India: GST Update: Notification Of GST Audit Form, TDS And TCS Provisions Notified, Extension Of Due Dates And Waiver Of Late Fees

Last Updated: 20 September 2018
Article by SKP  

GST Audit Form Notified

The government vide Notification No. 49/2018-Central Tax dated 13 September 2018 has notified the reconciliation statement to be certified by the auditor, whereby, the taxpayer is required to provide a reconciliation between the audited financial statements and the annual return i.e. GSTR-9. Key items in respect of which reconciliation is to be provided are:

  • Gross turnover;
  • Taxable turnover;
  • Tax paid and rate wise liability;
  • Net input tax credit.

The relevant notification can be accessed here.

TDS Provisions Notified

The government vide Notification No. 50/2018-Central Tax dated 13 September 2018 has notified 1 October 2018 as the date for bringing into force provisions requiring government departments, local authorities etc. to deduct tax at source at the rate of 2% from payment made or credited to the supplier of taxable goods or services under a contract exceeding INR 0.25 million. The government has also notified the list of certain additional entities which would have to comply with the TDS provisions including:

  • Public sector undertakings;
  • Society established by the Central Government or the State government or a local authority under the Societies Registration Act, 1860 etc.

TCS Provisions Notified

The government vide Notification No. 51/2018-Central Tax dated 13 September 2018 has notified 1 October 2018 as the date for bringing into force provisions requiring e-commerce operators to collect tax at source on supplies made through it by other suppliers at the rate not exceeding 2%.

Extension of Due Dates of the GST Returns

The government has issued notifications to extend the due dates of certain GST returns, which have been summarized below:




Revised due date

43/2018 - Central Tax dated 10 September 2018

GSTR 1 (Quarterly) - Taxpayers having an aggregate turnover of up to INR 15 million

All quarters from July 2017 to September 2018

31 October 2018

October 2018 to December 2018

31 January 2019

January 2019 to March 2019

30 April 2019

44/2018 - Central Tax dated 10 September 2018

GSTR 1 (monthly) - Taxpayers having an aggregate turnover of more than INR 15 million

All months from July 2017 to September 2018

31 October 2018

All months from October 2018 to March 2019

11th of the succeeding month

48/2018 - Central Tax dated 10 September 2018

GST TRAN 1 - Carry forward of CENVAT credit


31 March 2019

GST TRAN 2 - Carry forward of CENVAT credit by a person not having duty paid document (and who are filing GST TRAN 1 as per the revised due date)

July 2017 to December 2017 (monthly)

30 April 2019

Waiver of Late Fees

The government, vide  Notification No. 41/2018-Central Tax dated 4 September 2018, has waived late fees that are paid by certain taxpayers under the following special circumstances:


Issues faced by the taxpayers


Return for the month of October 2017 was submitted but not filed on the common portal, after generation of the application reference number.


Return for the period October 2017 to December 2017 was filed within due date but the late fee was erroneously levied on the common portal.


Input service distributor who has paid a late fee for filing or submission of the return for any tax period between 1 January 2018 to 23 January 2018.

SKP's Comments

  • The government has notified the format of much awaited GSTR-9C through which the taxpayers would have to provide a reconciliation between GST returns and the audited financial statements. Businesses should begin preparing these reconciliations immediately to avoid possibilities of qualifications by the auditor.
  • The number of GSTR-3B filed across the country is substantially higher than the number of GSTR-1 filed. In view of this, the government has extended the due date for filing of GSTR-1 as a one-time relief to the taxpayers to ensure compliance with the GST law.
  • A number of petitions were being filed by various taxpayers in High Courts across the country praying for relief, in the form of an extension of due dates for filing GST TRAN-1 and GST TRAN-2 in view of the technical difficulties faced by them. In order to reduce litigation, the government has granted a blanket extension to all taxpayers to carry forward their transitional credits.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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