Gst Late Fee Reduction And Time Limit Extension

Recently, on 21

st September 2020, the Central Board of Indirect Taxes and Customs issued three notifications. The notifications cover late fee reduction in case of Form GSTR-4 (i.e., return to be filed by composition scheme dealer) and Form GSTR-10 (i.e., final return) and extension of the time limit in a specified case. The current article highlights the gist of all three notifications.

Late Fee Reduction for the delay in filing of Form GSTR-4

The taxable person who has opted for the composition scheme is required to file an annual return in Form

GSTR-4. Vide notification no. 67/2020- Central Tax dated 21st September 2020, the late fees payable for delay in filing of Form GSTR-4 is reduced as under-

Particulars	Applicable Tax Period	Late fees payable
No tax liability (i.e. NIL return)	July 2017 to March 2020	NIL
Any other case	July 2017 to March 2020	Maximum INR 500 per return (INR 250 CGST + INR 250 SGST)

Notably, the above reduction is available only if the taxable person furnishes the delayed return within the period 22

nd September 2020 to 31st October 2020.

Late Fee Reduction for the delay in filing of Form GSTR-10

The taxable person whose GST registration is either surrendered or cancelled is liable to file final return in Form GSTR-10. GST return in Form GSTR-10 is to be filed within later of the following periods-

Three months from the date of cancellation or
Three months from the date of cancellation order.

Vide notification no. 68/2020- Central Tax, the late fees for delay in filing of Form GSTR-10 is capped to maximum INR 500 (INR 250 CGST + INR 250 SGST). However, the reduction is available only to the taxable person who furnishes the delayed return within the period 22

nd September 2020 to 31st December 2020.

Extension of the time limit in specified case

Vide notification no. 66/2020- Central Tax dated 21

st September 2020, the Central Board of Indirect Taxes and Customs has extended the time limit for issuing an invoice in respect of goods being sent/ taken out of India on approval for return or sale. The extension is provided for the period 20th March 2020 to 30th October 2020. In the specified case, the time limit for issuing invoice is extended to 31st October 2020.

Synopsis of notifications issued on 21st September 2020

Notification No.	Applicable to	Period Covered	Relief offered	Conditions (if any)
Notification no. 66/2020	Person liable to issue an invoice in respect of goods being sent or taken out of India on approval for sale/ return	20th March 2020 to 30th October 2020	The time limit for issuing invoice extended to 31st October 2020	NIL
Notification no. 67/2020	Composition Scheme Dealer	July 2017 to March 2020	Late fee reduced to NIL in case of no tax liability. Late fee reduced to INR 500 in any other case	Pending returns are to be filed within the period 22nd September 2020 to 31st October 2020.
Notification no. 68/2020	A person whose GST registration is cancelled or surrendered	_	Late fee payable capped to maximum INR 500.	Pending return is to be filed within the period 22nd September 2020 to 31st December 2020.

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Frequently Asked Questions

Common questions about GST Late Fee Reduction and Time Limit Extension.

Answer: Vide notification no. 67/2020, the late fee payable for delay in filing Form GSTR-4 (annual return for composition scheme dealers) has been reduced. If there is no tax liability (i.e., a nil return), there will be no late fee. For cases with tax liability, the maximum late fee has been capped at Rs. 500 (Rs. 250 CGST + Rs. 250 SGST) per return.

Answer: The late fee reduction for Form GSTR-4 is available only if the delayed return is furnished between 22nd September 2020 and 31st October 2020. If the return is filed after this period, the normal late fee provisions will apply.

Answer: As per notification no. 68/2020, the late fee payable for delay in filing Form GSTR-10 (final return) has been capped at a maximum of Rs. 500 (Rs. 250 CGST + Rs. 250 SGST). This reduced late fee is applicable only if the delayed return is filed between 22nd September 2020 and 31st December 2020.

Answer: Form GSTR-10 is the final return that needs to be filed by a taxable person whose GST registration has been either surrendered or cancelled. It is required to be filed within three months from the date of cancellation or the date of cancellation order, whichever is later.

Answer: Notification no. 66/2020 has extended the time limit for issuing invoices in respect of goods being sent or taken out of India on approval for sale or return. The time limit for issuing such invoices has been extended to 31st October 2020 for the period from 20th March 2020 to 30th October 2020.

Answer: Yes, there is a specific condition to avail the late fee reduction for both Form GSTR-4 and Form GSTR-10. For GSTR-4, the delayed return must be filed between 22nd September 2020 and 31st October 2020. For GSTR-10, the delayed return must be filed between 22nd September 2020 and 31st December 2020.

Answer: Form GSTR-4 is an annual return that needs to be filed by taxable persons who have opted for the composition scheme under GST. It is a summarized return that consolidates the quarterly or monthly returns filed by the composition scheme dealer during the financial year.

Answer: Yes, the late fee reduction for Form GSTR-4 and Form GSTR-10 is applicable for the tax periods from July 2017 to March 2020. However, the specific conditions mentioned in the notifications must be met to avail the reduced late fee.

Answer: The extension provided in notification no. 66/2020 is significant as it provides relief to businesses that were unable to issue invoices for goods sent or taken out of India on approval for sale or return during the COVID-19 pandemic period. It gives them additional time to comply with the invoicing requirements.

Answer: No, the three notifications issued on 21st September 2020 cover only the late fee reduction for Form GSTR-4 and Form GSTR-10, and the extension of the time limit for issuing invoices for goods sent/taken out of India on approval for sale or return. No other reliefs or extensions have been mentioned in these notifications.