Implementation of Mandatory HSN Codes in GSTR-1 & GSTR-1A

What You Need to Know

From January 2025, GSTN started phasing in the implementation of mandatory HSN codes in Table 12 of both GSTR 1 and GSTR 1A. It is a step based on the correct reporting of tax that has minimal human errors and simplifies compliance for businesses across the nation.

Below is a blog that has broken down what HSN codes are, change that has been introduced in Phase III, and compliance steps that need to be followed by businesses in India.

What Are HSN Codes and Why Are They Important?

It is, in fact the Harmonized System of Nomenclature, or HSN-an internationally accepted classification of goods and services. It classifies products or services with a unique numerical code, thereby standardizing trade and tax systems.

HSN is important for Goods and Services Tax in India in the following manners:

The implementation of HSN codes must be done correctly, and GST registered entities should cover it.

Phase III Implementation: Key Changes

GSTN has brought phase III in the process of reporting of HSN Codes in GSTR -1 and GSTR-1A. Here are the critical changes in the same:

  1. Segmentation of Table 12
    • Table 12 divided into two heads:
      • B2B Supplies: Business-to-business.
      • B2C Supplies: Sales to consumers.
    • Separation gives clear clarity and easy reporting of supplies.
  2. Validations Rules of Supplies and Value of Taxation
    • These supplies and taxation reported values have the new validations developed which cross-matching will happen on this reported value of supplies.
    • The business must complete the submission during this time period, so the rule will initially serve as a warning due to the mismatching.
  3. Features associated with the upgraded user
    • Download HSN Code List now with a new button whereby taxpayers can download the latest HSN and SAC codes along with descriptions in the Excel format.
    • My Master now facilitates search on product descriptions, making it easy to decide which HSN codes to use.

Change in Detail

  1. Verification for B2B Supplies
    • Verification rules will be applicable on tables like:
      • 4A, 4B, 6B and 6C for registered recipient.
      • 9A, 9B, and 15A for Exports or to registered recipient. 
    • This verification is an adjustment of tax values with correct tax amount.
  2. Verification in B2C Supplies
    • We will verify the non-registered recipient on the table such as.
      • 5A, 6A, 7A, and 7B. Domestic Supplies for non-registered recipient.
      • 9A (Ex) and 10 or 15 for unregistered recipient.

Addressing Amendments

If they conduct a revaluation, they will compare it based on differential value to eliminate the reuse of similar data.

Business Implication

Phases III Changes to GST registered will have more substantial effects for tax payers as follows -What Businesses should know:

Benefits of the new system
Challenges to be Overcome

Steps to comply with Phase III

To align the business to the new needs and ensure compliance, the businesses need to do:

  1. Study the Advisory
    • Read the official advisory given by GSTN in detail and understand what is changed and its implications.
    • The complete guidance is available on the GST portal that can be referred to.
  2. Accounting System
    • Check whether your accounting and billing software has the facility of dropping down the codes of HSN.
    • If yes then collaborate with the software vendor also to make the changes
  3. Train Your Employee
    • Train those employees who are handling GST return, which will file returns along with new updations.
    • Completely educate them about the drooping system as well as newly implemented validation rule and all change
  4. Validation Warnings Monitoring
    • Develop a procedure in order to trace the validation warnings that are arising while filing of returns.
    • Clear up the mismatches at once so no further penalties should arise.

FAQs on HSN Code Implementation

Q1: Will the validation warnings prevent the returns from being filed?

No, in the initial days, the validation warnings will not stop the filing of returns. However, the business needs to correct the warnings so as not to incur improper compliance in the future.

Q2: How can I get the new list of HSN codes?

You can download the latest HSN and SAC codes from the GST portal by clicking on the "Download HSN Code List" button on Table 12.

Q3: Is the drop-down selection compulsory for all taxpayers?

No, HSN code entry cannot be done manually. All the taxpayers must choose the appropriate HSN codes available in the list.

Why Compliances Are Important

In case of non-compliance with the latest rule, among other issues, the following may be faced:

Companies can avoid such issues and maintain smooth compliance with GST regulations by raising awareness and taking proactive measures.

Conclusion
The introduction of HSN codes in GSTR-1 and GSTR-1A in Phase III is a major step toward the betterment of GST compliance and accuracy. Mandatory drop-down selection, validation rules, and enhanced features make the process easy for businesses and promote transparency in taxation.
For that, companies should update their systems, train the teams, and be vigilant for validation warnings. Need help?
Contact Book My Accountant for expert assistance with GST compliance, tax planning, and more. Together, let's simplify your tax journey!

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TDS on Metal Scrap under GST: A Complete Guide

The Indian government has brought into effect new TDS provisions under the framework of Goods and Services Tax-specifically targeting all transactions in the form of metal scrap. With effect from 10 October 2024, these rules are aimed at improving tax compliance and transparency in the scrap materials sector. Let us dive into this and see what it will mean for the businesses buying and selling metal scrap.

What is TDS in GST for Metal Scrap?

TDS is a mechanism where tax is deducted at source at the time of making payment to the seller. Based on the latest GST rules, businesses, whose subject of business is procurement of metal scrap, are dutifully liable to deduct TDS at the time of entering into qualifying transactions.

And the transactions which attract TDS are under Chapter 72 to Chapter 81 of the Customs Tariff Act 1975, which comprises of:

Important Provisions of the TDS Rule

TDS shall apply on metal scrap under GST if the aggregate value of supplies exceeds ₹2,50,000 per transaction. The taxable value of scrap material will be deducted for deduction, and not the total invoice value.

