COMMON MISTAKES IN GST COMPLIANCE

It’s been more than one and half year of GST implementation however, GST has not yet started its settling phase. This is mainly because of two reasons; first, there are continuous amendments and second, non-clarity / confusion regarding applicability of legal provisions.  It is observed that due to non-clarity of many legal concepts, companies are making certain errors / mistakes or non-compliance which needs to be rectified before starting GST audit. Certain common mistakes in GST compliance, few of them are summarized below. The intention is to highlight common mistakes and precautions to be taken for GST audit so that efforts can be taken to solve / rectify them before starting GST audit and save cost of interest and penalty.
INPUT TAX CREDIT (ITC)
1	ITC availed without tracking date of payment – condition of payment within 180 days
2	Availment of 100% credit on pre-paid expenses. 100% ITC will not be available in the same month since condition of receipt of service is not satisfied
3	Non-reversal of ITC in case of free sample/write off / gift /personal consumption
4	Non-availment of ITC on banking transactions due to non-receipt of invoices OR ITC is availed on back statement but not on bank invoice
5	Non-payment of GST / non-reversal of ITC in case of receipt of insurance claim
6	Non-availment of ITC on air tickets since air travel agent provides his GSTIN instead of company. OR in other cases, air travel agent provides GSTIN of the company however, ITC is not availed due to non-availability of tax invoice of airline company
7	Non-availment of ITC on repairs / renovation of office or factory when such expenses are not capitalised
8	Availment of ITC on canteen / employee transport service from September 2018 without issue of Notification to give effect. ITC on such services will be available w.e.f. 1st February 2019
9	ITC of CGST and SGST of one State is claimed in other State – e.g. hotel accommodation
10	Availment of ITC on RCM in the subsequent month instead of in the same month
11	Carry forward of credit in TRAN-1 which was not reported in returns filed under excise, service tax and VAT but availed in books
DOCUMENTATION / RECORD
1	Non-issue of Tax Invoice (self-invoice) in case of RCM credit
2	Non-fixing / display of GST registration Certificate / GSTIN at the entrance of the office / factory
3	Non-issue of Receipt Voucher / Payment Voucher / Refund Voucher
4	Non-filing of ITC-04 related to job work transactions
5	Non-maintenance of ITC Register in a proper manner. Mainly not updating GSTIN of all suppliers which is essential at the time of reconciliation of ITC with GSTR-2A
6	Raising of Debit Note first in case of purchase return rather than supplier raising Credit Note
7	Issuing of separate delivery challan by job worker for returning of processed goods to the principal manufacturer
GST RETURNS
1	Many suppliers file GSTR-3B but not GSTR-1 or vice versa
2	Wrongly reporting outward supply liability under RCM or vice versa
3	Non-reconciliation of GSTR-1 and GSTR-3B for the same month