Recently due to pandemic we had seen conditional waiver of interest and late fees for filing of GSTR 1 and GSTR 3B wherein due dates were extended. The extended due dates for GSTR 3B during first half of 2021 for different type of taxpayers are as under:
| FORM GSTR-3B | ||||||
| TAXPAYERS HAVING AGGREGATE TURNOVER > RS. 5 CRORES IN PRECEDING FINANCIAL YEAR | ||||||
| Tax Period | Due date | Extended Due Date | Interest for late payment of tax in GSTR 3B | Late fees waived if return filed on or before* | ||
| No interest payable till | Interest payable @ 9% p.a. for below period | Interest payable @ 18% p.a. after | ||||
| Mar, 2021 | 20th Apr, 2021 | Not available | Not Applicable | 21st Apr to 05th May, 2021 | 06th May, 2021 | 05th May, 2021 |
| Apr, 2021 | 20th May, 2021 | Not available | Not Applicable | 21st May to 04th June, 2021 | 05th June, 2021 | 04th June, 2021 |
| May, 2021 | 20th June, 2021 | Not available | Not Applicable | 21st June, 2021 to 05th July, 2021 | 06th July, 2021 | 05th July, 2021 |
TAXPAYERS HAVING AGGREGATE TURNOVER UPTO RS. 5 CRORES IN PRECEDING FINANCIAL YEAR
Taxpayers who have opted for QRMP (Quarterly Return Monthly Payment) Scheme and are registered in following states – Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, Daman & Diu and Dadra & Nagar Haveli, Puducherry, Andaman and Nicobar Islands, Lakshadweep:
| Tax Period | Due date | Extended Due Date | Interest for late payment of tax in GSTR 3B | Late fees waived if return filed on or before | ||
| No interest payable till | Interest payable @ 9% p.a. for below period | Interest payable @ 18% p.a. after | ||||
| Jan to Mar, 2021 | 22nd Apr, 2021 | Not available | 07th May, 2021 | 08th May, 2021 to 21st June, 2021 | 22nd June, 2021 | 21st June, 2021 |
| Apr, 2021 (Form GST PMT-06) | 25th May, 2021 | Not available | 09th June, 2021 | 10th June, 2021 to 09th July, 2021 | 10th July, 2021 | Not Applicable |
| May, 2021 (Form GST PMT-06) | 25th June, 2021 | Not available | 10th July, 2021 | 11th July, 2021 to 25th July, 2021 | 26th July, 2021 | Not Applicable |
Taxpayers who have opted for QRMP (Quarterly Return Monthly Payment) Scheme and are registered in following states – Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand, Odisha, Jammu and Kashmir, Ladakh, Chandigarh, Delhi:
| Tax Period | Due date | Extended Due Date | Interest for late payment of tax in GSTR 3B | Late fees waived if return filed on or before | ||
| No interest payable till | Interest payable @ 9% p.a. for below period | Interest payable @ 18% p.a. after | ||||
| Jan to Mar, 2021 | 24th Apr, 2021 | Not available | 09th May, 2021 | 10th May, 2021 to 23rd June, 2021 | 24th June, 2021 | 23rd June, 2021 |
| Apr, 2021 (Form GST PMT-06) | 25th May, 2021 | Not available | 09th June, 2021 | 10th June, 2021 to 09th July, 2021 | 10th July, 2021 | Not Applicable |
| May, 2021 (Form GST PMT-06) | 25th June, 2021 | Not available | 10th July, 2021 | 11th July, 2021 to 25th July, 2021 | 26th July, 2021 | Not Applicable |
TAXPAYERS HAVING AGGREGATE TURNOVER UPTO RS. 5 CRORES IN PRECEDING FINANCIAL YEAR
| Taxpayers not under QRMP (Quarterly Return Monthly Payment) Scheme: | ||||||
| Tax Period | Due date | Extended Due Date | Interest for late payment of tax in GSTR 3B | Late fees waived if return filed on or before* | ||
| No interest payable till | Interest payable @ 9% p.a. for below period | Interest payable @ 18% p.a. after | ||||
| Mar, 2021 | 20th Apr, 2021 | Not available | 05th May, 2021 | 06th May, 2021 to 19th June, 2021 | 20th June, 2021 | 19th June, 2021 |
| Apr, 2021 | 20th May, 2021 | Not available | 04th June, 2021 | 05th June, 2021 to 04th July, 2021 | 05th July, 2021 | 04th July, 2021 |
| May, 2021 | 20th June, 2021 | Not available | 05th July, 2021 | 06th July, 2021 to 20th July, 2021 | 21st July, 2021 | 20th July, 2021 |
However, there has been some extension in due dates for filing GSTR 1 for first half of 2021 and other such returns which are as under:
Extension in Due Dates:
| Form | Tax Period | Due Date | Extended Due Date |
| GSTR-1 | April, 2021 | 11th May, 2021 | 26th May, 2021 |
| May, 2021 | 11th June, 2021 | 26th June, 2021 | |
| IFF | April, 2021 | 13th May, 2021 | 28th May, 2021 |
| May, 2021 | 13th June, 2021 | 28th June, 2021 | |
| ITC-04 | Jan to Mar, 2021 | 25th Apr, 2021 | 30th June, 2021 |
Now if you look at the above table government has extended due date for GSTR 1 for the month of May 2021 upto 26th June 2021 but the due date for GSTR 3B for taxpayer with turnover above Rs. 5 crore is still 20.06.2021. Hence, if they go to file GSTR 3B within due date, their GSTR 2B won’t be generated and which might give an error if someone claims credit.
Further, although late fees has been waived for GSTR 3B but still interest could be charged if tax not paid within 15 days from original due date so which again raises a question that can someone fulfill his liability to pay tax under GST just by depositing tax with government in cash ledger or filing GSTR 3B is considered as payment of tax?
Disclaimer: The views presented in the above article are personal views of our team and has no legal binding. For any legal opinion consult a tax professional.
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