Major changes in GSTR 3B reporting and filing

Recent Changes in GSTR-3B Filing by CBIC

Form GSTR-3B is the return through which the Government collects tax from its taxpayers. The CBIC has notified a series of changes to its existing return filing mechanism in GSTR-3B.

1. New Table 3.1.1 for E-commerce Transactions

CBIC has introduced a new table 3.1.1, in which taxpayers will be required to provide details about supplies made through e-commerce operators (ECO), where such ECO pays tax on reverse charge basis.

2. Amendments to Table 4 – Part B & D

Part B and Part D of Table 4 have been amended:

• Part B: Deals with reversal of ITC

• Part D: Deals with reporting of ITC which does not affect ITC eligibility

The revised format of these sections is as follows:

(B) ITC reversed
(i) As per rules 38, 42 and 43 of CGST Rules and sub-section (5) of section 17
(ii) Others

(D) Other details
(i) ITC reclaimed which was reversed under Table 4(B)(2) in earlier tax period
(ii) Ineligible ITC under section 16(4) and ITC restricted due to PoS provisions

3. Direction to File Returns Correctly

CBIC has issued a circular directing taxpayers to file returns correctly and properly. Tables of Form GSTR-1 and Form GSTR-3B shall furnish correct and proper information of:

• Inter-state supplies

• Amount of ineligible/blocked ITC

• Reversal thereof

4. Guidelines as per CBIC Circular

a) Reporting Inter-state Supplies to Unregistered Persons
Shall be reported place of supply wise in:

• Table 3.2 of Form GSTR-3B

• Table 7B or Table 5 or Table 9/10 of Form GSTR-1

b) Reporting Inter-state Supplies to Composite Dealers
Shall be reported place of supply wise in:

• Table 3.2 of Form GSTR-3B

• Table 4A or Table 4C or Table 9 of Form GSTR-1

c) Customer Database and POS
Registered persons shall:

• Update customer database properly with correct state name

• Ensure that correct Place of Supply (POS) is declared in tax invoice and relevant returns

d) Reporting ITC as per GSTR-2B
Total ITC – eligible and ineligible – shall be reported in different fields of Table 4A of Form GSTR-3B

5. Reversal of ITC: Absolute vs Conditional

e) Absolute and Non-reclaimable ITC Reversals
Shall be reported in Table 4(B)(1) of Form GSTR-3B. Includes:

• Rule 38 (banking/financial institutions)

• Rule 42 (exempted goods/services – input & input services)

• Rule 43 (exempted goods/services – capital goods)

• Section 17(5) (ineligible/blocked ITC)

f) Conditional and Reclaimable ITC Reversals
Shall be reported in Table 4(B)(2) of Form GSTR-3B. Includes:

• Rule 37 (non-payment within 180 days)

• Section 16(2)(b) (non-receipt of goods/services in tax period)

• Section 16(2)(c) (tax not paid by supplier)

• Any inadvertent ITC reversal in previous tax periods

6. Reporting in Part D of Table 4

Taxpayer shall disclose details that do not affect ITC credited to the Electronic Credit Ledger. To be reported in Part D of Table 4 of Form GSTR-3B:

• ITC reclaimed which was reversed under Table 4(B)(2) in earlier tax periods

• Ineligible ITC under section 16(4) (time-barred claims – after 30th Sept of subsequent year)

• ITC restricted due to PoS provisions (recipient located in a different state/UT than the place of supply)

Recent GST Circulars and Notifications