get inputs from intra-state or inter-state or import source.The other restrictions areAny taxable person is not eligible for composition levy if he is,-Engaged in supplies of services other than supply of goods, being food or any other article of human consumption or any drink (other than alcoholic liquor) { Ref: Clause (b) of Paragraph 6 of Schedule II of CGST Act, 2017 read with Section 10(2)(a) of the CGST Act,2017);Making supply of goods not leviable to GST(Ref: Section 10(2)(b) of the CGST Act,2017);Making inter-state supplies of goods(Ref: Section 10(2)(c) of the CGST Act,2017);Making supplies through electronic commerce operator (Ref: Section 10(2)(d) of the CGST Act,2017).Being manufacturer of any notified goods (as may be notified by Government by issuing notification) (Ref: Section 10(2)(e) of the CGST Act,2017)Vide notification No. 8/2017-Central Tax, dated 27.6.2017, the Central Government has notified manufacturer of ice-cream, pan masala and tobacco & manufactured tobacco substitute from availing composition levy scheme].The taxable person should neither be a casual taxable person nor a non-resident taxable person; (Ref: Rule 5(1)(a) of the CGST Rules, 2017)Composition scheme is levied for all business verticals with the same PAN. A taxable person will not have the option to select composition scheme for one, opt to pay taxes for other.Despite having advantage in case of B2C type of transactions, the scheme is not gaining popularity because of some of restrictive provisions.At a Glance Comparison of Normal & Composition Scheme

Matching & Reconciliation under GST – Importance & Procedure

GST Reconciliation and Matching are not new to any taxpayer. This has been prevalent in earlier VAT and excise regime too. Then, the matching of data between the books of accounts and tax returns was an easy task for many business organisations. If the tax department on processing returns found some discrepancy, communications would be sent to the taxpayer and accordingly further scrutiny and audits would be carried out by the authorities.

But under GST, this process has gained significance as the sanity of the Input tax credit utilised by businesses is monitored by the GST authorities regularly. Also, the taxpayers must on regular basis reconcile their data every month with the data declared by its vendors too. The return filing and processing are semantically automated and the GST returns are inter-linked.

1. What is Matching & Reconciliation under GST?

Following Mismatches can be noticed by taking up following Matching and Reconciliation exercises:

• Differences between the amount of credit shown in GSTR- 3B and the GSTR 2A or/and
• Discrepancies between GSTR-3B and GSTR-1 or/and
• Differences in the provisional credit claimed and actual credit that is claimable. This situation arises usually during transition stages.

Any differences noticed between these returns will lead to scrutiny notices being issued to the taxpayers.

There can be several causes for mismatches. Popular ones are:

1. The vendor has declared liability but credit is not availed in GST returns: Such credits should be availed at the earlier of due date of September returns or Annual returns.
2. The vendor has not declared liability on supplies made but businesses have availed credit on such procurements in the GST returns: Businesses should follow up with the vendor to ensure that the liability is declared. Else, risks of such credits being disallowed may arise.
3. Mismatch between liability declared by the vendor and credit availed: The reasons for differences should be identified and reconciled appropriately (e.g. by issuing debit notes/credit notes etc) before 30 September, 2018.
4. Mistakes in the details furnished: There can be mismatch in the fields such as GSTIN of the supplier/recipient, number and date of the invoice/debit note etc. Make amendments in the GST returns of the month following the relevant month when mistakes were committed.

Reconciliation under GST although seems to be a simple process due to automation but still consumes lot of time and resources, as taxpayers are required to continuously communicate with vendors for making amendments in the returns filed by them or even to track. It would not tasking for businesses having a handful of transactions to monitor. However, in case you have thousands of invoices in a month, then even a single digit percentile will be a significant volume. Therefore, one must reconcile the returns data on regular basis under GST.

2. Why is GST Reconciliation required?

There are several reasons why reconciliation for GST returns data is required by businesses under GST.

1. As per the new proposed model of GST returns by GSTN, taxpayers will be able to claim ITC only if the invoice is present as a part of their 2A data or vendor data. Owing to this, taxpayers will now need to do a reconciliation wherever the ITC as per their purchase register and 2A data is not matching.

2. GST returns are filed monthly or quarterly basis. Finally, after the financial year gets over, annual returns must be filed before the 31st December of subsequent FY. This would need consolidation of the data reported over the FY. In order to ensure the correctness of the declaration made and to avoid duplications, taxpayer must reconcile the data, then consolidate the values and make the declaration.

