CMA Final · Indirect Tax Laws and Practice
GST Returns: formula sheet
Key formulas
- GSTR-1
- Statement of outward supplies; standard dates: monthly by the 11th of next month; quarterly (QRMP) by the 13th of the month after the quarter
- Filed by regular taxpayers. Reports supplies, not payment. These are the usual dates. Due dates are set by notification and can change, so use any date the question gives.
- GSTR-3B
- Summary return with payment of tax; standard date: monthly by the 20th of next month
- QRMP taxpayers file quarterly, with tax paid monthly. The usual quarterly dates are the 22nd or 24th depending on the State or Union territory. Both are standard dates that can change by notification.
- GSTR-9
- Annual return; standard date: 31 December following the financial year
- Under section 44, for regular taxpayers. Filing is optional below the turnover limit notified for the year. The date can be extended by notification.
- GSTR-9C
- Reconciliation statement; filed with GSTR-9 above the notified turnover limit
- Reconciles audited financial statements with the annual return. It is now self-certified.
- GSTR-9A
- Annual return of composition taxpayer, up to FY 2018-19
- GSTR-9A was the annual return for composition taxpayers up to FY 2018-19. From FY 2019-20, composition taxpayers file their annual return in GSTR-4.
- GSTR-5, 6, 7, 8
- GSTR-5: non-resident taxable person; GSTR-6: Input Service Distributor; GSTR-7: TDS deductor; GSTR-8: e-commerce operator (TCS)
- Usual standard dates: GSTR-5 by the 20th of next month (or within 7 days after the registration expires, if earlier), GSTR-6 by the 13th, GSTR-7 by the 10th, GSTR-8 by the 10th. These dates are fixed by CBIC notification and can change. Confirm against the notification or the date in the question.
- GSTR-10
- Final return under section 45, filed electronically under Rule 81
- Section 45: within three months of the date of cancellation or the date of the cancellation order, whichever is later. Rule 81 requires it to be filed electronically in FORM GSTR-10 on the common portal.
- Record retention
- Retain books until 72 months from the due date of the annual return for that year (section 36)
- If an appeal, revision or proceeding is pending, or an offence investigation is on, keep the related records for one year after final disposal, or the 72 months, whichever is later.
- Rule 88C and 88D
- GSTR-1 tax > GSTR-3B tax → DRC-01B; GSTR-3B credit > GSTR-2B credit → DRC-01C; reply in 7 days
- Triggered only when the difference crosses the amount and percentage the Council recommends.
- GSTR-1 for regular filers
- Every registered person required to furnish outward supply details under section 37 files FORM GSTR-1 for the month or the quarter
- A person under section 14 of the IGST Act is excluded from Rule 59(1).
- Invoice-wise vs consolidated reporting
- Invoice-wise: all supplies to registered persons, and inter-State supplies to unregistered persons with invoice value > ₹1,00,000. Consolidated: other supplies to unregistered persons
- Intra-State to unregistered: by rate of tax. Inter-State up to ₹1 lakh: State-wise by rate of tax.
- IFF limits
- Months 1 and 2 of a quarter; cumulative value ≤ ₹50,00,000 in each month; window from 1st to 13th of the next month
- Only for persons furnishing quarterly returns. IFF covers supplies to registered persons only.
- No double reporting
- Details furnished through IFF are not furnished again in GSTR-1 for the quarter
- Quarterly GSTR-1 covers the rest.
- GSTR-1A
- After GSTR-1 for a period but before GSTR-3B for that period, the person may amend or add details in FORM GSTR-1A
- Optional. Amendments flow into the Rule 88C comparison.
- GSTR-3B block on GSTR-1
- GSTR-1 (or IFF) cannot be filed if GSTR-3B for the preceding month (or preceding tax period for quarterly filers) is not filed
- Rule 59(6)(a) and (b).
- Rule 88C difference
- Tax per GSTR-1 (as amended in GSTR-1A, if any) or IFF > tax per GSTR-3B by the amount and percentage recommended by the Council → Part A of FORM GST DRC-01B
- Response period is seven days: pay with interest under section 50 via FORM GST DRC-03, or explain.
