GSTR-4 Yearly Return for Composition Taxpayers

Published At: 15-Sep-2020

All registered taxpayers who have opted for Composition Scheme under GST law are required to file a yearly return in Form GSTR-4 for each financial year starting from FY 2019-20 as per Notfn. No. 31/2019 CT dated 28th June 2019.

GSTR-4 is applicable to.. 

GSTR-4 is not applicable to..

Those dealers who have opted for composition scheme since registration and have never opted out subsequently

Regular taxpayer who have not opted in composition scheme for any period during the financial year

Those dealers who have opted in for composition scheme before starting of the financial year; and

Non-resident taxable persons,

Casual Taxable Person ,

Service providers under OIDAR / UIN holder

Those dealers who had opted in for composition scheme earlier but subsequently opted out at any time during the financial year

Persons required to Deduct Tax at Source u/s 51

Persons required to Collect Tax at Source u/s 52

Input Service Distributor

 

Note: For simplicity the Composition Scheme as mentioned in this article, includes dealers opting for composition scheme under section 10 of CGST Act (basically composition scheme for goods)  & the dealers who have opted composition scheme  as per Notfn. No. 02/2020-CTR dated 07th March 2019 (basically composition scheme for service providers other than those covered under section 10 of CGST Act). The dealers opting for composition scheme are also referred as Composition taxpayers.

The due date for filing Form GSTR-4 yearly return is 30th of the month succeeding the end of the financial year or as the date as is extended by the Government, from time to time.

*The Government has further extended the last date to file return in Form GSTR-4 for composition dealers for Financial Year 2019-20 to 31st October, 2020 from 31st August, 2020 vide Notfn. 64/2020-CT dated 31st August 2020.

Salient features of form GST-4 (Yearly Return)

1)    It is mandatory for all composition taxpayers to file Form GSTR-4.

2)    GSTR-4 once filed, cannot be revised

3)    The Composition Taxpayer must have filed all Form CMP-08 (statement for payment of self-assessed tax) on quarterly basis for the relevant financial year before filing the Form GSTR-4.

4)    Taxpayer can file Nil form GSTR-4 subject to the conditions that the taxpayer has not made any outward/inward supplies, has no other liability, has filed all Form CMP-08 as Nil.

5)    There is a late fee for filing of Form GSTR-4 (Annual Return) beyond the due date.

6)    After successfully filing, ARN will be generated and intimated through email and SMS.

 Form GSTR-4 (Yearly Return) Comprises of following tables & details  

Particulars

Particulars

4A. Inward supplies from registered supplier

      (other than liable to reverse charge): 

 

Amounts to be mentioned on consolidated basis- GSTIN –wise and rate wise.

4B. Inward supplies from registered supplier

      (liable to reverse charge):

4C. Inward supplies from unregistered supplier:

Amounts to be mentioned on consolidated basis- PAN–wise and rate wise.

4D. Import of Service

Amounts to be mentioned  on consolidated basis - rate wise

5. Summary of self-assessed liability as per Form GST CMP-08

This will be auto –populated & not editable

6. Tax rate wise details of outward supplies / inward supplies attracting reverse charge during the year

Details of tax rate wise outward supplies from Table 5 & details of tax rate wise inward supplies from the Tables 4B, 4C and 4D will get auto reflected in Table 6. 

7. TDS/TCS Credit received

TDS/TCS credit received from deductor/e-commerce operator would be auto-populated  in case of restaurant service providers under composition scheme u/s 10(1) r.w. section 10(2)(d)

8. Tax, interest, late fee payable and paid

This will be auto –populated.

9. Refund claimed from Electronic cash ledger

 

 

What is the difference between GSTR-4 (Quarterly Return) & GSTR-4 (Yearly Return)

Old Form GSTR-4 (Quarterly Return )

New Form GSTR-4 (Yearly Return)

Frequency - Quarterly.

Frequency – Yearly.

The old Form GSTR-4 was applicable upto 31st March 2019 on quarterly basis.

Applicable from 1st April 2019.

In this form the details of inward supplies from registered supplier other than reverse charge was not required to be filled i.e Sr no 4A

No such relaxation in this GSTR-4

 

APMH Comments

As per FAQ’s available on GST portal  it is mandatory to file GSTR-9A for composition taxpayers even if there is no turnover during the said period. However there is one pre-condition for filing GSTR-9A is that Taxpayer has filed all applicable returns, i.e., Form GSTR-4, quarterly return of the relevant financial year, before filing the Annual Return.  It should be noted that  w.e.f  FY 2019-2020, the old  GSTR-4 quarterly return  has been discontinued and  filing of statement in Form CMP-08 on quarterly basis and New GSTR-4 on Yearly basis has been introduced. Thus it appears that there is no purpose in filing GSTR-9A for 2019-20, but the Form still continues on statute and unless it is removed/excluded by way of specific notification, the liability to file GSTR-9A continues, leading to unwarranted duplication of efforts by the small dealers. Let’s hope that the Government clarifies the position at the earliest.

 

In the new GSTR-4 Yearly Return from FY 2019-20, the table nos.  4A & 4B require the rate wise details of inward supply from registered persons (GSTIN wise-mandatory)  & unregistered person ( Pan wise-optional).  However in the quarterly Forms CMP-08 such details were not required to be mentioned. This detailing may not have been maintained by such dealers who are generally small dealers and also it would be very difficult to compile and maintain such details rate wise, especially in cases where such dealers are dealing in variety of items. It should be noted that even in Form GSTR-9 the providing of rate wise details is made optional for regular tax payers, and similarly this option should also be provided to the composition taxpayers by the Government.

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