Answer

GST

GSTR-3A for composition dealers

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  1. Facts

    For composition dealers, GSTR-3A usually relates to GSTR-4, the annual return under Sec 39(2). Check whether all CMP-08 statements and GSTR-4 are filed.

  2. Provisions and law

    • Sec 46, CGST Act 2017A registered person who fails to file a return under Sec 39, 44, 45 or 52 gets a notice to file within 15 days
    • Sec 39(2), CGST Act 2017Composition taxpayers file a return for each financial year
    • Sec 47, CGST Act 2017Late fee for late returns
  3. Analysis

    The GSTR-4 FAQ notes that the return cannot be filed until all CMP-08 statements for the year are filed. So start with the missing CMP-08s, then GSTR-4. Example: CMP-08 for Q3 not filed and GSTR-4 not filed; file Q3 CMP-08 with tax and interest, then GSTR-4 with late fee. The late fee for GSTR-4 is capped at ₹2,000 in total, or ₹500 for nil.

  4. Conclusion

    1. Check which CMP-08s and GSTR-4 are pending.
    2. File missing CMP-08s with tax and interest.
    3. File GSTR-4 with late fee.
    4. Keep ARNs as proof.

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