Clarification in respect of various measures announced by the Government for providing relief to the taxpayers in view of spread COVID-19

Circular No.: 141/11/2020-GST
Date of Circular: 24th June 2020
Relevant Sections and Rules:

• CGST Act, 2017:
  • Sections 37, 39, 47, 50, 168(1)
• CGST Rules, 2017:
  • Rule 61 (GSTR-3B filing)
• Notifications Referenced:
  • Notification Nos. 31/2020, 51/2020, 52/2020, 53/2020 – Central Tax

Summary of Circular in Paragraphs (One Clarification Each):

1. Interest Relief for Taxpayers with Turnover Above ₹5 Crore:
   Notification No. 51/2020-CT grants interest relief for late filing of GSTR-3B for Feb, Mar, and Apr 2020.

• First 15 days after due date: NIL interest
• Next period till 24.06.2020: Interest @ 9% per annum
• After 24.06.2020: Interest @ 18% per annum
  Illustrative table shows interest computation based on actual filing dates. Prior conditions from Notification No. 31/2020 and Circular 136/06/2020 are modified accordingly.

2. Interest Relief for Taxpayers with Turnover Up to ₹5 Crore:
   Notification No. 52/2020-CT provides complete relief for GSTR-3B delay for Feb–Jul 2020, as follows:

• NIL interest up to specified dates (varying per return period)
• 9% interest per annum till 30.09.2020
• 18% interest per annum thereafter
  Multiple examples provided for Mar 2020 and Jun 2020 filings show how interest transitions across these timelines.

3. Waiver of Late Fees for GSTR-3B:
   Notification No. 52/2020-CT also revises and extends conditional late fee waiver:

• Applies to GSTR-3B of Feb–Jul 2020
• Waiver is conditional upon timely filing by newly specified dates
• If missed, late fees are payable from original due date till date of actual filing

4. Waiver of Late Fees for GSTR-1:
   Notification No. 53/2020-CT offers conditional waiver of late fees for delay in GSTR-1 for the same periods.
   This benefits compliance for monthly and quarterly filers alike, provided returns are filed within the notified extended deadlines.
5. Circular 136/06/2020 Modified:
   This circular supersedes the earlier guidance wherever contrary to the above new relief measures recommended by the GST Council in its 40th meeting (12.06.2020).

Source: Circular No.: 141/11/2020-GST