The spread of Novel Corona Virus (COVID-19) across many countries of the world,
including India, has caused immense loss to the lives of people and resultantly impacted the
trade and industry. In view of the emergent situation and challenges faced by taxpayers in
meeting the compliance requirements under various provisions of the Central Goods and
Services Tax Act, 2017 (hereinafter referred to as the “CGST Act”), Government has
announced various relief measures relating to statutory and regulatory compliance matters
across sectors.
- Government has issued the following notifications in order to provide relief to the
 taxpayers:
 S.
 No.
 Notification Remarks
- N notification No.
 30/2020- Central
 Tax, dated
 03.04.2020
 Amendment in the CGST Rules 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 and to
 allow the cumulative application of the condition in rule 36(4) for
 the months of February 2020 to August 2020 in the return for
 tax period of September 2020.
- N notification No.
 31/2020- Central
 Tax, dated
 03.04.2020
 A lower rate of interest of NIL for first 15 days after the due
 date of filing return in FORM GSTR-3B and @ 9% thereafter
 is notified for those registered persons having aggregate
 turnover above Rs. 5 Crore and NIL rate of interest is notified
 for those registered persons having aggregate turnover below
 Rs. 5 Crore in the preceding financial year, for the tax periods
 of February, 2020 to April, 2020. This lower rate of interest
 shall be subject to condition that due tax is paid by filing return
 in FORM GSTR-3B by the date(s) as specified in the
 Notification.
 Circular No. 136/06/2020-GST
 Page 2 of 5
- N otification No.
 32/2020- Central
 Tax, dated
 03.04.2020
 Notification under section 128 of CGST Act for waiver of late
 fee for delay in furnishing returns in FORM GSTR-3B for the
 tax periods of February, 2020 to April, 2020 provided the return
 in FORM GSTR-3B by the date as specified in the Notification.
- N otification No.
 33/2020- Central
 Tax, dated
 03.04.2020
 Notification under section 128 of CGST Act for waiver of late
 fee for delay in furnishing the statement of outward supplies in
 FORM GSTR-1 for taxpayers for the tax periods March, 2020
 to May, 2020 and for quarter ending 31st March 2020 if the same
 are furnished on or before 30th day of June, 2020.
- N otification No.
 34/2020- Central
 Tax, dated
 03.04.2020
 Extension of due date of furnishing statement, containing the
 details of payment of self-assessed tax in FORM GST CMP-
 08 for the quarter ending 31st March, 2020 till the 7th day of July,
 2020 and filing FORM GSTR-4 for the financial year ending
 31st March, 2020 till the 15th day of July, 2020.
- N otification No.
 35/2020- Central
 Tax, dated
 03.04.2020
 Notification under section 168A of CGST Act for extending due
 date of compliance which falls during the period from the 20th
 day of March, 2020 to the 29th day of June, to 30th day of June,
 2020.
- Various issues relating to above mentioned notifications have been examined. In order
 to ensure uniformity in the implementation of the provisions of the law across the field
 formations, the Board, in exercise of its powers conferred under section 168(1) of the CGST
 Act hereby clarifies each of these issues as under:-
 S.
 No.
 Issue Clarification
- What are the
 measures that have
 been specifically
 taken for taxpayers
 who have opted to
 pay tax under section
 10 the CGST Act or
 those availing the
 option to pay tax
 under the
 notification No.
 02/2019– Central
 Tax (Rate), dated the
 7th March, 2019?
- The said class of taxpayers, as per the notification No.
 34/2020- Central Tax, dated 03.04.2020, have been allowed,
 to,-
 (i) furnish the statement of details of payment of selfassessed
 tax in FORM GST CMP-08 for the quarter
 January to March, 2020 by 07.07.2020; and
 (ii) furnish the return in FORM GSTR-4 for the financial
 year 2019-20 by 15.07.2020.
- In addition to the above, taxpayers opting for the
 composition scheme for the financial year 2020-21, have
 been allowed, as per the notification No. 30/2020- Central
 Tax, dated 03.04.2020, to,-
 (i) file an intimation in FORM GST CMP-02 by
 30.06.2020; and
 (ii) furnish the statement in FORM GST ITC-03 till
 31.07.2020.
- Whether due date of
 furnishing FORM
 GSTR-3B for the
 months of February,
 March and April,
 2020 has been
 extended ?
- The due dates for furnishing FORM GSTR-3B for the
 months of February, March and April, 2020 has not been
 extended through any of the notifications referred in para 2
 above.
- However, as per notification No. 31/2020- Central Tax,
 dated 03.04.2020, NIL rate of interest for first 15 days after
 the due date of filing return in FORM GSTR-3B and reduced
 Circular No. 136/06/2020-GST
 Page 3 of 5
 rate of interest @ 9% thereafter has been notified for those
 registered persons whose aggregate turnover in the preceding
 financial year is above Rs. 5 Crore. For those registered
 persons having turnover up to Rs. 5 Crore in the preceding
 financial year, NIL rate of interest has also been notified.
- Further, vide notification as per the notification No.
 32/2020- Central Tax, dated 03.04.2020, Government has
 waived the late fees for delay in furnishing the return in
 FORM GSTR-3B for the months of February, March and
 April, 2020.
- The lower rate of interest and waiver of late fee would be
 available only if due tax is paid by filing return in FORM
 GSTR-3B by the date(s) as specified in the Notification.
- What are the
 conditions attached
 for availing the
 reduced rate of
 interest for the
 months of February,
 March and April,
 2020, for a registered
 person whose
 aggregate turnover
 in the preceding
 financial year is
 above Rs. 5 Crore?
