NEW GSTR 3B : Concept Paper

The Central Board of Indirect Taxes and Customs (CBIC) has released a Concept Paper on the comprehensive changes proposed in the form GSTR-3B and invited comments and suggestions from the stakeholders. A proposal of comprehensive changes in FORM GSTR-3B was deliberated by the GST Council in its 47th meeting held at Chandigarh on 28th and 29th June 2022. The Council recommended that the said proposal may be placed in public domain for seeking inputs and suggestions of the stakeholders. “Accordingly, the general public and the trade at large are hereby informed that a detailed Concept Paper on comprehensive changes in FORM GSTR-3B is enclosed. All members of the trade/ stakeholders are requested to kindly furnish their views/comments/suggestions on the Concept Paper latest by 15th September 2022 at gstpolicywing-cbic@gov.in so as to facilitate finalization of the matter,” the CBIC stated in a statement.

New GSTR 3B  format Changes

i.                 Auto-population of values from GTSR-1 into GSTR-3B in specific rows: This would establish one-to-one correspondence to a large extent between rows of GSTR-1 & GSTR-3B, thereby providing clarity to the taxpayer and tax officers. Further, it would minimize requirement of user input in GSTR3B and ease GSTR-3B filing process.

ii.                 Provision for allowing amendment in GSTR-3B vide insertion of various amendment tables for outward supplies, input supplies liable to reverse charge and ITC: Since FORM GSTR-1 and FORM GSTR-2B have been linked with FORM GSTR-3B, it is recommended that amendment in FORM GSTR-3B, as far as feasible, should flow from amendment in FORM GSTR1, as far as outward liabilities are concerned. Even in the new return system which was envisaged, the amendment in RET-1(RET-1A) was proposed through amendment in details of outward supply (ANX-1/ANX-1A). Therefore, for giving more clarity to the taxpayers, separate amendment table (for liabilities) may be introduced in FORM GSTR-3B so that any amendment made in FORM GSTR-1 gets reflected in FORM GSTR3Bclearly. Similarly, an amendment table may also be incorporated in FORM GSTR-3B to show any amendment in ITC portion. [The amendment tables may be activated only on selection by taxpayers]

iii.               Allowing negative values in GSTR-3B & carrying forward the negative values of previous tax period to current tax period.

iv.               Providing specific rows for showing various reversals and subsequent reclaims of ITC.

v.                Streamlining the process of settlement of IGST revenues: The ITC reversed needs to be considered for Settlement of IGST. Further, amendments made by taxpayer in those details which are required for settlement (viz. in Table-3.2 or section 17(5) reversals etc.) need to be captured for ensuring accurate settlement of IGST revenues. Distinction must be made between:

a. the ITC reversed which need not be reclaimed in future; and

b. the ITC which is reversed but may be claimed in future.

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