Missed filing GSTR-3B for the previous two return period? From 1st January, 2022, the GSTR-1 return filing facility will be blocked for you. It was originally planned for September 2021, but with the latest GST council meeting, the implementation of the rule is postponed to 1st January,2022.
The rule also includes blocking of invoice furnishing facility (IFF) on the portal for businesses who have opted QRMP scheme. The return blocking rule intends to ensure that GST returns are filed on time and there is no delay in the filing process. This rule is in continuation of blocking of an e-way bill generation facility, effective from 15th August,2021.
Blocking of GSTR-1 return filing facility
From 1st January, 2022, the GSTR-1 return filing facility will be blocked if you have not submitted the return in FORM GSTR-3B for the previous two return period. In simple words, starting from 1st January,2022, taxpayers will not be able to file GSTR-1 or use the IFF for December,2021 on the GST portal if they have pending GSTR-3B filing.
This restriction is applicable to both monthly return filing as well as quarterly filing. If you are filing returns monthly, the last two months would be considered. For example, if a taxpayer has not filed GSTR-3B for October,2021 and Novomeber,2021, the GSTR-1 filing facility will be blocked from the 1st January,2022.
| Blocking of e-Way Bill generation Facility for Non-filing of GST Returns | Best GST Software for GST Return Filing and GST Billing |
In the case of quarterly returns, the previous two quarters will be considered. Here, along with restrictions to file GSTR-1, even the invoice filing facility (IFF) would be blocked. For example, if you have missed filing GSTR-3B for Apr-Jun and Jul-Sep quarters, the above-mentioned facility will be blocked in the portal from the subsequent month, starting from January,2022.
Returns considered for blocking GSTR-1 filing facility
On implementation of the above rule, before the filing of GSTR-1/IFF for a tax period, the system will check whether the following has been filed or not:
- GSTR-3B for the previous two monthly tax periods (for monthly filers)
- GSTR-3B for the previous two quarters (for quarterly filers)
Based on the status of the previous two returns, the system will restrict the filing of GSTR-1/IFF until the taxpayer complies with the rule.
How does blocking of GSTR-1 rule work?
Once the new rule of blocking GSTR-1 facility is implemented, the portal will have an additional check to verify the status of the previous two returns. This check will operate on clicking the ‘SUBMIT’ button of GSTR-1 and the system will give an error message if returns for the previous two tax periods are not filed.
Since the system checks and restricts filing after clicking submit button, the details/records which have been entered in GSTR-1 will remain saved. Once you have complied with the above rule, you can use the same details and submit the return.
This is rule works similar to blocking & unblocking of e-way bill facility. The blocking and unblocking are completely automated. The portal will automatically block the facility if GSTR-3B is not filed for two previous return periods. In the same way, it will restore the facility as soon you comply with the provision i.e., after filing of GSTR-3B for the relevant tax period. No separate approval would be needed from the tax officer to restore the facility.
In the advisory issued on the portal, the government recommends taxpayers who have not filed their pending GSTR-3B, especially from the period November 2020 and afterwards, may do so at the earliest to ensure no disruption in filing GSTR-1/IFF.
Business impact on blocking of GSTR-1 or IFF failing facility
As we all know, GSTR-1 is a statement in which all the outward supplies need to be furnished. Based on the outward supplies you declare; the GST system will auto-populate these details in the counterparty’s GSTR-2A and GSTR-2B. These are the two key statements based on which the businesses can avail the input tax credit.
Now, when you apply the restriction on filling facilities, the impact on business is huge. When you are blocked from filing GSTR-1 or invoices on the portal, will result in non-reflection of the transaction in the counterparty’s GSTR-2A and GSTR-2B. Non-reflection will result in denial of input tax credit to your customer. Does it impact me as a supplier? Yes, it does. If you are not compliant, you might lose your customers. Similarly, if your supplier is not compliant, he might lose you.
With the implementation of this rule, vendor management will again play a very crucial. The vendor’s GST compliance adherence will be one of the enabling factors for you to claim the input tax credit. Because of this, the business behavior is expected to change where the buyers may prefer to do the business with the suppliers who are GST compliant.
As a preparation towards this new rule, ensure that GSTR-3B returns for previous tax periods are filed. Also, re-look at your current vendors, review and identify compliant vendors.
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