GST Compliances for the period of 2017-18 needs to be done before Sep 2018
There are certain key aspects which should be considered for compliance pertaining to the period of 2017-18 from GST perspective.
It is suggested that a company should keep in consideration the below mentioned points:

Issuance of credit and debit notes

Statutory References

• The time-limit for issuance of a credit note is laid down by Section 34(2) of the CGST Act. As per Section 34(2) of the CGST Act credit note for the Financial year must be disclosed by the registered person but not later than September following the end of thefinancial year in which such supply was made, or the date of furnishing of the relevantannual return, whichever is earlier. The aforesaid provision categorically mandates that credit notes for a financial year must be disclosed by a registered person by theearlierof the following timelines :

(a) 30^thday of September following the end of financial year; or
(b) date of filing the annual return

• Thus, credit notes for the F.Y. 2017-2018 cannot be issued beyond30 September 2018for the purpose of claiming a reduction in output tax liability;

Advise

It is recommended that any issues in the supplies provided by vendors or invoices issued by such vendors are highlighted to the concerned party at the earliest so that credit note or debit note can be adjusted before 30th September.

• Section 34(2) of the CGST Actdoes not restrict commercial settlements (i.e. issuance of credit / debit note without levy of tax) with the customers post the cut-off date. However, claiming any benefit vide reduction in output tax liability by the supplier and consequent reduction in the input tax credit of the recipient shall be restricted.

Claim of Input tax credit

Statutory References

• The conditions for claiming input tax credit restrict the availment of credit for a financial year beyond the following date :

• 30^thday of September of succeeding financial year
• date of filing annual return

whichever isearlier

• Thus, the credit pertaining to the F.Y. 2017-2018 can be disclosed latest in the periodic return for the period September 2018

Advise

• Thus, it is advisable that assessee make communications with their vendors directing them to submit all invoices pertaining to F.Y. 2017 -2018 at the earliest considering the aforesaid time-lines. It is also recommended that a stringent deadline is circulated to vendors beyond which assessee opt not to accept invoices pertaining to the preceding financial year as it will be loss of credit for assessee.

• It shall be prudent to direct relevant internal teams, involved in the procurement/ accounting to expedite internal controls in respect of such invoices for F.Y. 2017-2018 that have been received but are yet to be accounted/verified for claiming credit at the earliest

Amendment of invoices

Statutory References

• In case of error in reporting any outward supply transaction (for instance incorrect GSTIN, incorrect taxable/ tax amount, incorrect POS), the assesse has an opportunity to amend the same in the outward supply return

• The provisions governing the filing of returns permit the rectification of any omissions or incorrect particulars till the 30^thSeptember of the succeeding year (Refer proviso to Section 37(3), proviso to Section 38(5) and proviso to Section 39(9) of the CGST Act, 2017)

Advise

• Thus, it is imperative thatAmendment of invoices of outward supplies reported in the F.Y. 2017-2018 are addressed latest by30 September 2018:
• Amendment of invoices of outward supplies reported in the F.Y. 2017-2018
• Amendment of invoices reported by the vendor in their outward supply return for the F.Y. 2017-2018

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