Relief Measures under GST due to COVID-19 Pandemic – updated till 05/05/2020 1


Coronavirus occurred at the times when India was at the verge of closing its financial year, many of the events/things likely to change with the closing of one financial year and opening of new financial year. Under GST Laws too, among others, there are so many things/events to be checked before moving to next financial year.

After the announcement of nation wide lockdown in India due to spread of Coronavirus (COVID-19), Finance Minister lately announced some relief measures for the statutory and regulatory compliance matters (returns, forms, applications, or others) which comes or becomes due in the period of such lockdown. In this regard, CBIC has issued various notifications and circulars on 3rd April 2020 to (officially) record the announcements of Finance Minister.

Further, on 5th May 2020, some more relaxations are announced like EVC facility to companies, SMS based 3B filing, Annual Return of FY 2018-19, e-way bills validity, etc.

Followings are the various measures notified under GST under these announcements.


For Composition Dealers

Extension in the time limit to opt for the Composition Scheme for FY 2020-21

CGST Rules has been amended so as to allow taxpayers opting for the Composition Scheme for the financial year 2020-21 to file their option in FORM CMP-02 till 30th June, 2020.

Along with this, time limit for filing of FORM ITC-03 has been extended till 31st July 2020 for the FY 2020-21.

Extension in the time limit to file CMP-08 for Quarter ending 31st March 2020

Time limit to furnish a statement in FORM GST CMP-08 for the quarter ending 31st March, 2020 extended till the 7th July, 2020

Extension in the time limit to file GSTR-4 for Financial Year 2019-20

Time limit to furnish a return in FORM GSTR-4 for the financial year ending 31st March, 2020 extended till the 31st August, 2020


Waiver of Late Fee for delay in filing FORM GSTR-1

For Taxpayers who are liable to file return in FORM GSTR-1 on monthly basis

There will not be any charge on account of late fee in case return (in form R-1) for the tax period of March 2020, April 2020 and May 2020 is furnished on or before the 30th June, 2020.

For Taxpayers who are liable to file return in FORM GSTR-1 on Quarterly basis

There will not be any charge on account of late fee in case return (in form R-1) for the tax period of Quarter ending March 2020 is furnished on or before the 30th June, 2020.


Waiver of Late Fee for delay in filing FORM GSTR-3B

For Taxpayers having an aggregate turnover of more than Rs 5 crores in the preceding financial year

There will not be any charge on account of late fee in case return (in form 3B) for the period of February 2020, March 2020 and April 2020 is furnished on or before the 24th June, 2020.

Taxpayers having an aggregate turnover of more than Rs 1.5 crores and up to Rs 5 Crores in the preceding financial year

There will not be any charge on account of late fee in case return (in form 3B) for the period of February 2020 and March 2020 is furnished on or before the 29th June, 2020.

And, in case of return (in form 3B) for the period of April 2020 is furnished on or before the 30th June, 2020, there will not be any charge as late fee.

Taxpayers having an aggregate turnover of up to rupees 1.5 crores in the preceding financial year

There will not be any charge on account of late fee in case return (in form 3B) for the following periods furnished on or before the dates given against them:

February 2020  :   30th June, 2020

March 2020        :   3rd July, 2020  

April 2020           :   6th July, 2020

Find Updated version of Relaxations for filing of GSTR-3B : Relaxations and Fee Waivers for GSTR-3B during COVID-19 Pandemic


Extension of due date of form GSTR-3B for May 2020

For Taxpayers having an aggregate turnover of more than Rs 5 crores in the preceding financial year :  Extended till 27th June 2020

For Taxpayers having an aggregate turnover upto Rs 5 crores in the preceding financial year : 

  • For taxpayers  whose principal place of business is in the States of Chhattisgarh, Madhya Pradesh, Gujarat, Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Telangana, Andhra Pradesh, the UTs of Daman and Diu and Dadra and Nagar Haveli, Puducherry, Andaman and Nicobar Islands or Lakshadweep, Extended till 12th July 2020;

  • For taxpayers, whose principal place of business is in the States of Himachal Pradesh, Punjab, Uttarakhand, Haryana, Rajasthan, Uttar Pradesh, Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Jharkhand or Odisha, the UTs of Jammu and Kashmir, Ladakh, Chandigarh or Delhi, Extended till 14th July 2020.

