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New Simplified Return Forms - Sahaj & Sugam and difference in filing return for small taxpayers

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In our previous blog series of GST new return formats, we have covered the aspects of introductory part giving brief idea about the simplified formats, new return formats for Large tax payers and comparative analysis of GSTR-1 and proposed tax returns for Large Taxpayers.

Our recent blog states all the differences in GSTR-1 parameters however, this blog focuses on “Small taxpayers” and how return filing will be shaping in the new return formats scenario.

Who are Small-Taxpayers?

Taxpayers who have a turnover up-to Rs.5 Cr. in the last financial year shall be considered small Taxpayer. These small taxpayers shall have facility  to file quarterly return with monthly payment of taxes on self-declaration  basis. However, the facility would be optional and small taxpayer can also file monthly return like a large taxpayer.

Point to note is that a newly registered taxpayer shall be classified on the basis of self-declaration of the estimated turnover.

 

Though in existing scenario, there is no terminology-based bifurcation, the Turn-over bifurcates the tax-payers into different category. In forth coming  GST return regime, the tax-payers are bifurcated as Small and Large based on turn-over.

 

In this blog let’s understand about changes as per the new return process for Small Taxpayers.

Filing Frequency & Return Format

Criteria

Existing scenario

Forthcoming scenario

Filing Frequency

Tax-payers with turnover not exceeding Rs.1.5 Cr during preceding  financial year have an option to file ‘Quarterly return’.

Tax-payers with turnover not exceeding Rs.5 Cr during preceding financial year are termed as Small Tax-payers and have an option to file ‘Quarterly return’.

Return Format

Return format for Quarterly filers is same as that for Monthly filers.

Apart from Quarterly return format which is akin to the monthly return format, there are two pre-defined return formats: i) Sahaj ii) Sugam (Briefly described below)

 

Uploading of outward Supplies Invoices & Payment of Taxes

See how the new rules affect uploading of invoices and tax payment

 

Criteria

Existing Scenario

Forthcoming Scenario

Uploading of Outward Invoices

If “Quarterly Filing” is opted, the upload of Outward Invoices is done on Quarterly  basis in Quarterly filed GSTR-1.

A facility to continuously upload invoices in the normal course would be available. The invoices uploaded by 10th of the following month would be available as input tax credit to the recipient in the next month and in the case of purchases from large taxpayers.

Tax Payment

Taxes are paid monthly by way of GSTR-3B.

Taxes are paid monthly by way of GSTR-3B.

 

Pre-determined Scenario and Actionable invoices

Check in which category you fall under as a taxpayer and what authorities you have

Criteria

Existing Scenario

Forthcoming Scenario

Predetermined Scenario

There is no checklist to include pre-determined transactions in the return

Sahaj & Sugam are two different pre-defined return types. Small tax-payers, opting for Quarterly filings, have an additional option to opt for appropriate pre-defined options from amongst Sahaj and Sugam.

Actionable invoices

Currently there is no provision for such actionable invoices as GSTR-2 is suspended indefinitely.

In case, if small taxpayer decides to take an action on the inward invoices, then this can be done provided such tax-payer shall have to file on monthly  basis

 

How to determine you Input Tax Credit

Criteria

Existing Scenario

Forthcoming Scenario

Input Tax Credit

Self-declaration in GSTR-3B and if purchases are made from B2B dealers, then on the basis of such invoices as appearing in GSTR-2A.

Since there will be continuous uploading facility, similar viewing facility of uploaded invoices will also be there to facilitate calculation and appropriate claiming of ITC.

 

Penalty for Late Filing and HSN requisite

Learn what will get you a fine for late filing under the new changes and the new requisites for HSN

Criteria

Existing Scenario

Forthcoming Scenario

Late Fees and Penalties

Late fees at Rs.25/- for each day of delay under CGST and SGST respectively and Rs.50/- for each day of delay under IGST shall be attracted.

Late payment of tax liability including that in first and second month of the quarter shall attract interest liability.

HSN

Minimum 2 digits HSN code is mandatory for turnover not exceeding Rs.1.5 crore

Minimum of 4 digits HSN code is mandatory for turnover not exceeding Rs.5Cr.

 

Cost Effectiveness

Criteria

Existing Scenario

Forthcoming Scenario

Cost Effectiveness

The GST implementation and the initial compliance made the registered dealers to  bear high  cost to set up the infra-structure  or to decide not register themselves. The later  resulted in loss  of business as large-tax payers hesitate to deal with unregistered dealers.

Since the regular uploading of invoice  is made available, the ITC and business won’t be hampered. Also, since currently the infrastructure is set and the compliance has been made flexible through Sahaj and Sugam forms and Payment forms, the return compliance has be  relaxed.

 

What are “Sahaj” and “Sugam” Returns?

Small taxpayers often have purchases only from the domestic market and sales in the domestic market i.e B2B purchases locally and supplies either as B2C or B2B+B2C. They constitute a very large part of the tax base and therefore two simplified quarterly returns are proposed for them respectively. They have been named as “Sahaj” (only B2C outward supplies) and “Sugam” (both B2B and B2C outward supplies). In effect, these returns are pre-determined profiles for small taxpayers using quarterly return.

In our subsequent blog, we will be covering a Comparative analysis of Quarterly return, Sahaj and Sugam.

The new return formats are available here and comments can be provided till Aug 31, 2018.  Please provide your comments and suggestions. 

IRIS Business is a leading GST Suvidha Provider (GSP) and provides easy and efficient solutions for GST and E-way bill compliance. For further details, please write to support@irisgst.com or visit our site https://irisgst.com.

 

About Anushree Joshi

Anushree Joshi, a CA and CMA, is associated with IRIS as Business Analyst for over 7 years. She is actively involved in the IRIS GST product development and client interactions and issue handling . Before GST she was handling US compliance analyzing US financial statements and reviewing XBRL filings for US and India market. In her leisure time, she enjoys reading and put up her feet on the classical dance form of Kathak.

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