New GST return transition plan: Here’s everything you must know

The GST Council in its 31st meeting decided that a new GST return system will be introduced to facilitate taxpayers. In order to ease the transition to the new return system, a transition plan has been worked out. It may be noted that there are three main components to the new return – one main return (FORM GST RET-1) and two annexures (FORM GST ANX-1 and FORM GST ANX-2).

For those who are not aware, in May this year, a prototype of the offline tool has already been shared on the common portal to give the look and feel of the tool to the users. The look and feel of the offline tool would be the same as that of the online portal.

Here are the details of the indicative transition plan

1. From July 2019, users would be able to upload invoices using the FORM GST ANX-1 offline tool on trial basis for familiarisation. Users will also be able to view and download, the inward supply of invoices using the FORM GST ANX-2 offline tool under the trial program. The summary of inward supply invoices will also be available for view on the common portal online. They will be able to import their purchase register in the offline tool and match it with the downloaded inward supply invoices to find mismatches from August 2019.

2. Between July to September 2019 (for three months), the new return system (ANX-1 & ANX-2 only) will be available for trial for taxpayers to make themselves familiar. This trial will have no impact at the back end on the tax liability or input tax credit of the taxpayer. In this period, taxpayers shall continue to fulfil their compliances by filing FORM GSTR-1 and FORM GSTR-3B i.e. taxpayers will continue to file their outward supply details in FORM GSTR-1 on a monthly/quarterly basis and return in FORM GSTR-3B on monthly basis. Non-filing of these returns will attract penal provisions under the GST Act.

3. From October 2019 onwards, FORM GST ANX-1 will be made compulsory and FORM GSTR-1 will be replaced by FORM GST ANX-1. The large taxpayers (i.e. those taxpayers whose aggregate annual turnover in the previous financial year was more than Rs. 5 Crore) will upload their monthly FORM GST ANX-1 from October 2019 onwards. However, the first compulsory quarterly FORM GST ANX-1 to be uploaded by small taxpayers (with an aggregate annual turnover in the previous financial year up to Rs 5 crore) will be due only in January 2020, for the quarter October to December 2019. 

It is to be noted that invoices etc. can be uploaded in FORM GST ANX-1 on a continuous basis both by large and small taxpayers from October 2019, onwards. FORM GST ANX-2 may be viewed simultaneously during this period but no action shall be allowed on such FORM GST ANX-2.

4. For October and November 2019, large taxpayers will continue to file FORM GSTR-3B on monthly basis. They will file their first FORM GST RET-01 for the month of December 2019 by January 20, 2020. The small taxpayers will stop filing FORM GSTR-3B and will start filing FORM GST PMT-08 from October 2019, onwards. They will file their first FORM GST-RET-01 for the quarter of October 2019 to December 2019, from January 20, 2020.

5. From January 2020 onwards, all taxpayers will be filing FORM GST RET-01 and FORM GSTR-3B will be completely phased out.

As per the official statement, separate instructions will be issued for filing and processing of refund applications between October to December 2019.

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