Extension of due date of form GSTR-3B for Ladakh

Due date for the return in FORM GSTR-3B for the months of January, 2020 to March, 2020 for registered persons whose principal place of business is in the Union territory of Ladakh has been extended till 20th May 2020.


Relaxation for Interest charge on late payment of GST through GSTR-3B

As, CBIC has not extended due date for filing of GSTR-3B for the tax period of February 2020, March 2020 and April 2020, but only waived late fee for delay in filing of return for these periods, thus, interest is still liable to pay for delay in payment of tax for these periods.

To provide relaxation for interest on late payment of tax for these periods, a separate notification has been issued.

For Taxpayers having an aggregate turnover of more than Rs 5 crores in the preceding financial year

–> Nil interest where tax paid within 15 days of due date of filing GSTR-3B.

–> Interest to be paid @ 9% p.a. where tax paid after 15 days of due date of filing GSTR-3B till 24th June 2020. (i.e. nil for first 15 days and @ 9% for remaining days)

–> Interest to be paid @ 18% p.a. where tax paid after 24th June 2020. (i.e. @ 18% p.a. from the day next to due date till actual date of payment).

Illustration:- Calculation of interest for delayed filing of return for the month of March, 2020 (due date of filing being 20.04.2020) may be illustrated as per the below Table:

S.No. Date of filing GSTR-3B No. of days of delay Whether the condition for reduced interest is fulfilled? Interest
1 02.05.2020 11 Yes Zero interest
2 20.05.2020 30 Yes Zero interest for 15 days + interest rate @9% p.a. for 15 days
3 20.06.2020 61 Yes Zero interest for 15 days + interest rate @9% p.a. for 46 days
4 24.06.2020 65 Yes Zero interest for 15 days + interest rate @9% p.a. for 50 days
5 30.06.2020 71 No Interest rate @18% p.a. for 71 days (i.e. no benefit of reduced interest)

Taxpayers having an aggregate turnover of more than Rs 1.5 crores and up to Rs 5 Crores in the preceding financial year

–> For the tax periods of February 2020 and March 2020:-

— Nil interest where tax paid by 29th June, 2020

— Interest to be paid @ 18% p.a. where tax paid after 29th June 2020. (i.e. @ 18% p.a. from the day next to due date till actual date of payment).

–> For the tax period of April 2020:-

Nil interest where tax paid by 30th June, 2020

Interest to be paid @ 18% p.a. where tax paid after 30th June 2020. (i.e. @ 18% p.a. from the day next to due date till actual date of payment).

Taxpayers having an aggregate turnover of up to Rs 1.5 crores in the preceding financial year

–> There will not be any charge on account of Interest in case GST paid for the following periods on or before the dates given against them:

February 2020  :   30th June, 2020

March 2020        :   3rd July, 2020  

April 2020           :   6th July, 2020

–> Interest to be paid @ 18% p.a. where tax paid after above said dates. (i.e. @ 18% p.a. from the day next to due date till actual date of payment).


Relaxation from applicability of Rule 36(4) of CGST Rules

Rule 36(4) of CGST Rules provides that a registered person shall claim ITC for a tax period in respect of eligible invoices which are filed by its corresponding supplier in his GSTR-1. And, in case invoices are not filed by its corresponding supplier in his GSTR-1, he may claim only 10% of eligible invoices filed by suppliers in GSTR-1 subject to maximum of sum of tax on invoices being not filed by corresponding suppliers in their GSTR-1.

In this regard, as a relief measure, it is provided that the said condition shall apply cumulatively for the period February, March, April, May, June, July and August, 2020 and the return in FORM GSTR-3B for the tax period September, 2020 shall be furnished with the cumulative adjustment of input tax credit for the said months in accordance with the condition mentioned in Rule 36(4).

It means that there is no requirement to follow Rule 36(4) for each tax period separately. However, a person would have to calculate and furnish the total adjustment of this rule collectively for tax periods from Feb 20 to Sept 20 to be made in the return of September 2020.


E-way Bills

Due to instant lockdown announcement, goods carriages were stuck at the places where they were present at the time of commencement of period of lockdown. Thus, the validity of e-way bills was required necessary enhancement. To provide relaxation over genuine hardships to operators of such goods carriages’, validity of all the e-way bills has been generally extended till 30th April 2020 whose validity was subject to expiry during the period 20th March, 2020 to 15th April, 2020.

