电子发票门槛延长 | GST 申报自动化 | GST 审查时限及其他 GST 更新

The GST Department and CBIC keeps on issuing various notifications, circulars and instructions on small and big matters for ease of industries. Similarly, various updates are also made on GST portal to make the GST portal more automated and integrated with other portals.

Here is a gist of certain notifications, circulars, instructions or advisories issued by CBIC and GST Department in last sometime:

1. Reduction in threshold limit of e-invoice upto INR 5 Crores

• So far, e-invoice is required to be generated by any person whose aggregate turnover exceeds INR 10 Crores during any preceding Financial year from 2017-18.
• With an objective to expand base of e-invoice, GST Authority has reduced the threshold limit for e-invoice upto INR 5 Crores with effect from 1st August, 2023 vide notification No. 10/2023 dated 10th May, 2023.
• With effect from 1st August, 2023, every registered person who is having aggregate turnover exceeding INR 5 Crores during any preceding year from 2017-18 onwards, is required to generate e-invoice against following transactions:
  • Tax Invoice, Debit Note and Credit Note issued to registered person
  • Export Invoice

• However, e-invoice is not applicable on following type of registered person:
  • Insurance Company
  • Banking Company or a financial Institutions 
  • SEZ Units 
  • Government Department and Local Authorities 
  • Goods Transport Agency.

2. Time barring of Scrutiny of GST Returns of Delhi taxpayers for the FY 2017-18, 2018-19 & 2019-20.

• Section 73 of CGST Act, 2017 provides for scrutiny of GST returns in following cases:
  • Tax has not been paid; or 
  • Tax has been short-paid; or
  • ITC has been wrongly availed or utilized; or
  • Erroneous refund has been claimed

For reasons other than fraud or any wilful mis-statement or suppression of facts to evade taxes.

• As per Section 73(10) of CGST Act, proper officer is required to issue order under section 73(9) of CGST act within 3 years from due date of filing of annual return of relevant financial year.

• CBIC has extended the time limit for issuance of order under section 73(9) of CGST Act vide notification No. notification No. 9/2023 Central Tax dated 31.03.2023 in following manner:

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• In compliance with the above-mentioned notification, Department of Trades and Taxes, Delhi has issued a circular No. F.3/432/GST/Policy/2022/582-89 dated 8th May, 2023 to specify that entire process of scrutiny takes around 5 to 6 months. 

• Therefore, instructions has been issued to all jurisdictional officers to issue the notice in such a manner that order u/s 73(9) of CGST Act can be issued upto date notified by CBIC.

3. Automated Return Scrutiny Module for GST returns

• CBIC has given directions to roll out an Automated Return Scrutiny Module for GST returns at the earliest.
• In order to implement this non-intrusive means of compliance verification, CBIC has rolled out the Automated Return Scrutiny Module for GST returns in the ACES-GST backend application for Central Tax Officers.  
• This module will enable the officers to carry out scrutiny of GST returns of Centre Administered Taxpayers.
• Such taxpayers shall be selected on the basis of data analytics and risks identified by the System.
• In the module, discrepancies on account of risks associated with a return are displayed to the tax officers. Tax officers shall follow the following process for communication with taxpayers:
  • Discrepancies shall be communicated in Form GST ASMT-10
  • Taxpayer shall file the reply in FORM GST ASMT-11;
  • Tax officer shall either the order of acceptance of reply in FORM ASMT-12 or shall issue the show cause notice or shall initiate the audit/investigation.
• Implementation of this Module has commenced with the scrutiny of GST returns for FY 2019-20 and the requisite data for the purpose has already been made available on the officers’ dashboard.

4. Validation of Bank Account Validation

• For the purpose of GST registration, taxpayers are required to provide details of bank account.
• So far, many taxpayers, specially fake firms, were providing incorrect Bank account details and uploading fake cheque copies on the GST portal. 
• In order to put an end to this practise, GST portal has integrated the functionality of validation of Bank account with GST portal. 
• This integration aims to verify and validate the accuracy of bank account details for all types of GST taxpayers.
• The bank account validation status can be seen under:
  • “Dashboard > My Profile > Bank Account Status tab”
• Tax Payers will also receive the bank account status details on registered email and mobile number immediately after the validation is performed for his declared bank account. Here are the types of bank account validation status:

• Success
• Failure
• Success with remark
• Pending for verification 

5. New facility to verify document Reference Number (RFN) mentioned on offline communications issued by State GST authorities

• The GST portal (“System”) generates various documents, such as notices/ orders, etc which are communicated to the taxpayer. Most such documents have a system-generated unique identifier DIN (Document Identification Number)/ RFN (Reference Number). 
• All portal-generated documents are traceable on the taxpayer's dashboard within the portal.
• However, a new feature allowing taxpayers to verify such documents using the auto-generated RFN is currently under development and will be provided shortly.
• Further, there are many notices or orders which are issued by the department in offline mode and no information is available about such document on GST portal.
• in order to enable the taxpayers to ascertain that an offline communication (i.e. one which is not system-generated) was indeed sent by the State GST tax officer or not, a new facility for Reference Number (RFN) generation by State tax officer and verification by taxpayer has been provided
• As per the latest GSTN advisory, state tax offices can generate a unique RFN for each physical correspondence sent to taxpayers. Taxpayers can verify this RFN on the GST portal, (both pre-login and post-login). The facility to verify RFN of System-generated documents, once deployed, shall also be available in a seamless manner using the same link.
• Taxpayer can verify the RFN on following path on portal:

“Services > User Services > Verify RFN 

• 如果 RFN 属于州 GST 官员生成的线下通信，系统将显示与该有效 RFN 相关的详细信息。登录前也可查看部分有限信息以供核实，而纳税人在登录并核实发给其的线下通信中提到的 RFN 后，可获取更详细的信息。
• 此功能适用于州 GST 当局签发的线下信函。对于中央 GST 官员签发的文件，可使用 CBIC DIN 功能。

6. 推迟 7 天内报告旧电子发票的时限

• GST 部门已将电子发票 IRP 门户网站上报告旧电子发票的 7 天时限推迟了三个月。此外，该部门尚未公布新的实施日期。

7. 延长 GTA 行使选择权的截止日期

• 根据 2017 年 6 月 28 日第 11/2017-CGST（税率）号通知第 9(iii)(b) 条，GTA 有权选择自行按前向收费缴纳 GST。然而，GTA 必须在上一财政年度的 3 月 15 日或之前通过提交附件 V 中的声明来行使此选择权。
• 因此，2023-24 财年行使此选择权的截止日期为 2023 年 3 月 15 日。
• CBIC 已通过 2023 年 5 月 9 日发布的第 05/2023-中央税（税率）号通知，将 2023-24 财年的该截止日期延长至 2023 年 5 月 31 日。
• 该通知还规定，在任何财政年度内开展新业务或达到注册门槛的 GTA，可通过在以下日期中较晚的一个日期提交附件 V 中的声明来行使此选择权：
  • 申请 GST 注册之日起 45 天内；或
  • 获得注册之日起 1 个月内。