Challenging Case Studies.
Research Document Studies.
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
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 ,
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
Persons required to Deduct Tax at Source u/s
Persons required to Collect Tax at Source u/s
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
It is mandatory for
all composition taxpayers to file Form GSTR-4.
GSTR-4 once filed, cannot
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
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.
There is a late fee
for filing of Form GSTR-4 (Annual Return) beyond the due date.
filing, ARN will be generated and intimated through email and SMS.
Form GSTR-4 (Yearly Return) Comprises
of following tables & details
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
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
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.
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 )
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
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
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.
Please feel free to write to us on [email protected] / [email protected] for any further queries on the above blog.
Please feel free to get in touch with us if you have any questions or would like more information on our services.