Taxpayers are facing many difficulties in meeting their regular compliances due to COVID-19 pandemic. Keeping into consideration the severe consequences of COVID-19, the Government of India (GOI) has announces relaxations and several relief measures for GST Return filing to lower the compliance burden on the taxpayers.
In the context of the same, the Government has introduced following relaxations in relation to GST return filing, due dates, wavier of late filing fees and penalty, revised return, opt-in composition scheme, etc. as discussed below:
1. Due date extended for filing Form GSTR-3B return
(Refer Circular dated 07/04/2020 – Part 1)
(i) Based on Turnover
| Month | Turnover more than 5 crores | Turnover exceeding 1.5 crores to 5 crores | Turnover up to 1.5 crores |
| February, 2020 | 24th June, 2020 | 29th June, 2020 | 30th June, 2020 |
| March, 2020 | 24th June, 2020 | 29th June, 2020 | 03rd July, 2020 |
| April, 2020 | 24th June, 2020 | 30th June, 2020 | 6th July, 2020 |
| May, 2020 | 27th June, 2020 | Refer below (ii) | Refer below (ii) |
(ii) Based on the principal place of business
For the period May, 2020 Due date extended for filing Form GSTR-3B return for the taxpayers having aggregate turnover upto Rs. 5 crores and the principal place of business is in the state as listed below:
| Extended due date | Group | Principal place of business |
| 12th July, 2020* | Group 1 | Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, Daman & Diu and Dadra & Nagar Haveli, Puducherry, Andaman and Nicobar Islands, Lakshadweep |
| 14th July, 2020* | Group 2 | Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, Jammu and Kashmir, Ladakh, Chandigarh, Delhi |
* Date till which the late fee is not applicable
2. Due date extended for filing Form GSTR-1
(Refer Circular dated 07/04/2020 – Part 1)
| Tax period | Original Due date | Extended Due date |
| March, 2020 | 11th April, 2020 | 30th June, 2020 |
| April, 2020 | 11th May, 2020 | 30th June, 2020 |
| May, 2020 | 11th June, 2020 | 30th June, 2020 |
| Quarterly taxpayers Jan to March 2020 | 30th April, 2020 | 30th June, 2020 |
3. Timeline for filing GSTR-7
The due date for filing GSTR-7 for the period March, April and May 2020 has been extended up to 30th June, 2020.
4. Interest Liability for filing Form GSTR-3B
(Refer Circular dated 07/04/2020 – Part 3)
15 days grace period has been allowed from the original date as interest-free. If the return filed within these period, no interest will be charged. Post that, if the return is filed by 24th June, 2020, then interest at 9% will be charged and if filed after 24th June, 2020, interest at 18% will be levied.
(i) Interest not applicable, if filed by
| Month | Turnover more than 5 crores | Turnover exceeding 1.5 crores to 5 crores* | Turnover up to 1.5 crores* |
| February, 2020 | 4th April, 2020 | 29th June, 2020 | 30th June, 2020 |
| March, 2020 | 5th May, 2020 | 29th June, 2020 | 03rd July, 2020 |
| April, 2020 | 4th June, 2020 | 30th June, 2020 | 6th July, 2020 |
* Interest at the rate if 18% will be applicable if the returns are filed after the dates as listed above.
(ii) Interest applicable as below after due date filing having aggregate turnover more than Rs. 5 crores
| Month | Date from which Interest is payable @ 9% till date of filing, if filed by 24th June, 2020 | Date from which Interest is payable @ 18% till date of filing, if not filed by 24th June, 2020 |
| February, 2020 | 5th April, 2020 | 21st March, 2020 |
| March, 2020 | 6th May, 2020 | 21st April, 2020 |
| April, 2020 | 5th June, 2020 | 21st May, 2020 |
(iii) Interest @ 18% applicable, if not filed by the dates mentioned in the above point (i) having aggregate turnover up to Rs. 5 crores based on Principal place of business (Group-wise)
| Month | Date from which interest @ 18% for taxpayers falling in States/ UT of Group 1 | Date from which interest @ 18% for taxpayers falling in States/ UT of Group 2 |
| February, 2020 | 23rd March, 2020 | 25th March, 2020 |
| March, 2020 | 23rd April, 2020 | 25th April, 2020 |
| April, 2020 | 23rd May, 2020 | 25th May, 2020 |
5. Due date extended for Composition dealers:
(Refer Circular dated 07/04/2020 – Part 2)
| Form | Tax period | Extended Date |
| GST CMP-08 | Jan to March 2020 | 07.07.2020 |
| GSTR-4 | FY 2019-20 | 15.07.2020 |
| GST CMP-02 | 2020-21 | 30.06.2020 |
| GST ITC-03 | 2019-20 (As on 31-3-2020) | 31.07.2020 |
6. NRTP, ISD, TDS & TCS taxpayers:
(Refer Circular dated 07/04/2020 – Part 2)
The due date for filing GSTR-5, GSTR-6, GSTR-7 and GSTR-8 by the taxpayers for the period March, April and May 2020 has been extended up to 30th June, 2020.
7. Extension of validity period of EWB:
(Refer Circular dated 07/04/2020 – Part 2)
The validity of E-way bills (EWBs), generated on or before 24th March, 2020, and whose validity expiry date lies on or after 20th March, 2020, is deemed to have been extended till 30th June, 2020.
8. Opting-in for Composition Scheme for FY 2020-21
(Refer Circular dated 07/04/2020)
Existing Normal taxpayers who want to opt for Composition Scheme in Financial Year 2020-21 may note following changes:
i. Revised date to file Form GST CMP 02: Normal and registered taxpayers who want to opt in for Composition in FY 2020-21 can apply in Form GST CMP-02 by 30th June 2020.
ii. No GSTR 1 or 3B to be filed in FY 2020-21 for associated PAN: The taxpayers should not file any GSTR-1/GSTR-3B, for any tax period of FY 2020-21, from any of the GSTIN on the associated PAN, or else they will not be able to opt for composition scheme for FY 2020-21.
iii. No need for re-opting for the composition scheme: The taxpayers who are already in composition scheme, in previous financial year are not required to opt in for composition again for FY 2020-2021.
iv. Revised date to file Form GST ITC 03: Form GST ITC-03 to reverse ITC for the stock in hand at the time of transition can be filed till 31st July, 2020.
v. Modification in earlier advisory date 18.02.2020: The advisory issued on 18.02.2020 and available on GST Portal stands modified to above extent.
The Government is looking after the interests of the small businesses by waving off interest, penalty and late fees. The above relaxations and relief measures for GST return filing announced by the government are welcomed by all the taxpayers.