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GSTN : Brief Discussion on Email Sent by GSTN on Aggregate Turnover with CA Rajender Arora

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Published on 22 Aug 2020 / In GST

Brief Discussion on Email Sent by GSTN on Aggregate Turnover with CA Rajender Arora

1. What is the meaning of aggregate turnover?

As per Sub Section 6 of Section 2 of CGST Act, 2017, "aggregate turnover" means the aggregate value of

all taxable supplies

(excluding the value of inward supplies on which tax is payable by a person on reverse charge basis),

exempt supplies,

exports of goods or services or both and

inter-State supplies of persons having the same PAN (Permanent Account Number),

to be computed on all India basis but

excludes central tax, State tax, Union territory tax, integrated tax and cess;

What is the purpose of this email?
The basic purpose of the email is to determine the turnover in order to determine the due date of return and accordingly the late fee shall be calculated. Infact, it is an opportunity to declare the correct turnover and the taxpayer can use this for reporting interest on delayed payments based on self-assessment basis.

Whether this mail is a notice?
It is to be noted here that this email is sent by the GST. GSTN is the portal which maintains the GST Portal i.e. https://www.gst.gov.in/ . The DIN (Document Identification Number) which is mandated to be quoted in every communication by the GST Authorities, but it is not required in this email as this is sent by GSTN and not by GST Authorities. This is to be treated as a communication and not as a notice at all.

How GSTN has calculated this Aggregate Turnover?
GSTN has computed the Aggregate Turnover based on returns (i.e. GSTR-3B) filed by the taxpayer in Financial Year 2019-20 by all registrations on the common PAN.

The taxpayer who has filed all returns, Aggregate turnover has been computed by taking turnover from all GSTR 3B.

For the taxpayers, who have not filed all the GSTR-3B, Aggregate turnover has been computed

v in respect of tax periods for which return have been filed, turnover has been computed by taking turnover from all GSTR 3B

v in respect of tax periods for which return has not been filed, turnover would be calculated by Turnover declared/No. of GSTR-3B Filed*No. GSTR-3B liable to be filed.

Do we need to reply this mail? If yes then under which circumstances?
A taxpayer shall respond to this email in cases, where the Aggregate Turnover computed by GSTN is more than 5Crores but Infact the actual Aggregate Turnover is less. Possible reasons for this:-

The GSTR-3B in which there is comparatively less sale is not yet filed.

Correction of turnover pertaining to FY 2018-19 done in 2019-20 i.e. the turnover was less reported in 2018-19 and while correcting that excess turnover is reported in FY 2019-20.

Incorrect turnover of FY 2019-20 reported in returns and the taxpayer has a facility to correct it in returns of FY 2020-21 or in annual return.

Should grievance be submitted even if no email is received?
Yes the grievance shall be submitted even if the email is not received, in the cases, where the Aggregate Turnover computed by GSTN is less than 5Crores but Infact the actual Aggregate Turnover is more. Possible reasons for this:-

The GSTR-3B in which there is comparatively more sale are not yet filed.

Correction of turnover pertaining to FY 2018-19 done in 2019-20 i.e. the turnover was excess reported in 2018-19 and while correcting that less turnover is reported in FY 2019-20.

Incorrect turnover of FY 2019-20 reported in returns and the taxpayer has a facility to correct it in returns of FY 2020-21 or in annual return.

Non – GST supplies/Exempted supplies/Outward supplies which are liable to reverse charge are not reported.

Where to reply this mail?
The reply to this email, wherever required, shall be send by taxpayer in form of grievance by filing at https://selfservice.gstsystem.in for redressal. The taxpayers are advised to upload the information while raising grievance in format provided in email, which will enable GSTN team to resolve the same. It is to be noted that communication shall be completed within 500 characters otherwise the entire communication shall be attached as an attachment.

What shall be the consequences where it was required to submit the reply but no reply is submitted by the taxpayer?
In cases where the Aggregate Turnover computed by GSTN and actual Aggregate Turnover vary, then following two scenarios is possible:-

Aggregate Turnover computed by GSTN is more than 5Crores but Infact the actual Aggregate Turnover is less. In such a case, the due date shall be early than in actual it should be and extra late fee shall be levied by the GST Portal, if returns are filed after the due date as shown by the portal.

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