3. Certain deadlines are stipulated in the GST laws for making amendments to GST returns data or to claim ITC. As per CGST Act, following actions must be taken at the earlier of due date of the September ,2018 GST returns or Annual returns:

• Claim eligible ITC against any invoice raised in FY 2017-18.
• Any apportionment of ITC belonging to FY 2017-18, as eligible and ineligible not made earlier must be affected before the deadline.
• Declare CDNs issued against any Invoices raised in FY 2017-18.
• File Amendments to information reported in the GST Returns filed between July 2017 to March 2018.
• Taxpayers who opted into Composition scheme or the vice versa current year 2018-19, may make amendments to the information reported in the GST returns filed in FY 2017-18 prior to conversion.

3. How to do GST Reconciliation?

To start with, Reconciliation must be done within the GSTIN and then must be taken to the PAN level. Reconciliation must be done across months for the entire FY 2017-18. Not just that, but the amendments made to GST returns of FY 2017-18 in the CY 2018-19 must also be considered.

Input tax credit (ITC) is the most important component of your GST returns as it holds greater relevance when compared to any other component of the GST returns. The stage at which the sanctity of claims were checked in the previous tax regime is no longer the same as the current GST regime. The genuineness can be confirmed by a taxpayer now at a stage of filing GST returns( vis-vis with GSTR-2A & take action). Earlier, tax authorities usually carry out this check while processing the returns.

Hence, the vendor-wise reconciliation must be done on a regular basis. If not done, taxpayer must consider doing it before filing September 2018 GST returns. This will help identify and declare any unclaimed ITC within the deadline.

• Reconcile transitional ITC
• Claim ITC belonging to FY 2017-18, if not claimed earlier or reverse the ineligible ITC, if not identified and done earlier.
• Match Table of exports at 6A of GSTR-1 vis-a-vis Corresponding declaration in GSTR-3B
• Matching Table of exports at 6A of GSTR-1 vis-a-vis details of shipping bills submitted on ICEGATE
• Comparison between Annual Income Tax Return with Annual GST return

Declaration of Turnover from Business(at PAN level)

• Comparing Purchase register vis-a-vis GSTR-2A for the entire year 2017-18
• Compare GSTR-1 vis-a-vis GSTR-3B
• To Compare the ITC in GSTR-3B vis-a-vis GSTR 2A  for the entire year 2017-18

4. What are the major issues with Reconciliation?

The primary concerns of the taxpayer revolve around the following:

Am I:

• Being Tax compliant in accordance with GST and it’s claiming of ITC?
• At fault anywhere and hence the possibility of getting notices later?
• Missing out on possible working capital by claiming lesser than what I should be claiming?
• Who are the suppliers from whom I am getting the most amount of pain reconciling and how to make it easier for them and for myself?

The major issues with the Reconciliation under GST between GST returns are:

• The invoice number that the purchaser has recorded does not match with seller’s invoice received in 2A. Both follow a different convention.
• The purchaser may work in multiple states, and the seller has raised invoice with another GSTIN/HQ GSTIN instead of the actual purchaser GSTIN. In this case it might not reflect completely at a GSTIN level.
• The invoice date by purchaser doesn’t match with seller. Difference because of date of recording the invoices is different at both places. Mostly purchaser at fault here as they should’ve entered the same date as in Sales invoice.
• The purchaser and supplier have recorded invoices in different return periods.
• Invoice value from Supplier and Purchaser differs by a minor value because both parties have different conventions of rounding off.
• The invoice value differs at supplier and purchaser’s end in case a CN/DN is issued and it fails to match in a recon row.
• When invoice number and date do not match while only the invoice value matches between two parties.
• There are multiple invoices between a purchaser and supplier where every invoice is of same value at different dates and one of the parties has recorded invoices higher than the other. This happens in case of regular fixed supply business.

One of major challenges in doing a reconciliation is that both parties involved may have different nomenclature of storing the invoice numbers, while the implementation has a hard match around invoice number.

5. How to choose a tool or software to reconcile faster and ensure 100% compliance?

A technological solution which can solve for all of the major pain points discussed above. This will add a lot of value to the business owner.

