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January 22, 2021

Frequently asked question on Form GSTR-6 and Form GSTR-6A

by CA Shivam Jaiswal in GST

Frequently asked question on Form GSTR-6 and Form GSTR-6A

1. What is Form GSTR-6?

Answer: Form GSTR-6 is a monthly return to be filed by all the Input Service Distributors (ISD) for distribution of credit (ITC) amongst its units.

2. Who needs to file Form GSTR-6 and is it mandatory to file this form?

Answer: Only those persons who are registered as Input Service Distributor (ISD) need to file Form GSTR-6. It is a mandatory return, to be filed on monthly basis. A ‘Nil’ return must be filed in case of no ITC being available for distribution or no ITC is being distributed during the month.

3. By when do I need to file Form GSTR-6?

Answer: ISD Returns for month M can only be filed on or before the 13th of month M+1 or the extended date, if any.

4. From where can I as a taxpayer file Form GSTR-6?

Answer: GSTR-6 can be accessed on the GST Portal, post login in the Returns Dashboard by the taxpayer.

The path is Services > Returns > Returns Dashboard.

5. Form GSTR-6 comprises of which tables?

Answer: Form GSTR-6 comprises of following tables:

Form GSTR-6 Invoice Details:

  1. Table 3:  To enter details of input tax credit received for distribution.
  2. Table 6B: To enter details of debit or credit notes received.
  3. Table 6A: To make amendments to information furnished in earlier returns in Table 3.
  4. Table 6C: To make amendments to debit or credit notes received.
  5. Form GSTR-6 ITC Distribution:
  6. Table 4: To view details of ITC available and eligible and ineligible ITC distributed.
  7. Table 5, 8: To enter details of distribution of input tax credit for ISD invoices and ISD Credit notes.
  8. Table 9: To enter details of ITC available and eligible and ineligible ITC redistributed.
  9. Can I file my ISD return if my counterparties have not filed Form GSTR-1/5?

Yes, you can file your Form GSTR-6 return even if your counterparties have not filed their respective Form GSTR-1 or Form GSTR-5.

7. Is there any Offline Tool for filing Form GSTR-6?

Answer: Yes, there is an offline tool for filing Form GSTR-6.

8. Is there any late fee in case of delayed filing of Form GSTR-6?

Answer: Yes, there is a late fee prescribed in Law.

9. Is there an Electronic Credit Ledger available for ISD Registrations?

Answer: No, there is no Electronic Credit Ledger maintained for ISD Registrants, since ISD has to only distribute credit available during a tax period.

10. As an ISD, am I liable to pay tax on a reverse charge basis? OR Is reverse charge applicable to ISDs?

Answer: No. Reverse charge liability is not applicable for an ISD person.

11. How do I allocate credit to my other units in the Form GSTR 6?

Answer: Using Table 5 and Table 8 of the Form GSTR-6, both eligible and ineligible ITC can be distributed to the units.

12. Can I amend the credit allocated to the units in Form GSTR 6 of earlier tax periods? If yes, how?

Answer: You can distribute the credit through ISD invoice and provide the details in Table 5 and Table 8 of the Form GSTR-6, indicating both eligible and ineligible distribution to the units.

13. Can the date of filing of Form GSTR-6 be extended?

Answer: Yes, date of filing of Form GSTR-6 can be extended by Government through notification.

14. What are the pre-conditions for filing Form GSTR-6?

Answer: Pre-conditions for filing of Form GSTR-6 are:

  • Recipient should be Registered as an ISD and should have an active GSTIN.
  • Recipient should have valid login credentials (i.e., User ID and password).
  • Recipient should have valid and non-expired/ unrevoked Digital Signature Certificate (DSC which is mandatory for companies, LLPs and FLLPs).
  • Recipient should have with him an active mobile number which is indicated in his registration details furnished to GST Portal at the time of registration or amendment thereof for authentication through EVC.
  • Recipient will have an option to file Form GSTR-6 for cancelled GSTINs for the period in which it was active.

15. What happens after Form GSTR-6 is filed?

Answer: After Form GSTR-6 is filed:

ARN is generated on successful filing of the Form GSTR-6 Return.

An SMS and an email are sent to the applicant on his registered mobile and email id

16. What are the modes of signing Form GSTR-6?

Answer: You can file Form GSTR-6 using DSC, or EVC.

(a) Digital Signature Certificate (DSC)

Digital Signature Certificates (DSC) are the digital equivalent (that is electronic format) of physical or paper certificates. A digital certificate can be presented electronically to prove one’s identity, to access information or services on the Internet or to sign certain documents digitally. In India, DSC are issued by authorized Certifying Authorities.

The GST Portal accepts only PAN based Class II and III DSC.

