GST
GSTR-3A for composition dealers
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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.
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
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.
Conclusion
- Check which CMP-08s and GSTR-4 are pending.
- File missing CMP-08s with tax and interest.
- File GSTR-4 with late fee.
- Keep ARNs as proof.
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