Certain features that one must find in a powerful reconciliation tool or system for matching and reconciling GST returns data are:

• The tool should be able to handle a massive amount of data.
• It should make it easy for the business owner to get data into the system for reconciliation and also take it back to his ERP post- GST reconciliation. A seamless integration here would help. It should be able to get the data into the reconciliation system from any kind of source – ERP, Excel, bill books, etc.,
• It should be able to provide deep reporting and insights which can help answer the pain points above.
• Overall, it should also make the whole process month over month seamless and largely efficient that the business owner does not feel a burden.
• It should allow for easy data sharing and collaboration between the business owner and his accountant(s).
• Given the Government GST rules might keep changing over time, the system should have the ability to evolve fast and in-line with Govt. changes. This will abstract the real problem away from the business owner and make it still seamless for them.
• It must be extremely intelligent to handle any case of missing/wrong information. It can be wrong dates, wrong invoice numbers, missing items, wrong tax rate, wrong sale value and a lot more. The system should be able to provide the most effective reconciliation in all such scenarios.
• The system should be real-time and proactive. A seamless integration to bring the invoice for reconciliation and real-time automatic application of pre-defined rules will help.
• Proactive reminders and automatics to reduce human intervention will also make the system more efficient.

ClearTax GST offers the most powerful and Advanced Reconciliation Tool that comes packed with all the above discussed features and intelligence to auto-identify, match entries and assures 100% ITC claimed. Some of its tools are:

• GSTR-3B vs GSTR-1 Tax Comparison Report

Compares GSTR-3B and GSTR-1. Gives a graphical representation as well. This enables clients to understand the difference in the tax liability which helps clients avoiding penalty or Notice from GSTN

• GSTR-3B vs GSTR-2A ITC Comparison Report :

Compares GSTR-3B and GSTR-2A. Gives a graphical representation as well. If ITC is claimed in excess, this can be identified here for each month. Thus ensuring that the clients are prepared for any notice that comes their way

• Monthly Tax and ITC summary Report :

Month on Month view for the top management on the tax paid and ITC taken by each of the GSTINs.

• Advanced Reconciliation Tool :

1. Download multi-month GSTR-2A in a click – Enabling all clients to start reconciliation of their 2A and purchases by pulling complete financial year’s 2A report.
2. Intelligent and Smart Rules – ClearTax Recon uses intelligent and smart rules for you to get suggestions on what could be reconciled without taking much effort in looking for. Helps you do recon faster and easier.
3. Claim Max ITC – Use ClearTax to claim 100% ITC.
4. Four buckets in ClearTax GST to identify data match, mismatch type :

• Matched

Shows in this section when purchase invoices uploaded by you and GSTR-2A data downloaded from the GSTN portal matches based on default and suggestions from ClearTax

• Mismatch In Values

Shows in this section when purchase invoices uploaded by you and GSTR-2A data downloaded from the GSTN portal doesn’t match which is highlighted in red on the software

• Missing In My Data

Shows in this section when you have not uploaded purchase invoices but data is present on 2A side

• Missing In Supplier Data (Not In 2A) My Data

Shows in this section when you have uploaded purchase invoices but data is not present on 2A side

GST

1. What is GST Return?

A return is a document containing details of income which a taxpayer is required to file with the tax administrative authorities. This is used by tax authorities to calculate tax liability.

Under GST, a registered dealer has to file GST returns that include:

• Purchases
• Sales
• Output GST (On sales)
• Input tax credit (GST paid on purchases)

To file GST returns, GST compliant sales and purchase invoices are required. You can generate GST compliant invoices for free on ClearTax BillBook.

2. Who should file GST Returns?

In the GST regime, any regular business has to file two monthly returns and one annual return. This amounts to 26 returns in a year.

The beauty of the system is that one has to manually enter details of one monthly return – GSTR-1. The other return GSTR 3B will get auto-populated by deriving information from GSTR-1 filed by you and your vendors.

There are separate returns required to be filed by special cases such as composition dealers.

3. What are the types of GST Returns?

Here is a list of all the returns to be filed as prescribed under the GST Law along with the due dates.

