GST return filing deadlines - The Three-Month Storm

Companies subject to Indian GST should take note….

Recently Indian Revenue Secretary Hasmukh Adhia stated very clearly, “We (the GST Council) have already extended the period for GSTR-3B. People have to file their own self-assessed summary return till December, and there will not be any extension of time as far as GSTR-3B is concerned.”

Why is this important?

This statement takes any further delay of GST return filing deadlines off the table.  That means that following the already stated November 10th due date for July’s return, there will likely be another GST return deadline every five days through January!   The net result will be a calendar that looks something like this, with five to six tax return events every month for November, December, and January:

But wait…. the GST Council hasn’t said that.

That is true, but they have said enough to figure out what the rest of this year’s GST Tax calendar will look like:

• They have set the due dates for July, with the final return due for most companies by Nov 10^th.
• The GST Council has put the GSTN on notice to have all the issues resolved by end of October.
• Remember that the monthly returns all consist of three separate events (GSTR 1,2,3) and must be completed in order as each is dependent on the prior return being completed.
• They have extended the interim GSTR3B self-assessment thru December and no further. We must be back to the originally planned schedule end of January.

All this mean that between November 10^th and January 31^st every company in the country must complete at least fifteen separate tax filing events for GST, plus four GSTR3B self-assessments!  So, while the calendar above is speculative but for the announce July dates, the GST council will have to adhere to a very aggressive schedule that is something very much like the one above.

So how concerned should a GST registered company be about this?

Well, that depends on whether you have chosen a GST returns automation solution.  If you have, then your Application Service Provider should be guiding you through the current returns and completing the data integration to their solution.

…hmm…and if not?

Huge mistake.

Companies should in no way relax their preparations in the face of the most recent deadline delays, especially given that the Council has pushed the July dates all the way into November.  Instead, companies should strive to have a GST returns automation solution in place by the time the July GSTR2 return is filed in October.   The schedule for GST filing due dates is going to go from dead stop to rocket speeds immediately following the July return dates.

Action items for your business

1. The time to choose a GST returns automation solution is RIGHT NOW. With deadlines this aggressive, no amount of manual effort will be sufficient to keep up the pace given the last three months of this year will see five to six GST events every month.
2. By end of September, one should have an automation solution in hand. Do not allow the October 10^th date for GSTR1 to pass with only manual processing as an option for returns.
3. October should be dedicated to working through the data integration details with you selected ASP and their automation solution.
4. Expect to work a lot with your ASP to incorporate the changes made by the GSTN as they correct their systems thru October. Even today, as I write this article, we are discovering new changes posted overnight to the GSTNs return APIs.    It will, however, be those companies working with integration partners that are most ready for those changes.  Companies filing manually will lack the right kind of technical guidance to absorb those changes before the deadlines.

India Goods and Services Tax fundamentally changes the way any company, foreign or domestic, doing business here in India must operate. The right automation solution put into place now will allow those companies to file early and stay ahead of the bulk of the 8.5 million tax payers registered so far under GST.    Do not allow a lack of announced deadlines from the GST Council slow down your automation efforts.  Act today.

Avalara is an experienced application service provider (ASP) and partner of authorized GST Suvidha Providers (GSPs). To understand how our cloud-based application Avalara India GST can help you with GST compliance automation, contact us through https://www.avalara.com/in/products/gst-returns-filing.

Disclaimer: This blog is made available by Avalara for educational purposes only as well as to give you general information, not to provide specific legal or tax advice. The blog is an author’s opinion based on his learning and should not be used as a substitute for legal or tax advice from a licensed professional in your state or country.