Additional Comments
It is important to note that GST Council in its 27 th Council Meeting held on 04.05.2018 has approved the principles for the new return design proposed by a Group of Ministers on IT simplification. According to the press release issued by Central Board of Indirect Taxes and Customs, it is recommended that there will be one single return to be furnished by taxpayer every month (except for composition taxpayer). Further uploading of invoices for outward supplies will be allowed on real time basis and the same will visible to the recipient as and when the invoice(s) is / are uploaded by the supplier.
The recommendations also state that for another six months, returns will have to be filed in Form GSTR 3B and GSTR 1. Input tax credit will be available to the recipient during this phase as well as for six months from the date of introduction of new return proposed on provisional basis i.e., on the basis of input tax credit availed by the recipient of supply in his return. However from the date of introduction of proposed return system, details of differences between credit availed by recipient of supply and amount of credit as per the invoices uploaded by the supplier will be made available to the recipient of the supply. After end of Phase 2 of introduction of new return system, availability of input tax credit on provisional basis will be withdrawn i.e., input tax credit will be available only when the invoice details is uploaded by the supplier i.e., purely on the matching concept basis.
Also, the proposed return system has taken into consideration unnecessary movement of input tax credit by suppliers who are defaulters of payment of taxes. Default beyond threshold amount will result in blocking of input tax credit to the recipient of supply from such default suppliers