Rate of deduction is provided as 2%, split as below:

Who must deduct TDS?

The Ministry of Finance issued Notification No. 25/2024-Central Tax on October 9, 2024, amending the earlier Notification No. 50/2018-Central Tax to clarify the Tax Deduction at Source (TDS) provisions under Section 51 of the CGST Act, 2017. Section 51 of the CGST Act 2017 deals with the mechanism of Tax Deduction at Source (TDS).

TDS provisions under Section 51 of the CGST Act shall not apply to the supply of goods or services between certain categories of persons specified in clauses (a), (b), (c), and (d) of sub-section (1) of Section 51 except for those specified in clause (d).

Process for becoming compliant

If you are a buyer dealing with metals scrap, here is what you need to do to become compliant with the new GST rules:

Obtain a Separate GST Registration

The buying party would be required to apply for a separate GST registration under REG-07 in order to start deducting TDS. Subsequently, the buyer can claim TDS on eligible transactions with which they will have to file a return month under Form GSTR-7. Simultaneously, the system generates a certificate of TDS, just like Form 16A under the Income Tax Act, after filing GSTR-7.

File Monthly Returns

The buyers who deduct TDS are liable to file GSTR-7 for the month. The return should be filed by the 10th of the next month where a payment liability will arise along with the return filing. This return should state the amount of TDS deducted.

Provide TDS Certificates

Once the return is filed by the purchaser, he shall issue the TDS certificate, GSTR-7A, to the supplier. Therefore, he would get the TDS credit to his ledger of cash at the end of every month.

TDS not Applicable in Respect of Metal Scrap

It is another important aspect that TDS under GST is not levied upon importing the metallic scraps. It does not draw any TDS deduction under such rules if the buyer imports scraps from abroad.

Conclusion

The introduction of TDS on metal scrap under the GST is perhaps a landmark to ensure better tax compliance in the industry. With the above move, the government has consequently mandated 2% TDS on all transactions, with an element of transparency and accountability that can be availed by the suppliers in due time.

Ensure your business is GST compliant with these new provisions by registering for GST TDS and the timely returns filing, contact Book My Accountant today for help with GST registration, TDS filing, and much more in accounting.

Navigating the Maze of Input Tax Credit (ITC) in GST: An Analysis of Section 16(4)

The ITC (Input Tax Credit) may be difficult to understand within the labyrinth of regulations of taxation, but undoubtedly it is one of the most important mechanisms for the businesses to operate in the tax system. The Input Tax Credit (ITC) under GST lets businesses reduce tax on inputs by offsetting it against output tax, preventing double taxation.Claiming ITC faces obstacles, notably under Section 16(4) of the GST Act, warranting a closer look.

Understanding Section 16(4) of the GST (Goods and Services Tax) Act

You must claim Input Tax Credit (ITC) under section 16(4) of the GST Act before the prescribed period ends; failing to do so means you will forfeit the opportunity to use it.The strict restriction introduced by the provision governs the order of claims for the number of credits in the last sentence.

Stated Conditions for Claiming ITC

To claim ITC under GST, businesses must adhere to several conditions outlined in Sub-Sections (1) to (4) of Section 16. These conditions include possessing valid tax invoices, receiving goods or services, and filing tax returns within the specified timeframes. Compliance with these prerequisites is essential for businesses to avail themselves of the benefits of ITC.

Arguments Against Section 16(4)

Constitutional Validity:

Section 16(4) is a controversial provision that could contradict the constitutional rights to equality and freedom to conduct business as it gives some companies an unfair advantage over others.

Administrative Burden:

Companies involved in intricate economic deals bear an increased administrative burden when tax reporting deadlines are imposed upon them. They must ensure that they comply with all the deadlines that have been provided.

Compliance Challenges:

Businesses face significant challenges meeting this deadline due to payment delays or disputes hindering timely acquisition of deserved ITC.

Impact on Cash Flow:

The import tax credit time limit can hurt cash flow, especially in industries with long payment cycles or during recessions.

Legal Ambiguity:

A challenge arises from the uncertain or unclear language and the misworded subsection (16)(4), opening the way for potential interpretation issues.

Counterarguments and Analysis

Legislative Intent:

It is crucially important to take into account the legislative purpose of introducing a time period for claiming ITC and whether it is in sync with the general objectives of the GST regime such as promoting tax compliance and minimizing revenue losses.

Preventing Fraud and Revenue Leakage:

Time limits performs very important functions like preventing tax evasion, fraud and revenue losses. Providing a mechanism whereby the government can avert the revenue loss is the role of Section 16(4).

Legislative Intent:

It is crucially important to take into account the legislative purpose of introducing a time period for claiming ITC and whether it is in sync with the general objectives of the GST regime such as promoting tax compliance and minimizing revenue losses.

Preventing Fraud and Revenue Leakage:

Time limits performs very important functions like preventing tax evasion, fraud and revenue losses. Providing a mechanism whereby the government can avert the revenue loss is the role of Section 16(4).

Harmonization with International Practices:

An evaluation of time limits for claiming ITC in the GST regime, in the context of international practices, may reveal whether they are reasonable and abide by global standards.

Conclusion

The debate on GST Act 16(4) highlights system weaknesses, compliance costs, and dispute settlement concerns.Clear legal definitions explaining judicial review are essential for a good GST experience. The business community needs to be able to adapt well to ITC provisions.

While GST may sound daunting, Book My Accountant will make sure that you are compliant and can grow your business with an efficient GST framework.