Understanding FORM GST RET-1A: The Amendment Return for GST RET-1

The GST Council had previously introduced a new return filing framework, which included a primary return known as FORM GST RET-1, supplemented by two annexures. Within this proposed system, FORM GST ANX-1 was intended for taxpayers to detail all outward supplies, inward supplies subject to reverse charge, and imported goods and services. Conversely, FORM GST ANX-2 was designed to record all inward supplies. The initial proposal required monthly filing for this new return, with an option for quarterly filing available to small taxpayers whose turnover did not exceed Rs. 5 crores. An update from March 14, 2020, indicated that this new GST return system would be implemented from October 2020, and the existing GSTR-1, 2A, and 3B system would remain active until September 2020, subject to official notification from the CBIC.

What is an Amendment Return?

A significant feature introduced in the proposed GST return filing system was the provision to amend a previously filed return. Historically, GST returns could not be directly amended; any mistakes or discrepancies typically required rectification through adjustments to specific invoices or details in subsequent monthly returns. Under the new proposal, however, taxpayers would be able to file FORM GST RET-1A to amend their original FORM GST RET-1.

Advantages of Filing Amendment Returns

The ability to file amendment returns offered several benefits:

• Amendments could be submitted for any tax period, whether monthly or quarterly, enabling prompt correction of identified errors.
• Any additional tax liability resulting from an amended return could be settled with the amendment itself. This proactive payment helped avoid interest charges on delayed payments, as corrections could be made within the same tax period.
• Taxpayers were permitted to file up to two amendment returns per tax period, providing flexibility and mitigating challenges caused by errors in either the initial or a prior amended return.

Amending Returns: Process and Frequency

Taxpayers could modify details in an amendment return that were manually entered in the primary return and not auto-populated. Any increased tax liability from an amended return, specifically GST RET-1A, could be paid when filing the amendment. However, no refunds would be issued through this process. Any resulting negative liability would be transferred to the subsequent tax period's main return. Taxpayers were allowed to file a maximum of two amendment returns for each tax period.

Components of FORM GST RET-1A

FORM GST RET-1A served as the amendment return for FORM GST RET-1, with a similar filing procedure. This form was structured into several key sections:

1. GSTIN: The taxpayer was required to enter their Goods and Services Tax Identification Number.

2. Basic Details: Essential information such as the trade name, legal name, Application Reference Number (ARN), and filing date would be automatically populated.

3. Amendments to Summary of Outward Supplies, Inward Supplies (Reverse Charge), and Tax Liability: It was understood that GST ANX-1A, the annexure for FORM GST RET-1A, would be considered filed once FORM GST RET-1A was submitted. The filing process for ANX-1A mirrored that of the original FORM GST ANX-1.

   No.	Description	Details
   A	Details of amendment to outward supplies	The system would auto-populate information from GST ANX-1A, including taxable supplies to consumers and unregistered persons, along with exports (both with and without tax payment). Taxpayers also needed to input liability from the period before this return system's introduction and any other liabilities.
   B	Details of amendment to inward supplies attracting reverse charge	Information on inward supplies subject to reverse charge and import of services would be auto-populated from GST ANX-1A.
   C	Details of amendment to adjustment of liability	Taxpayers were required to enter reductions in tax liability, such as those arising from transitioning from the composition levy to the normal levy.
   D	Details of amendment to supplies having no liability	Taxpayers needed to input details for exempt and NIL-rated supplies, non-GST supplies, outward supplies subject to reverse charge, and goods supplied by SEZ/developers to DTA on a bill of entry.
   E	Total value and tax liability	This represented the cumulative sum of values from sections A, B, C, and D.

4. Amendments to Summary of Inward Supplies for Claiming Input Tax Credit (ITC):

   No.	Description	Details
   A	Details of amendment to ITC based on auto-population from GST ANX-1A	Details such as inward supplies attracting reverse charge, import of services, import of goods, and imported goods from SEZ/developers would be auto-populated from GST ANX-1A. Taxpayers also needed to enter upward adjustments in input tax credit from credit notes and other reclaims or adjustments.
   B	Details of amendment to reversals of credit	Taxpayers were required to enter details for supplies not eligible for credit and reversals of ITC in accordance with relevant legal provisions (Rules 37, 39, 42, and 43).
   C	Net ITC available	This figure was calculated as the difference between the values in sections A and B.

   Note: Taxpayers had to separately declare input tax credit pertaining to capital goods and services, derived from the total net ITC in section C.

5. Interest and Late Fees: The system would automatically calculate specific liabilities: fees for amendments exceeding prescribed limits and interest due to an upward revision of tax liability. Taxpayers were responsible for self-assessing interest related to input tax credit reversals and any other applicable interest.

6. Payment of Tax: The tax payment process mirrored that of the main return, allowing the utilization of available Input Tax Credit from the electronic credit ledger to settle liabilities.

7. Verification: Before filing, taxpayers were required to verify all information provided in the tables and digitally sign the return. Submission was only possible after this verification.