Introduction:

The Central Government, through Notification No. 18/2022-Central Tax dated 28.09.2022, has made significant amendments to the provisions of the Finance Act, 2022, impacting the Goods and Services Tax (GST) compliance landscape. The amendments primarily focus on extending the time limit for specific compliances related to the financial year 2021-22. This article delves into the details of the amended provisions and their implications on the GST compliance timeline.

Extended Deadlines and Revised Provisions:

The amended provisions, effective from 01.10.2022, pertain to sections 100 to 114 of the Finance Act, 2022. Notably, the changes impact various sections of the CGST Act, 2017, and introduce new timelines for compliance. The key amendments are highlighted below:

1. Section 16(4) - Amendment to Claiming Input Tax Credit (ITC)

The revised provision restricts the entitlement to ITC for invoices or debit notes related to the supply of goods or services after the 30th day of November following the end of the financial year or the furnishing of the relevant annual return, whichever is earlier.

2. Section 34(2) - Declaration of Credit Notes

The amendment introduces a deadline for declaring credit notes related to the supply of goods or services. The details must be declared in the return for the month in which the credit note is issued but no later than the 30th day of November following the end of the financial year or the date of furnishing the relevant annual return, whichever is earlier.

3. Proviso to Section 37(3) - Rectification of Details

The proviso limits rectification of errors or omissions in details furnished under subsection (1) after the 30th day of November following the end of the financial year or the furnishing of the relevant annual return, whichever is earlier.

4. Proviso to Section 39(9) - Rectification of Omissions

Similar to Section 37(3), this proviso restricts the rectification of any omission or incorrect particulars after the 30th day of November following the end of the financial year or the actual date of furnishing the relevant annual return, whichever is earlier.

5.Analyzing the Impact on GST Filing Deadlines:

The amended provisions explicitly mention the date, i.e., 30th November, as the crucial deadline for various compliances. It is imperative to note that this date is not defined as the due date for filing the return for the month of November. This distinction is vital for understanding the extended timelines for compliance.

6. Last Date for Availment of Input Tax Credit (ITC):

  For monthly return filers, the last date for availing ITC based on invoices of the financial year 2021-22 is 20th November  

  2022, aligning with the due date of filing GSTR-3B for the month of October 2022.

  Quarterly return filers must consider the specific due dates depending on the state of registration, falling between 22nd

  or 24th October 2022.

7 Declaration of Credit Notes and Amendments in Value of Outward Supply:

 The last date for declaring credit notes pertaining to invoices raised in the financial year 2021-22 is 11th November 2022 (due date of GSTR-1 for October 2022). The adjustments must be reflected in GSTR-3B filed by 20th November 2022.

Amendments in the value of outward supply and related taxes for invoices raised in FY 2021-22 can only be made through GSTR-1 and GSTR-3B for October 2022. The respective due dates are 11th and 20th November 2022.

8.Clarifications from CBIC:

The Central Board of Indirect Taxes and Customs (CBIC) issued a press release on 4th October 2022, affirming that the specified compliances must be carried out in the relevant return or statement filed up to 30th November 2022 of the subsequent financial year. Importantly, the press release clarified that there would be no extension in the due date for filing returns for October 2022.

Conclusion:



In conclusion, the amendments introduced through Notification No. 18/2022-Central Tax have a profound impact on the GST compliance timeline for the financial year 2021-22. Businesses and professionals must diligently adhere to the extended deadlines for availing ITC, declaring credit notes, and making amendments in the value of outward supply. The nuanced understanding of these deadlines is crucial for ensuring seamless compliance with the revised provisions.