- As clarified at sl.no. (2) above, the due date for furnishing
 the return remains unchanged; i.e. 20th day of the month
 succeeding such month. The rate of interest has been notified
 as Nil for first 15 days from the due date, and 9 per cent per
 annum thereafter, for the said months.
- The reduced rate of interest is subject to the condition that
 the registered person must furnish the returns in FORM
 GSTR-3B on or before 24th day of June, 2020.
- In case the returns in FORM GSTR-3B for the said
 months are not furnished on or before 24th day of June, 2020
 then interest at 18% per annum shall be payable from the due
 date of return, till the date on which the return is filed. In
 addition, regular late fee shall also be leviable for such delay
 along with liability for penalty.
- How to calculate the
 interest for late
 payment of tax for
 the months of
 February, March
 and April, 2020 for a
 registered person
 whose aggregate
 turnover in
 preceding financial
 year is above Rs. 5
 Crore?
- As explained above, the rate of interest has been notified
 as Nil for first 15 days from the due date, and 9 per cent per
 annum thereafter, for the said months. The same can be
 explained through an illustration.
 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
 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
 Circular No. 136/06/2020-GST
 Page 4 of 5
 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) 5. What are the
 conditions attached
 for availing the NIL
 rate of interest for
 the months of
 February, March
 and April, 2020, for a
 registered person
 whose aggregate
 turnover in
 preceding financial
 year is up to Rs. 5
 Crore?
- As clarified at sl.no. (2) above, the due date for furnishing
 the return remains unchanged. The rate of interest has been
 notified as Nil for the said months.
- The conditions for availing the NIL rate of interest is that
 the registered person must furnish the returns in FORM
 GSTR-3B on or before the date as mentioned in the
 notification No. 31/2020- Central Tax, dated 03.04.2020.
- In case the return for the said months are not furnished on
 or before the date mentioned in the notification then interest
 at 18% per annum shall be charged from the due date of
 return, till the date on which the return is filed as
 explained in the illustration at sl.no (4) above, against entry
- In addition, regular late fee shall also be leviable for such
 delay along with liability for penalty.
- Whether the due
 date of furnishing the
 statement of outward
 supplies in FORM
 GSTR-1 under
 section 37 has been
 extended for the
 months of February,
 March and April
 2020?
 Under the provisions of section 128 of the CGST Act, in
 terms of notification No. 33/2020- Central Tax, dated
 03.04.2020, late fee leviable under section 47 has been
 waived for delay in furnishing the statement of outward
 supplies in FORM GSTR-1 under Section 37, for the tax
 periods March, 2020, April 2020, May, 2020 and quarter
 ending 31st March 2020 if the same are furnished on or before
 the 30th day of June, 2020.
- Whether restriction
 under rule 36(4) of
 the CGST Rules
 would apply during
 the lockdown
 period?
 Vide notification No. 30/2020- Central Tax, dated
 03.04.2020, a proviso has been inserted in CGST Rules 2017
 to provide that the said condition shall not apply to input tax
 credit availed by the registered persons in the returns in
 FORM GSTR-3B for the months of February, March, April,
 May, June, July and August, 2020, but that the said condition
 shall apply cumulatively for the said period and that the
 return in FORM GSTR-3B for the tax period of September,
 2020 shall be furnished with cumulative adjustment of input
 tax credit for the said months in accordance with the
 condition under rule 36(4).
- What will be the
 status of e-way bills
 which have expired
 In terms of notification No. 35/2020- Central Tax, dated
 03.04.2020,Issued under the provisions of 168A of the CGST
 Act, where the validity of an e-way bill generated under rule
 Circular No. 136/06/2020-GST
 Page 5 of 5
 during the lockdown
 period?
 138 of the CGST Rules expires during the period 20th day
 of March, 2020 to 15th day of April, 2020, the validity
 period of such e-way bill has been extended till the 30th day
 of April, 2020.
- What are the
 measures that have
 been specifically
 taken for taxpayers
 who are required to
 deduct tax at source
 under section 51,
 Input Service
 Distributors and
 Non-resident
 Taxable persons?
 Under the provisions of section 168A of the CGST Act, in
 terms of notification No. 35/2020- Central Tax, dated
 03.04.2020, the said class of taxpayers have been allowed to
 furnish the respective returns specified in sub-sections (3),
 (4) and (5) of section 39 of the said Act, for the months of
 March, 2020 to May, 2020 on or before the 30th day of June,
 2020.
- What are the
 measures that have
 been specifically
 taken for taxpayers
 who are required to
 collect tax at source
 under section 52?
 Under the provisions of section 168A of the CGST Act, in
 terms of notification No. 35/2020- Central Tax, dated
 03.04.2020, the said class of taxpayers have been allowed to
 furnish the statement specified in section 52, for the months
 of March, 2020 to May, 2020 on or before the 30th day of
 June, 2020.
- The time limit for
 compliance of some
 of the provisions of
 the CGST Act is
 falling during the
 lock-down period
 announced by the
 Government. What
 should the taxpayer
 do?
 Vide notification No. 35/2020- Central Tax, dated
 03.04.2020, issued under the provisions of 168A of the CGST
 Act, except for few provisions covered in exclusion clause,
 any time limit for completion or compliance of any action
 which falls during the period from the 20th day of March,
 2020 to the 29th day of June, 2020, and where completion or
 compliance of such action has not been made within such
 time, has been extended to 30th day of June, 2020.
- It is requested that suitable trade notices may be issued to publicize the contents of this
 circular.
- Difficulty, if any, in the implementation of the above instructions may please be
 brought to the notice of the Board. Hindi version would follow.
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