However, validity of all e-way bills generated on or before 24th March 2020, whose validity expires during the period 20th day of March, 2020 to the 15th day of April, 2020, the validity period of such e-way bill shall be deemed to have been extended till the 31st day of May, 2020.


EVC verification facility extended to Companies for filing 3B

As per Rule 26 of CGST Rules 2017, registered person registered under the provisions of the Companies Act, 2013 (18 of 2013) shall furnish the documents or application verified only through digital signature certificate.

Due to Coronavirus effect, this requirement has been relaxed w.e.f. 21st April 2020 to 30th June 2020 to verify return in Form GSTR-3B by such registered persons through Electronic Verification Code (‘EVC’) also.


Nil return in 3B through SMS

A registered person who is required to furnish a Nil return under section 39 in FORM GSTR-3B for a tax period, he may furnish the said return through a short messaging service (‘SMS’) using the registered mobile number and the said return shall be verified by a registered mobile number based One Time Password facility. (Detailed manner to be notified yet)


Due date of Annual Return of FY 2018-19

Due date for Annual Return for the FY 2018-19 has been extended till 30th September 2020. Earlier, it was 30th June 2020.


General enhancement to all other provisions

For all the other provisions, other than those specifically listed in above paragraphs, it is provided that where, any time limit for completion or compliance of any action, by any authority or by any person, which falls during the period from the 20th March, 2020 to the 29th June, 2020, then, the time limit for completion or compliance of such action, shall be extended upto the 30th June, 2020, including for the purposes of :-

(a) completion of any proceeding or passing of any order or issuance of any notice, intimation, notification, sanction or approval or such other action, by whatever name called, by any authority, commission or tribunal, by whatever name called, under the provisions of GST laws; or

(b) filing of any appeal, reply or application or furnishing of any report, document, return, statement or such other record, by whatever name called, under the provisions of GST laws;

However, above referred general extension shall not apply for following provisions/compliances:-

  • Provisions of Chapter IV of CGST Act 2017, i.e. to decide TIME AND VALUE OF SUPPLY;

  • Provisions of Section 10(3) of CGST Act 2017, i.e. Composition Scheme will be lapsed from the date when aggregate turnover exceeds threshold limit;

  • Provisions of Section 25 and Section 27 of CGST Act 2017, i.e. requirement of Registration of Taxpayers including casual taxable person and non resident taxable person;

  • Provisions of Section 31 of CGST Act 2017, i.e. issuance of Tax Invoice;

  • Provisions of Section 37 (GSTR-1), Section 47 (Late fee) and Section 50 (Interest on late payment) of CGST Act 2017, because the relaxations pursuant to these sections specifically provided above;

  • Provisions of Section 39 of CGST Act 2017, i.e. Furnishing of Returns, except given below:-
    • For GSTR-3B, GSTR-4, CMP-08 : – Extension and relaxations already provided in specific provisions stated above;
    • For TDS deductors under section 51, all the actions (returns and payments, etc.) falls during the period from the 20th March, 2020 to the 29th June, 2020, shall be extended upto the 30th June, 2020. Section 39(3));
    • For Input service distributors and registered Non-Resident Taxable person, all the actions (returns and payments, etc.) falls during the period from the 20th March, 2020 to the 29th June, 2020, shall be extended upto the 30th June, 2020 (Section 39(4) and Section 39(5));

  • Provisions of Section 68 of CGST Act 2017, i.e. Inspection of goods in movement in so far as as e-way bill is concerned;

  • Provisions of Section 69 of CGST Act 2017, i.e. Power to Arrest and to produce arrested person before Magistrate within twenty-four hours of arrest;

  • Provisions of Section 90 of CGST Act 2017, i.e. Liability of partners of firm to pay tax, to intimate proper officer about the retirement of any partner within one month from the date of retirement;

  • Provisions of Section 122 of CGST Act 2017, i.e. Penalty for certain Offences;

  • Provisions of Section 129 of CGST Act 2017, i.e. Detention Seizure and release of goods and conveyance in transit.

All the rules and other provisions shall also be extended or excluded in accordance with their respective sections of CGST Act, 2017.

It is hereby specifically mentioned that returns required to be filed by persons under section 52 i.e. TCS registrants, due date falling during the period from the 20th March, 2020 to the 29th June, 2020, has been extended till the 30th June, 2020 under general enhancement provisions discussed just above.


Read full circular for source of above relaxations:- CIR-136/6/2020-GST


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