To obtain a DSC, please contact any one of the authorised DSC-issuing Certifying Authorities: http://www.cca.gov.in/cca/?q=licensed_ca.html

(b) Electronic Verification Code (EVC)

The Electronic Verification Code (EVC) authenticates the identity of the user at the GST Portal by generating an OTP. The OTP is sent to the mobile phone number of the registered mobile phone of Authorized Signatory filled in part A of the Registration Application.

17. Can I preview Form GSTR-6 before submitting?

Answer: Yes, you can preview Form GSTR-6 before submitting on the GST Portal.

18. I have credit note in CGST & SGST,with no Input Tax Credit available in CGST & SGST, but credit in IGST is available. Hence, credit available for distribution in CGST & SGST is negative, what will be the implications?

Answer: If the reversal of Input Tax Credit exceeds the credit available under any of the major head, during a tax period, then sum under such head will become negative. The excess reversal, over available input tax credit is added to the liability. Consequentially the total credit available for distribution will be reduced accordingly.

Total credit available i.e. IGST+CGST+SGST will always be equal to total credit to be distributed (IGST+CGST+SGST), including the liability due to negative credit. Hence, total credit available for distribution will be sum of –

I. Inward supplies received during the month (net of credit/debit notes and amendments of invoices and credit/debit notes).

II. Receipt of credit notes will reduce the ITC available for distribution while receipt of debit notes will increase the same.

III. Availability of ITC, due to issue of ISD credit notes to its units. 

IV. Availability and distribution of Cess will always be the same as it is not cross utilised with any of the major heads.

 For example:-

Credit available in IGST – 1,08,000 INR

Negative credit available in CGST & SGST – 43,200 INR each (Amount of credit note is more than credit available in CGST & SGST)

Total credit available for distribution – [Sum of IGST=1,08,000, CGST= -43200 & SGST= -43200] = 21600 INR

Total input tax credit available for distribution i.e. 21600 INR only will be bifurcated to the eligible and ineligible credit.

19. Which State code is to be selected as place of supply (PoS) in case of transportation of goods outside India, by a registered taxpayer on behalf of a registered recipient?

 Answer: In case of supply of services (by a registered taxpayer) by way of transportation or courier of goods to a place outside India, the place of supply is the foreign country outside India (being destination of such goods).

For reporting such transactions, where POS lies in foreign country, the supplier of services (the registered taxpayer) needs to select State code as ‘96-Foreign Country’ from the list of codes.

The registered recipient of services will then be entitled to ITC, though POS lies outside the State of his registration, in case State code 96 is mentioned by of the supplier of services (the registered taxpayer) in their statement of outward supplies.

Illustration – Supplier of goods ‘A’ is registered in State ‘X’ in India who has got an order for supply from a foreign country ‘F’. Supplier ‘A’ asked another taxpayer ‘B’ registered in the same State ‘X’ to supply services (couriers etc.) for transportation of goods to the foreign country. Taxpayer ‘B’ will issue invoice in the name of ‘A’ and mention POS as state code 96. Though, both the taxpayers are located in the same State but by virtue of POS as 96, the supply will be taxable under IGST and ITC will be available to taxpayer ‘A’ under IGST head.

20. What would be the type of supply when the State Code is selected as ‘96-Foreign Country’?

Answer: Supplies with Place of Supply selected as state code ‘96-Foreign Country’ will always be inter-State supply.

21. In which tables of Form GSTR-6 the State Code as ‘96-Foreign Country’ will be available for selection from the dropdowns?

Answer: The state code ’96-Foreign Country’ will be available for selection in the existing list of Place of Supply (POS) drop-down in following tables of Form GSTR-6:

i. B2B (Table 3)

ii. B2B Amendments (Table 6A)

22. What is the difference between Form GSTR-6 before and after delinking of Debit/ Credit Note?

Answer:

S. No.Form GSTR-6 before delinking of Debit/ Credit NoteForm GSTR-6 after delinking of Debit/ Credit Note
1While entering the Debit/ Credit note details, original invoice number and original invoice date were mandatory to be entered.While entering the Debit/ Credit note details or amendment in debit/ credit note details, ISD is not required to enter original invoice number and original invoice date.
2POS field was not available.Entering POS is mandatory.
3Supply type was determined based on Original invoice details.Supply type is determined on the basis of GSTIN of supplier and POS.
4Suppliers were issuing one debit/credit note for each invoice.Supplier can issue one Debit/ Credit note for multiple invoices.
5Pre-GST checkbox was available.Pre-GST checkbox has been removed.

23. I have already saved Debit/ Credit note details online before delinking of Debit/ Credit Note but have not filed the returns. What will happen to the saved Debit/ Credit note?

Answer: If you have saved Debit/ Credit Note details before delinking of Debit/ Credit Note, it will be saved in old format only until you edit and again save the same.

Post delinking of Debit/ Credit Note, you can edit the saved Debit/ Credit note in post delinking format only (Original Invoice Number and Date will not be available and entering POS is mandatory).