- Who files GSTR-9 (Rule 80(1))
- Every registered person, except ISD, section 51 payer, section 52 payer, casual taxable person, non-resident taxable person and the Government/local authority class in the second proviso to section 44
- Composition taxpayers under section 10 file GSTR-9A instead.
- Due date of GSTR-9
- 31 December following the end of the financial year
- Example: for FY 2026-27, the due date is 31 December 2027. The 28 February 2022 date was only for FY 2020-21.
- GSTR-9C threshold (Rule 80(3))
- Aggregate turnover during the financial year > ₹5 crore
- The test is 'exceeds', so exactly ₹5 crore does not require GSTR-9C. The statement is self-certified and filed with GSTR-9 by the same due date.
- Time bar (section 44(2))
- No annual return after 3 years from the due date
- Government may allow later filing by notification on Council's recommendation, with conditions.
- Other annual forms
- GSTR-9A: section 10 payer; GSTR-9B: e-commerce operator under section 52
- GSTR-9B is an annual statement under section 52(5).
- Interest on late-filed return (rule 88B(1))
- Interest = tax paid through electronic cash ledger × notified rate × days of delay ÷ 365
- Applies when supplies are declared in a return filed after the due date. Credit ledger payments are excluded. Rate is notified under section 50(1). Does not apply if filed after proceedings under section 73, 74 or 74A have started.
- Cash ledger proviso
- Amount credited to cash ledger on or before due date and lying there until debit at filing is excluded from interest
- Added by the 2024 amendment to rule 88B(1). Such balance is not counted.
- Interest in all other cases (rule 88B(2))
- Interest = unpaid tax × notified rate × days from due date to payment date ÷ 365
- Applies to all cases not covered by rule 88B(1).
- Interest on wrongly availed and utilised ITC (rule 88B(3))
- Interest = ITC wrongly availed and utilised × notified rate × days from utilisation to reversal or payment ÷ 365
- Mere availment without utilisation does not attract interest under section 50(3). Utilisation occurs when the credit ledger balance falls below the wrongly availed amount.
- Date of utilisation (Explanation to rule 88B(3))
- Earlier of due date and actual filing date, if utilised through the return; otherwise the date of debit
- Extent of utilisation is the amount by which the ledger balance falls below the wrongly availed credit.
- Rule 37A reversal
- Reverse ITC by 30 November if supplier's GSTR-3B is not filed by 30 September following the financial year
- If not reversed, the amount is payable with interest under section 50. You may re-avail if the supplier files later.
- Late fee on assessment order (section 62)
- Return filed within 60 days of the order: order is withdrawn; a further 60 days allowed with an additional late fee of ₹100 per day
- Interest under section 50(1) and late fee under section 47 continue to apply.
- Notice under section 46
- Failure to file return under section 39, 44 or 45 → notice → file within 15 days
- The notice must require filing within fifteen days, in the prescribed form and manner.
- Rule 68
- Notice in FORM GSTR-3A, issued electronically
- Covers failure under section 39, 44, 45 or 52.
- Assessment of non-filers, section 62(1)
- Order within 5 years from the due date of the annual return for the relevant financial year
- Applies where return is not filed even after service of the section 46 notice. Assessment is on best judgment.
- Withdrawal, section 62(2)
- Valid return within 60 days of service of order → order deemed withdrawn
- Interest under section 50(1) and late fee under section 47 continue.
- Extended period, proviso to section 62(2)
- Further 60 days, with additional late fee of ₹100 per day beyond 60 days
- If a valid return is filed in the extended period, the order is deemed withdrawn. Interest and late fee continue.
- Assessment order forms, Rule 100(1)
- Order in FORM GST ASMT-13; summary in FORM GST DRC-07
- Do not confuse with ASMT-14 and ASMT-15, which relate to the section 63 best judgment assessment under Rule 100(2).
- Legal basis of scrutiny
- Section 61 CGST Act: proper officer may scrutinise return and related particulars to verify correctness
- Procedure is in Rule 99. The officer informs you of discrepancies and seeks your explanation.
- Notice of discrepancy
- FORM GST ASMT-10, reply time ≤ 30 days from date of service or further period permitted
- Notice should, where possible, quantify tax, interest and any other amount payable.
