In the light of the recent clarification from CBEC, the businesses are allowed to use the transitional input tax credit in paying the July month’s tax liability. This is a much needed relief to businesses who had huge amount of transitional credit. This is because they feared that the non-availability of such option would have a severe impact on cash out-flow of the business. 

With the council’s decision to allow the transitional credit, the due date of GSTR-3B has also been extended for businesses that wish to claim the transitional ITC in July month’s return. As a result, there are two sets of due date to file GSTR-3B for businesses: 20th August, 2017, and 28th August, 2017. Let us discuss who has to File GSTR-3B on 20th August, 2017 and who on 28th August, 2017.

Also read: Transitional credit in GSTR-3B

GSTR-3B due date of 20th August, 2017

Businesses planning not to avail transitional credit for discharging the tax liability for the month of July, 2017, or new registrants who do not have any transitional credit to avail, the due date to file 3B will be 20th August, 2017. The following are the key actions these business needs to take care of in filing GSTR-3B

1. Arrive at July Month’s tax liability, by considering only the ITC availed in July. You can use the below formula to calculate the tax liability

Tax payable = (Output tax liability + Tax payable under reverse charge) – Input tax credit availed in the month of July, 2017

2. Tax payable as determined above needs to be deposited in cash/cheque/e-payment on or before 20th August, 2017, which will get credited to electronic cash ledger.

3. File the Form GSTR-3B on or before 20th August, 2018 after discharging the tax liability by debiting the electronic credit or cash.

GSTR-3B Due Date by 28th August, 2017

For businesses planning to use the transitional ITC towards payment of July tax liabilities, the due date to file GSTR-3B is by 28th August, 2017. The following are the key actions need to be taken care of in filing GSTR-3B.

1. Arrive at July month’s tax liability, by considering both input tax credit availed in July, as well as transitional ITC. You can use the below formula to calculate the tax liability :

Tax payable = (Output tax liability + Tax payable under reverse charge) – (Transitional credit + input tax credit availed in the month of July, 2017)

2. Tax payable as determined as above needs to be deposited in cash on or before 20th August, 2017, which gets credited to electronic cash ledger.

3. Ensure Form Tran-1 is filed in the portal before filing the return in Form GSTR-3B. The option to upload Form Tran-1 will be available on GST portal from 21st August, 2017.

4. File the Form GSTR-3B on or before 28th August, 2017, after discharging the tax liability by debiting the electronic credit or cash ledger.

Businesses opting to avail the transitional ITC in discharging the July month’s tax liability need to take utmost care and caution in determining the eligible transitional ITC allowed to be carried forwarded. This is to arrive at the accurate tax liability to pay on 20 August, 2017. This is because, any shortfall (that is, tax liability of GSTR-3B is greater than the payment made on 20th August, 2017), have to be paid along with interest @18% calculated from 21 August, 2017 till the date of such deposit. This amount will also get credited to electronic cash ledger.

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