Proposed changes in GST Return filing

Source: The Economic Times     Jan 23, 2018

In its last meeting, the GST Council deliberated changes in the filing regime for the new tax. The simplified system is expected to be approved by the Council in its next meeting. ET explains the likely scenario: 


1. Seller to upload invoice level details in GSTR 1 within prescribed due dates 

2. Buyer to download invoice details uploaded by seller (in Form GSTR 2A) 

3. Buyer to reconcile the GSTR 2A details with ERP purchase register 

4. Buyer to take action (Accept/reject/modify) on GSTR 2A invoices. Buyer also has option to upload invoices if not uploaded by vendor - this activity is done by buyer through filing of monthly GSTR 2 within prescribed due dates 

5. Seller and buyer to file monthly GSTR 3/3B to disclose liability, credits and pay taxes

6. GSTN to perform reconciliation of data uploaded by buyer and share mismatch report 

7. Seller and buyer to take relevant action on the mismatches 


1. Seller has option to upload invoices on real time basis 

2. Buyer can view the invoices uploaded by multiple sellers on the portal 

3. Buyer to accept the invoices to claim credits 

4. Seller to disclose output liabilities in GSTR 3B based on invoices uploaded 

5. Credit to be restricted for the buyer in GSTR 3B to the extent of invoices accepted 

6. Buyer to claim credit/ report transaction w.r.t unregistered suppliers/RCM in GSTR 3B 

7. Buyer would not have option to claim credit for any invoice not uploaded by seller 

8. GSTN would not perform any reconciliation for the data uploaded as credit restricted to invoices accepted 

Concept of invoice matching continues but at the end of buyers and sellers, without it being part of the return process and work flow based system envisaged earlier. This would effectively mean greater onus on businesses to ensure compliance of vendors. It needs to be ensured the new system does not entail more physical scrutiny at the time of assessment or audit and dilute the concept of 'faceless' tax administration that we were all hoping for: Pratik Jain, Leader - Indirect Tax, PwC.