 Note: In case you are filing the return without editing the saved record, it will be filed in old format only.

24. I have generated the JSON file from old excel utility before delinking of Debit/ Credit Note but have not uploaded on GST Portal. Can I upload the same after delinking of Debit/ Credit Note?

Answer: No, you cannot upload the JSON file generated before delinking of Debit/ Credit Note. You need to update the details manually in new offline excel utility again and then generate the new JSON file to upload it onto the GST Portal.

25. I have already filed Form GSTR-6 for a particular tax period before delinking of Debit/ Credit Note. Do I need to file Form GSTR-6 again for that tax period post delinking of Debit/ Credit Note?

Answer: If you have already filed Form GSTR-6 for a particular tax period before delinking of Debit/ Credit Note, there is no need to file Form GSTR-6 again for that tax period.

26. What is Form GSTR-6A?

Answer: Form GSTR-6A is a system generated ‘draft’ Statement of Inward Supplies for an ISD (Input Service Distributor). Form GSTR-6A is a read only form. ISD cannot take any action in Form GSTR-6A.

Form GSTR-6A for a particular tax period changes, based on the details uploaded by the counter- party supplier, in their Form GSTR-1.

27. When can I view Form GSTR-6A of a tax period?

Answer: You can view Form GSTR-6A of a tax period –

1. When the counterparty has saved/submitted/filed their Form GSTR-1, then the invoices will be available for view in Form GSTR-6A.

2. When the counterparty has only uploaded invoice details, but has not submitted/filed their Form GSTR-1,  then such saved documents will also be available for view in Form GSTR-6A.

28. Do I have to file the Form GSTR-6A?

Answer: No, you don’t have to file the Form GSTR-6A. It is a read-only document provided to you so that you have a record of all the invoices received from various supplier taxpayers in a given tax period.

29. Can I make changes to or add an invoice in my Form GSTR-6A in case there are any errors or omission in the details uploaded by my supplier taxpayers?

Answer: No, you cannot make any changes to the Form GSTR-6A, as it is a read-only document.  The information displayed in Form GSTR-6A is also available in Form GSTR-6 and any/all actions must be taken in the GSTR-6 by the receiver.

30. Which details are available in Form GSTR-6A?

Answer: The details available in Form GSTR-6A are:        

Input tax credit received for distribution – To view the details of inward supply invoices received from counter-party suppliers, for distribution of ITC to the GSTINs (with same PAN) mapped to the ISD

Debit / Credit notes (including amendments thereof) received during current tax period – To view the details of debit or credit notes received from counter-party suppliers, by the ISD, during current tax period

Amendments to Input tax credit received for distribution – To view the details of amendment in inward supply invoices received from counter-party suppliers by the ISD

Amendments to Debit/Credit notes received during current tax period – To view the details of amendment in debit or credit notes received from counter-party suppliers by the ISD, during current tax period

31. Form GSTR-6A will be updated in which scenarios?

Answer: Form GSTR-6A will be updated in below scenarios, as explained below:

S.No.ScenarioFor the Return period ofSupplier status of Form GSTR-1/5Receiver (ISD) status of Form GSTR-6Details are auto-populated in Form GSTR-6A of the receiver ISD in tax Period of
1When Receiver (ISD) has not submitted Form GSTR-6 for the month of June 2020, but supplier has already submitted Form GSTR-1/5 for June 2020June 202010-July-2020Not submittedThe supplier’s B2B details will be auto-populated in Form GSTR-6A in June 2020 of the receiver ISD (i.e., in current tax period)
2When the supplier submits the Form GSTR-1/5 return before Receiver (ISD) submits the Form GSTR-6 for the period of June 2020June 202010-July-202012-July-2020The supplier’s B2B details will be auto-populated in Form GSTR-6A in June 2020 of the receiver ISD (i.e., in current tax period)
3When supplier submits Form GSTR-1/5 return after Receiver (ISD)submits Form GSTR-6 for the period June 2020June 202010-July-202006-July-2020The supplier’s B2B details will be auto-populated in Form GSTR-6A in July 2020 of the receiver ISD (i.e., next tax period)

32. Can I as a taxpayer download and keep a copy of my Form GSTR-6A for future reference?

Answer: After logging into GST Portal, you can view Form GSTR-6A and/or download the same in an Excel format.

33. What is the impact of Debit/ Credit Note on Form GSTR-6A, before and after its delinking with invoices?

Answer:

S. NoBefore Delinking of Debit/ Credit Note with invoicesAfter Delinking of Debit/ Credit Note with invoices
1Original invoice number and original invoice date were auto-draftedOriginal invoice number and original invoice date fields are not visible for entry.
2POS field was not required as the same was derived from original invoice. Hence, POS was not provided.POS field is a mandatory field for entry and is visible for entry.

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