17 September 2018
GST Update: Notification of GST Audit Form, TDS and TCS provisions notified, Extension of Due Dates and Waiver of Late Fees

GST Audit Form Notified
The government vide Notification No. 49/2018-Central Tax dated 13 September 2018 has notified the reconciliation statement to be certified by the auditor, whereby, the taxpayer is required to provide a reconciliation between the audited financial statements and the annual return i.e. GSTR-9. Key items in respect of which reconciliation is to be provided are:
  • Gross turnover;
  • Taxable turnover;
  • Tax paid and rate wise liability;
  • Net input tax credit.
The relevant notification can be accessed here.

TDS Provisions Notified
The government vide Notification No. 50/2018-Central Tax dated 13 September 2018 has notified 1 October 2018 as the date for bringing into force provisions requiring government departments, local authorities etc. to deduct tax at source at the rate of 2% from payment made or credited to the supplier of taxable goods or services under a contract exceeding INR 0.25 million. The government has also notified the list of certain additional entities which would have to comply with the TDS provisions including:
  • Public sector undertakings;
  • Society established by the Central Government or the State government or a local authority under the Societies Registration Act, 1860 etc.
TCS Provisions Notified
The government 
vide Notification No. 51/2018-Central Tax dated 13 September 2018 has notified 1 October 2018 as the date for bringing into force provisions requiring e-commerce operators to collect tax at source on supplies made through it by other suppliers at the rate not exceeding 2%.
Extension of Due Dates of the GST Returns
The government has issued notifications to extend the due dates of certain GST returns, which have been summarized below:
Notification Return Period Revised due date
43/2018 - Central Tax dated 10 September 2018 GSTR 1 (Quarterly) - Taxpayers having an aggregate turnover of up to INR 15 million All quarters from July 2017 to September 2018 31 October 2018
October 2018 to December 2018 31 January 2019
January 2019 to March 2019 30 April 2019
44/2018 - Central Tax dated 10 September 2018 GSTR 1 (monthly) - Taxpayers having an aggregate turnover of more than INR 15 million All months from July 2017 to September 2018 31 October 2018
All months from October 2018 to March 2019 11th of the succeeding month
48/2018 - Central Tax dated 10 September 2018 GST TRAN 1 - Carry forward of CENVAT credit - 31 March 2019
GST TRAN 2 - Carry forward of CENVAT credit by a person not having duty paid document (and who are filing GST TRAN 1 as per the revised due date) July 2017 to December 2017 (monthly) 30 April 2019
Waiver of Late Fees
The government, vide Notification No. 41/2018-Central Tax dated 4 September 2018, has waived late fees that are paid by certain taxpayers under the following special circumstances:
Return Issues faced by the taxpayers
GSTR- 3B Return for the month of October 2017 was submitted but not filed on the common portal, after generation of the application reference number.
GSTR-4 Return for the period October 2017 to December 2017 was filed within due date but the late fee was erroneously levied on the common portal.
GSTR-6 Input service distributor who has paid a late fee for filing or submission of the return for any tax period between 1 January 2018 to 23 January 2018.
SKP's Comments
  • The government has notified the format of much awaited GSTR-9C through which the taxpayers would have to provide a reconciliation between GST returns and the audited financial statements. Businesses should begin preparing these reconciliations immediately to avoid possibilities of qualifications by the auditor.
  • The number of GSTR-3B filed across the country is substantially higher than the number of GSTR-1 filed. In view of this, the government has extended the due date for filing of GSTR-1 as a one-time relief to the taxpayers to ensure compliance with the GST law.
  • A number of petitions were being filed by various taxpayers in High Courts across the country praying for relief, in the form of an extension of due dates for filing GST TRAN-1 and GST TRAN-2 in view of the technical difficulties faced by them. In order to reduce litigation, the government has granted a blanket extension to all taxpayers to carry forward their transitional credits.

Urmi Axis | 7th Floor | Famous Studio Lane | Mahalaxmi | Mumbai | 400 011 | India
+91 22 6730 9000 | 
skp.gst@skpgroup.com | www.skpgroup.com

India | USA | Canada | UAE
This update contains general information which is provided on an “as is” basis without warranties of any kind, express or implied and is not intended to address any particular situation. The information contained herein may not be comprehensive and should not be construed as specific advice or opinion. This update should not be substituted for any professional advice or service, and it should not be acted or relied upon or used as a basis for any decision or action that may affect you or your business. It is also expressly clarified that this update is not intended to be a form of solicitation or invitation or advertisement to create any adviser-client relationship.

Whilst every effort has been made to ensure the accuracy of the information contained in this update, the same cannot be guaranteed. We accept no liability or responsibility to any person for any loss or damage incurred by relying on the information contained in this update.

© 2018 SKP Business Consulting LLP. All rights reserved.