Understanding Credit and Debit Note Declaration in GST Returns

The Goods and Services Tax (GST) system aimed to simplify tax return filing through a new return mechanism, though its implementation was later suspended. Credit and debit notes play a crucial role in maintaining transparent invoicing between parties under GST. These financial instruments are also significant for accurate reporting in GST returns. This article will examine how credit and debit notes were intended to be reported under the proposed, but now suspended, new GST return system, comparing it with the existing framework.

Current Credit and Debit Note Reporting in GST Returns

Under the current system, credit and debit notes are reported in GSTR-1 on the GST portal. The reporting process varies based on the recipient type:

• For Unregistered Persons (B2C Supplies): These notes are declared in Table 9B – Credit/Debit Notes (Unregistered). The required details include the debit/credit note number, original invoice number and date, type (debit note, credit note, or refund voucher), value, and an indication if the supply qualifies for a differential tax rate as per government notification.
• For Registered Persons (B2B Supplies): These are reported in Table 9B – Credit/Debit Notes (Registered). Information such as the receiver's GSTIN, debit/credit note number and date, original invoice number and date, type, value, and supply type (interstate or intrastate) must be provided. It also requires indicating if the supply is eligible for a differential tax rate.

Credit and Debit Note Declaration in the Proposed New GST Return System

Under the proposed new GST return system, credit and debit notes were to be reported in Form GST ANX-1. This reporting mechanism included:

• For Unregistered Persons (B2C Supplies): Taxpayers were required to report these in Table 3A: Supplies made to consumers and unregistered persons (net of debit/credit notes). This table explicitly states that supplies should be declared net of any debit or credit notes. As these relate to B2C transactions, invoice-level declaration was not necessary. Information required included place of supply, tax rate, taxable value, and tax amounts for IGST, CGST, SGST, UTGST, and Cess.
• For Registered Persons (B2B Supplies): Details for these notes were to be provided in Table 3B: Supplies made to registered persons (excluding reverse charge, including edits/amendments). Unlike B2C supplies, these were not declared on a net basis, as declaration was required at the invoice level. Specifics to be provided included GSTIN/UIN, place of supply, document type, credit/debit note number, date, value, HSN Code, tax rate, taxable value, and tax amounts for IGST, CGST, SGST, UTGST, and Cess. To report a credit or debit note, it had to be selected from a 'Document Type' dropdown. A key difference from the existing system was that while the current system has a separate table for registered person credit/debit notes, the new system integrated these declarations into the same table used for outward supplies.

Impact of Proposed Changes in the New GST Return System

A primary change concerning credit note reporting in the new GST return framework was the elimination of a dedicated table for them. Instead, this information was to be integrated into the tables for declaring outward supplies.

• For Unregistered Persons (B2C Supplies): Details of outward supplies in Table 3A were required to be reported net of credit or debit notes. Since invoice-level declaration was not part of this table, individual credit notes did not need separate reporting. The annexure also permitted negative figures if the value of credit notes surpassed the value of outward supplies in a given tax period. While the current system mandates linking credit/debit notes to their original invoices, the proposed new system removed this requirement within the return.
• For Registered Persons (B2B Supplies): The outward supply details in Table 3B were to be provided at the invoice level, necessitating individual declaration of each credit or debit note with all relevant information. Similar to B2C supplies, the linking of credit/debit notes to original invoices was not a requirement in this proposed system.

Practical Example of Credit and Debit Note Reporting

Consider a scenario where Mr. A sold goods to Mr. B (an intra-state transaction) on May 1, 2019, for a taxable value of Rs. 10,000. GST was applied at 18% (9% CGST and 9% SGST). The invoice details were:

By August 1, 2019, Mr. B discovered that goods valued at Rs. 2,000 (excluding GST) were defective and requested a credit note from Mr. A. After verification, Mr. A issued a credit note for Rs. 2,000, which included CGST of Rs. 180 (9%) and SGST of Rs. 180 (9%). Assuming both parties are registered, Mr. A would report this as follows in Table 3B of Form GST ANX-1 for September: