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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 21^st 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 31^st 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 31^st 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 20^th March 2020 to 30^th October 2020.

In the specified case, the time limit for issuing invoice is extended to 31^st October 2020.

Synopsis of notifications issued on 21^st 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.