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Relaxation of GSTR-1 & GSTR-3B Return for Feb, March and April 2020

CA Adityavikram Banka

The Government has issued several notifications in order to implement the compliance relaxation announced by Hon’ble Finance Minister amid Pandemic COVID 19. We have compiled various Clarification on Compliance Relaxation for GST Return for Feb, March and April 2020.

GSTR-1 Return 

A. Late Fee Waiver – if return filed by 30th June 2020.

The CBIC, vide Notification No. 33/2020-CT dated 03.04.2020, has waived the late fee on delayed filing of return in GSTR-1, for the month of February 2020, March 2020 and April 2020, by the registered person subject to the condition that such taxpayer shall file the return in GSTR – 1, for the month of February 2020, March 2020 and April 2020, by 30th June 2020.

Thus, if the return in GSTR-1 is not filed on or before the above mentioned date then such taxpayer shall be liable to pay the late fee on delayed filing of return in GSTR-1 and such late fee shall be applicable from the actual due date of filing of return in GSTR-1.

GSTR3B Return

A. Interest Waiver:

i. Taxpayer having turnover upto INR 1.5 Crore

  • Interest Waiver if return filled by 30th June 2020 for Feb 2020, 3rd July 2020 for Mar 2020 & 6th July 2020 for Apr 2020 return.

The CBIC, vide Notification No. 31/2020-CT dated 03.04.2020, has waived the interest on delayed payment of tax, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover upto INR 1.5 Crore subject to the condition that such taxpayer shall file the return in GSTR – 3B for the month of February 2020 by 30th June 2020, for the month of March 2020 by 3rd July 2020 and for the month of April 2020 by 6th July 2020.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned dates then such taxpayer shall be liable to pay the interest @18% p.a. on the delayed payment of tax.

ii. Taxpayer having turnover of more than INR 1.5 Crore and upto INR 5 Crore

  • Interest Waiver if return filled by 20th June 2020 for Feb & Mar 2020 and 30th June 2020 for April 2020.

The CBIC, vide Notification No. 31/2020-CT dated 03.04.2020, has waived the interest on delayed payment of tax, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover of more than INR 1.5 Crore and upto INR 5 Crore subject to the condition that such taxpayer shall file the return in GSTR – 3B for the month of February 2020 and March 2020 by 20th June 2020 and for the month of April 2020 by 30th June 2020.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned dates then such taxpayer shall be liable to pay the interest @18% p.a. on the delayed payment of tax.

iii. Taxpayer having turnover of INR 5 Crore and above 

  • Interest Waiver if return filled within 15 days of the actual due date.
  • Reduced Interest Rate of 9% p.a. if filled by 24th June 2020.

The CBIC, vide Notification No. 31/2020-CT dated 03.04.2020, has waived the interest on delayed payment of tax, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover of INR 5 Crore and above subject to the condition that such taxpayer shall file the return in GSTR – 3B, for the month of February 2020, March 2020 and April 2020, within 15 days of the actual due date.

However, after 15 days of due date, such taxpayer shall be liable to pay interest on delayed payment of tax at the reduced rate of 9% p.a. provided that the return in GSTR – 3B, for the month of February 2020, March 2020 and April 2020, shall be filed by 24th June 2020. Such interest will be calculated from the expiry of 15 days after the due date.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned date then such taxpayer shall be liable to pay the interest @18% p.a. on the delayed payment of tax.

B. Late Fee Waiver:

i. Taxpayer having turnover upto INR 1.5 Crore

  • Late Fee Waiver if return filled by 30th June 2020 for Feb 2020, 3rd July 2020 for Mar 2020 & 6th July 2020 for Apr 2020 return.

the CBIC, vide Notification No. 32/2020-CT dated 03.04.2020, has waived the late fee on delayed filing of return in GSTR-3B, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover upto INR 1.5 Crore subject to the condition that such taxpayer shall file the return in GSTR – 3B for the month of February 2020 by 30th June 2020, for the month of March 2020 by 3rd July 2020 and for the month of April 2020 by 6th July 2020.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned dates then such taxpayer shall be liable to pay the late fee on delayed filing of return in GSTR-3B and such late fee shall be applicable from the actual due date of filing of return in GSTR-3B.

ii. Taxpayer having turnover of more than INR 1.5 Crore and upto INR 5 Crore

  • Late Fee Waiver if return filled by 20th June 2020 for Feb & Mar 2020 and 30th June 2020 for April 2020.

The CBIC, vide Notification No. 32/2020-CT dated 03.04.2020, has waived the late fee on delayed filing of return in GSTR-3B, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover of more than INR 1.5 Crore and upto INR 5 Crore subject to the condition that such taxpayer shall file the return in GSTR – 3B for the month of February 2020 and March 2020 by 20th June 2020 and for the month of April 2020 by 30th June 2020.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned dates then such taxpayer shall be liable to pay the late fee on delayed filing of return in GSTR-3B and such late fee shall be applicable from the actual due date of filing of return in GSTR-3B.

iii. Taxpayer having turnover of INR 5 Crore and above 

  • Late Fee Waiver if return filled by 24th June 2020.

the CBIC, vide Notification No. 32/2020-CT dated 03.04.2020, has waived the late fee on delayed filing of return in GSTR-3B, for the month of February 2020, March 2020 and April 2020, by the taxpayer having turnover of INR 5 Crore and above subject to the condition that such taxpayer shall file the return in GSTR – 3B, for the month of February 2020, March 2020 and April 2020, by 24th June 2020.

Thus, if the return in GSTR-3B is not filed on or before the above mentioned date then such taxpayer shall be liable to pay the late fee on delayed filing of return in GSTR-3B and such late fee shall be applicable from the actual due date of filing of return in GSTR-3B.

CA Adityavikram Banka
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