3.1. Any regular business:

As per the CGST Act ( Note : subject to change by Notifications /orders)

Return Form	Particulars	Interval	Due Date
GSTR-1	Details of outward supplies of taxable goods and/or services affected from July 2018 to March 2019 ( Taxpayers whose turnover is more than Rs. 1.5 Crores in previous year)	Monthly*	11th of the next month**
GSTR-2	Details of inward supplies of taxable goods and/or services effected claiming input tax credit.	Monthly*	15th of the next month (Suspended now )
GSTR-3	Monthly return on the basis of finalization of details of outward supplies and inward supplies along with the payment of amount of tax.	Monthly*	20th of the next month
GSTR-9	Annual Return	Annually	31st December of next financial year
GSTR-3B	Return for the months of up to March 2019	Monthly	20th of the next month

** Details of outward supplies of taxable goods and/or services affected till June 2018 will be 10th of the next month.

** Taxpayers whose turnover was less than Rs. 1.5 Crores in the previous financial year has the option to file a quarterly GSTR-1 by end of the next month affected July 2018 to March 2019.

3.2. A dealer opting for composition scheme :

A composition dealer will enjoy the benefits of lesser returns & compliance along with payment of taxes at nominal rates. A composition dealer will file only 2 returns:

Return Form	Particulars	Interval	Due Date
GSTR-4	Return for compounding taxable person	Quarterly	18th of the month succeeding quarter**
GSTR-9A	Annual Return	Monthly	31st December of next financial year

3.3. Returns to be filed by certain specific registered dealers:

Return Form	Particulars	Interval	Due Date
GSTR-5	Return for Non-Resident foreign taxable person	Monthly	20th of the next month***
GSTR-5A	Return for Non-resident persons providing OIDAR services	Monthly	20th of the next month***
GSTR-6	Return for Input Service Distributor	Monthly	13th of the next month***
GSTR-7	Return for authorities deducting tax at source.	Monthly	10th of the next month
GSTR-8	Details of supplies effected through e-commerce operator and the amount of tax collected	Monthly	10th of the next month
GSTR-10	Final Return	Once. When registration is cancelled or surrendered	Within three months of the date of cancellation or date of cancellation order, whichever is later.
GSTR-11	Details of inward supplies to be furnished by a person having UIN and claiming refund	Monthly	28th of the month following the month for which statement is filed

Here is a video to understand who should file GST Return and why should it be filed –

Here is a video to understand who should file GST Return and why should it be filed – 

4.Due Dates to file GST Returns

Due Dates for filing GST Returns can be extended by issuing Orders or Notifications. Here, we have got for you the list of upcoming GST returns due dates that you must not miss!

GSTR-1

For turnover upto Rs 1.5 cr and who opted Quarterly filing

Period	Due dates
Jan- Mar	30th April 2018
Apr-June 2018	31st July 2018
July-Sept 2018	31st Oct 2018

For turnover of more than Rs 1.5 cr/ For turnover of less than 1.5 cr but opted Monthly filing

Period	Dates
April 2018	31st May 2018
May 2018	10th June 2018
June 2018	10th July 2018
July 2018	10th Aug 2018
Aug 2018	10th Sept 2018
Sept 2018	10th Oct 2018

GSTR-2 and GSTR-3

GSTR-2 and GSTR-3 filing has been suspended.  Know more about what was discussed on Return filing at 27th GST Council Meeting!

GSTR-3B

• GSTR-3B has been extended to March 2019.
• All businesses have to file GSTR-3B by 20th of next month until March 2019.

Due date for the month September 2018 is 20th October 2018.

GSTR-4

Due date  for the quarter July 2018 to September 2018 is 18th October 2018

GSTR-5

Due date for September 2018 is 20th October 2018

GSTR-5A

Due date for September 2018 is 20th October 2018

GSTR-6

Due date of GSTR-6 for the months from July 2017 to August 2018 is extended to 30th September 2018.

5. Late Fees for not Filing Return on Time

If GST Returns are not filed within time, you will be liable to pay interest and a late fee.

Interest is 18% per annum. It has to be calculated by the taxpayer on the amount of outstanding tax to be paid. The time period will be from the next day of filing to the date of payment.

Late fee is Rs. 100 per day per Act. So it is 100 under CGST & 100 under SGST. Total will be Rs. 200/day. Maximum is Rs. 5,000. There is no late fee on IGST.

Update as on 7th March 2018!

• CBEC withdraws the reduction in Late fees for only GSTR-5A charged for delay in return filing with effect from 7th March 2018.

