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GST Check-list you need to tick as stepping in new Financial Year

CA. Sachin Jindal

9 April 2024

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As we are stepping into the new Financial year, there are various compliance requirements which a taxpayer is required to do with the changing year. Any non-compliance on part of the taxpayer can lead to major disallowances or withdrawal of benefits from the taxpayer.
This article list down check-list which a taxpayer is required to tick as they enter into new financial year:

1. Filing of Letter of Undertaking (LUT) to export without payment of IGST

• As per Rule 96A of Central Goods and Service Tax rules, 2017, any registered person, who intends to avail option to export goods and services without payment of IGST, shall file an undertaking in Form GST RFD-11.
• Form GST RFD-11 is required to file prior to date of export made without payment of IGST.
• If an exporter fails to file GST RFD-11 then he shall not be allowed to export without payment of IGST. He can export goods and services on payment of IGST and later on can claim refund of such IGST.
• GST RFD-11 is filed on yearly basis and is valid till 31st March of the Financial year to which it pertains.
• Therefore, to export goods and services without payment of IGST, all taxpayers are required to file GST RFD-01 for FY 2024-25.

2. Commencement of New Invoice Series

• As per Rule 46(b) of CGST Rules, invoice invoice is required to be a consecutive serial number not exceeding sixteen characters.
• Further, a invoice number should be unique for a financial year.
• Therefore, most taxpayers generally use a separate invoice series for every financial year to avoid any duplication or repetition of invoice from preceding Financial year.
• All taxpayers are required to note that they commence a new series with a changing financial year.

3. Reconciliation of Output Liability under GST for FY 2023-24

• Assessments proceeding of FY 2018-19 against show Cause notice, issued in Form GST DRC-01, are going on and most of the taxpayers have received show cause notice because of difference in turnover and tax liability declared in GSTR-1, GSTR-3B and GSTR-9.
• WIth the close of Financial Year 2023-24, the taxpayers are now required to reconcile turnover declared in GSTR-1, GSTR-3B and turnover as per books of accounts.
• Through reconciliation, taxpayers can identify:
  • Invoices recorded in books of accounts but not reported in GST return;
  • Invoices reported in GSTR-1 and later on amended in books of accounts;
  • GST Liability reported in GSTR-1 and not paid in GSTR-3B;
  • Correction in Invoice details such as invoice number, date, GSTIN of recipient etc.
• The taxpayers can file necessary amendments in GSTR-1 and GSTR-3B of FY 2024-25 by the due dates.

4. Reconciliation of Input Tax Credit appearing in GSTR-2B and Books of Accounts for FY 2023-24

• There are various suppliers who collect GST on invoice but fail to report the same in GSTR-1 or report the same on GSTIN of some other recipient. Therefore, such ITC against such invoice shall not be available to the recipient.
• Therefore, with commencement of new financial year, all taxpayers are required to prepare reconciliation of ITC appearing in GSTR-2A on GST Portal and ITC recorded in Books of accounts.
• Through such reconciliation, the taxpayer can identify:
  • Invoices recorded in Books but the same are not appearing in GSTR-2A;
  • Invoices appearing in GSTR-2A but not recorded in books, i.e., Invoice of some other person is uploaded on GSTIN of some other person;
  • Difference in Invoice amount 

• Taxpayers are required to identify such invoices and take necessary action such as requesting suppliers to file suitable amendments in GSTR-1 or upload invoice on GST portal.
• Further, if any ITC is appearing on GST portal and not claimed by the taxpayer while filing GSTR-3B then the supplier can claim the same by 30th November of FY 2024-25.

5. Filing of ITC-04 for Goods send for Job Work for FY 2023-24

• ITC-04 is a statement furnished by the principal (person sending goods for job work) wherein following information is given:
  • Details of Goods sent for job work during the period;
  • Goods received back from job worker;
  • Goods received back from job worker, other than the job worker to whom goods were initially sent;
  • Goods sent for job work but subsequently supplied from the premises of the job worker.

• GST ITC-04 is required to be furnished on half yearly or yearly basis depending on the aggregate turnover of the taxpayer.
• For both, half yearly and yearly filers, due date of filing of GST ITC-04 is 25th April, 2024 for FY 2023-24.
• With the close of the financial year, the taxpayers are required to prepare information to be furnished in GST ITC-04.