- Reply by the registered person
- FORM GST ASMT-11: accept and pay, or furnish explanation
- Rule 99(2). Acceptance involves paying tax, interest and other amount arising from the discrepancy.
- Acceptance by the officer
- FORM GST ASMT-12
- Rule 99(3). Issued when explanation or information is found acceptable. Section 61(2): no further action on that matter.
- Consequence of no satisfactory reply
- Section 61(3): audit under section 65, special audit under section 66, inspection, search and seizure under section 67, or determination of tax under section 73, 74 or 74A
- Applies if no satisfactory explanation within thirty days (or extended period), or if discrepancy is accepted but not corrected in the return for the month of acceptance.
Quick revision
- A regular taxpayer files a return for every calendar month or part of it, unless notified for the quarterly option.
- A return is required for every tax period even if there were no supplies.
- A person paying tax under section 10 files a yearly return, and the statement is on a quarterly basis.
- CMP-08 is due by the 18th day of the month after the quarter.
- GSTR-4 is due by 30 April; from FY 2024-25 it is due by 30 June.
- Composition tax is paid by debiting the electronic cash ledger.
- An Input Service Distributor and a non-resident taxable person have a 13-day limit after month end for the return, as stated in the section; the non-resident one also has a 7-day test after registration ends, whichever is earlier.
- Rectification under section 39(9) is not allowed after 30 November following the financial year, or the annual return date if earlier.
- A return cannot be filed after three years from its due date, unless the Government notifies otherwise.
- Section 62 assessment: best judgment, after a section 46 notice, within five years from the annual return due date.
- A valid return within 60 days of the section 62 order withdraws it; interest and late fee still apply.
- A further 60 days is available with an additional late fee of ₹100 per day beyond the first 60 days.
Common mistakes
- Saying GSTR-1 is the return where tax is paid. Fix: GSTR-1 reports outward supplies. Tax is paid through GSTR-3B.
- Using the monthly due dates for a QRMP taxpayer. Fix: For QRMP, the standard position is that GSTR-1 is quarterly by the 13th after the quarter and GSTR-3B is quarterly by the 22nd or 24th, with monthly tax payment. These dates can change by notification, so use any date the question gives.
- Treating the ₹1 lakh invoice value limit as applicable to all supplies Fix: The limit applies only to inter-State supplies to unregistered persons. Supplies to registered persons are always invoice-wise.
- Reporting supplies to unregistered persons in IFF Fix: IFF holds only invoice-wise supplies to registered persons and related debit and credit notes.
- Saying GSTR-9C is required at ₹5 crore turnover. Fix: Rule 80(3) says 'exceeds five crore rupees'. Exactly ₹5 crore needs no GSTR-9C.
- Treating GSTR-9C as a CA/CMA-certified audit statement. Fix: The current Rule 80(3) requires a self-certified reconciliation statement. The earlier certification wording was substituted in 2021.
- Charging interest on the entire tax liability of a late return. Fix: Under rule 88B(1), charge interest only on the portion paid through the electronic cash ledger.
- Charging interest on a nil return. Fix: No tax was paid late, so no interest. Late fee alone may apply.
- Naming FORM GST ASMT-02 as the non-filer notice Fix: Link Rule 68 with GSTR-3A. ASMT-02 is for provisional assessment under Rule 98.
- Saying the assessment order can be passed immediately on the due date Fix: Section 62 applies only where the return is not filed even after service of the section 46 notice.
Exam tips
- MCQs usually test who files which form or the due date. Learn the Person–Form–Date grid cold.
- In descriptive answers, always state what each return reports. Marks go for the purpose, not just the form number.
- On Rules 88C and 88D, name the form, the trigger, the seven-day period and the consequence.
- If a question gives a special due date or relief, use it. Do not insist on the standard date.
- Remember record retention: 72 months from the due date of the annual return, extended if a proceeding is pending.
- MCQs often test numbers: ₹1 lakh invoice limit, ₹50 lakh IFF limit, 13th date, and seven days under Rule 88C. Memorise them with their conditions.
- In a case scenario, classify each supply by recipient and inter-State or intra-State before answering.
- When a question mentions a mismatch of GSTR-1 and GSTR-3B, name Rule 88C and DRC-01B, and mention the 7-day response and interest.