This means that the late fees to be paid by taxpayers for late-filing of GSTR-5A now stands at a total of Rs. 200 per day of delay (Rs. 100 per day of delay for NIL return) subject to the maximum cap in the late fees at Rs. 5,000

As on 7th March 2018, the reduced late fees for other returns such as GSTR-1, GSTR-3B(October 2017 onwards), GSTR-4, GSTR-5 &  GSTR-6 continue to apply.

There are prescribed formats for each of the above of the returns. The forms may seem complex and difficult to understand. Do not worry, you can file your returns very easily usingClearTax GST Software. 

Sign-up now and try it yourself.

ALL ARTICLES

1. Quick comparison of GSTR-9 & GSTR-9C
   Although GSTR-9 and GSTR-9C sounds similar there are huge differences between the two. Read to know more as we compare the two forms.
2. Everything you need to know about GSTR 4A
   GSTR 4A is a record of all invoices received by the composition dealers from the suppliers in a particular tax period. Read to know more about Form GSTR-4A.
3. GST Sahaj Return
   The GST council announced the new GST quarterly returns for small taxpayers known as Sahaj & Sugam. Read to know about Sahaj form in detail.
4. GST Sugam Return
   The GST council introduced new quarterly returns called Sahaj & Sugam in 27th GST council meeting. Let us know the GST Sugam returns in detail.
5. Guide to Download GSTR 2A in Excel
   GSTR 2A for reconciliation can be downloaded from the GST portal in JSON and excel format. Know the steps to download GSTR 2A in excel format.
6. GSTR 9C : Reconciliation Statement & Certification- Filing, Format & Rules
   GSTR-9C is to be filed where the taxpayer is subject to GST Audit for FY. Get to know about this reconciliation statement, certification & filing process
7. GSTR-9A – Overview, Due Dates & Format
   GSTR-9A forms are released and must be filed by Composition dealers by 31st December 2018. Know the rules and compliance around this.
8. Guide To File GSTR-5A on GST Portal
   GSTR-5A must be filed monthly by 20th of next month by OIDAR service provider. Here are steps to be followed to file this GST returns on the Government portal.
9. GUIDE TO FILE GSTR-5 ON GST PORTAL
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10. Information return under GST
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11. GSTR 5A GST For Non-Resident OIDAR Service Providers
    Filing GSTR 5A is mandatory for the non-resident OIDAR service providers even if there is no business activity within 20th day of the succeeding month
12. Checksum Validation Failed Error in GST Return
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13. Amendments of Details in GSTR 1 and Error Messages
    Amendments can be made in each invoice and details at summary level also. Both type of amendments have there own limitations. Read this article to know more
14. GSTR-06 : Guide to File on GST Portal
    Learn to file GSTR-06 on the GST Portal. GSTR-06 is a monthly return to be filed by Input Service Distributor. Important return for distribution of credit.
15. Table 6A of GSTR-1 : Refund on Export
    A dealer who wants to claim refund on export has to file the Table 6A of GSTR-1. Here is a guide on how to do file the Table 6A of GSTR-1 on GST portal
16. Details to be mentioned in GSTR-4 Return
    GSTR-4 is a quarterly return to be filed by Composition dealers. This article contains in detail each section and the details to be provided in it.
17. Is it Possible to Revise GSTR-3B ?
    not possible to revise GSTR-3B once filed. But Government has now allowed to ‘Reset GSTR 3B’ after submission but before filing the return.
18. Details to be Mentioned in GSTR-1 Return
    GSTR 1 is a monthly or quarterly return to be filed by a regular taxpayer. This article is a detailed analysis of GST Form GSTR-1.
19. Guide to File GSTR-3B using Tally
    All regular taxpayers have to file GSTR-3B every month. Here is a step-by-step guide for Tally users to generate the report and enter values in GST Portal.
20. Guide to File GSTR-3B on GST Portal
    GSTR-3B is a monthly return required to be filed by all regular taxpayers till March 2019. Here is a step-by-step guide to filing your return on GST Portal.
21. Guide on filing GSTR-4 on GST Portal
    A step-by-step guide on filing GSTR-4 on GST Portal to help composition dealers in easy GST return filing.
22. GSTR-2A: Convert JSON to Excel Format
    A dealer has to convert GSTR-2A JSON to Excel. This conversion is required for matching and reconciliation, an important step in GSTR 2 return filing.
23. Guide on GSTR-2 Filing on GST Portal
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