The deadline for first GST Return, GSTR- 3B, has been extended (states are still coming up with Notifications) to August 28 from its original deadline of August 20. However, one must keep in mind that this is only for taxpayers who opt to use the opening balance of pre-GST credit in the current month. Those who do not wish to claim opening credit in the current month or those who have no credit; the deadline continues to be August 20.

The extended deadline also allows the taxpayers to file form TRAN 1 by August 28, which is a pre requisite as per the strict interpretation of law to claim the opening credit.

“Interestingly, TRAN 1 filing system is not up and running yet on GST portal. The industry raised the working capital issue as without filing TRAN 1 they could not have taken the benefit of the opening credit, resulting in adverse cash flow impact in the first month of GST implementation,” says KPMG India, Partner, Priyajit Ghosh.

The other key points to note are as follows:

a) The extended deadline would also help GST portal to ready itself for implementing TRAN 1 filing system.

b) Considering the elaborate reporting requirements under TRAN 1, the window of 8 days appears to be far less for the tax payers.

c) There is no clarity on revision of TRAN 1 and there would be interest implications in case of excess credit claim hence, most taxpayers would avoid hasty filing of TRAN 1, even after extension of timeline. It seems most have braced up for the adverse cash flow position already.

However, businesses are unsure if the extension of eight days is enough. TRAN 1 is a fairly complex form and something that businesses have never dealt with. Input credit as a mechanism is also a new concept and it may take some time for businesses to come to grips with it.

“It is a much awaited notification for the industry as it was not clear as to whether opening input credit can be claimed while filing GSTR 3B. Now, the businesses will be able to claim opening credit by filing TRAN 1 before 28th August, which is the revised due date for filing GSTR 3B. However, since GST has to be paid by August 20th, businesses will have to determine the opening credit beforehand. It is not clear, however, as to whether TRAN 1, once filed, can be revised later,” said PwC, Partner and Leader Indirect Tax, Pratik Jain in a statement.