GST Compliance – Form GSTR-6 (Input Service Distributor Return)

A. The Law

Relevant Sections – CGST Act, 2017

• Section 2(61): Defines Input Service Distributor (ISD).

• Section 24(viii): Mandatory registration for ISDs.

• Section 39(4): Filing of returns by ISDs.

• Section 47: Levy of late fee for delay in filing.

Relevant Rules – CGST Rules, 2017

• Rule 65: ISD to file monthly return in Form GSTR-6.

• Rule 39: Prescribes distribution manner of ITC by ISD.

Key Point:

• Form GSTR-6 is a monthly return to be filed by every ISD for distribution of ITC to its units.

• Filing due date: 13th of next month, unless extended.

• Nil GSTR-6 is mandatory if no ITC is received or distributed.

B. How Do I – Step-wise Compliance Process

Step 1: Login & Navigate

1. Visit gst.gov.in.

2. Login → Services → Returns → Returns Dashboard.

3. Select FY & Period → Search.

4. Under GSTR-6 tile, click Prepare Online.

Step 2: Enter Details (Main Tables)

1. Table 3 – ITC Received for Distribution

   • Add invoices: Supplier GSTIN, Invoice No., Date, POS, Value, Tax, Cess.

2. Table 6A – Amendment of Earlier ITC Entries.

3. Table 6B – Debit/Credit Notes Received.

4. Table 6C – Amendment of Debit/Credit Notes.

5. Table 4 – Total ITC (Eligible/Ineligible) Distributed.

6. Table 5 & 8 – Distribution of ITC via ISD Invoices/Credit Notes.

7. Table 9 – Redistribution of ITC distributed wrongly earlier.

Step 3: Preview & Validate

• Click Preview Draft GSTR-6 (PDF).

• Validate entries: processed, errored, pending records.

• Amend or delete if needed.

Step 4: Compute & File

1. Click Calculate ITC → system computes eligible/ineligible ITC.

2. Click Proceed to File.

3. Select declaration checkbox → Authorized Signatory.

4. File using DSC (for companies/LLPs) or EVC (OTP).

5. ARN generated → SMS & Email confirmation sent.

Step 5: Post-Filing

• View Consolidated Summary.

• Download filed return PDF.

• Late fee payable if delay in filing; create challan if insufficient balance.

C. FAQs (15 Practical Clarifications & Errors)

1. Who files GSTR-6?
   Only registered ISDs.

2. Is Nil GSTR-6 mandatory?
   Yes, even if no ITC to distribute.

3. Due date?
   13th of next month.

4. Offline tool available?
   Yes, JSON upload facility exists.

5. Can I file if suppliers haven’t filed GSTR-1/5?
   Yes, ISD filing not dependent on them.

6. Reverse charge applicable to ISD?
   No, ISD not liable under RCM.

7. What if ITC reversal > available ITC?
   Negative balance treated as liability.

8. How to distribute ITC?
   Use Tables 5 & 8, via ISD invoices/credit notes.

9. Can ITC be redistributed?
   Yes, using Table 9.

10. What if invoice/credit note dated after supplier’s cancellation?
    Not allowed.

11. Is ITC cross-utilization allowed?
    No, cess not cross-utilized.

12. What if uploaded invoices not visible?
    Recompute ITC → Refresh dashboard.

13. Can debit/credit note be issued for multiple invoices?
    Yes, post delinking amendment.

14. What is POS for exports?
    Use State Code 96 – Foreign Country.

15. What happens after filing?
    ARN generated, ledgers updated.

D. Fillable Checklist – GSTR-6