Page 64 - GSTL_2nd July 2020 _Vol 38_Part 1

C4 GST LAW TIMES [ Vol. 38
persons for the tax period of February, March and April, 2020. The same was
clarified through Circular No. 136/06/2020-GST, dated 3-4-2020 (para 3, sl. No.
3, 4 and 5). It was clarified that in case the return for the said months are not
furnished on or before the date mentioned in the notification No. 31/2020-
Central Tax, dated 3-4-2020, interest at 18% per annum shall be charged from the
due date of return, till the date on which the return is filed.
3.2 The Government, vide notification no. 51/2020-Central Tax, dated
24-6-2020 has removed the said condition. Accordingly, 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 till 24-6-2020 is notified. After the specified date, normal rate of interest
i.e. 18% per annum shall be charged for any further period of delay in furnishing of the
returns.
3.3 The calculation of interest in respect of this class of registered
persons for delayed filing of return for the month of March, 2020 (due date of
filing being 20-4-2020) is as illustrated in the Table below :
TABLE
Sl. Date of filing No. of days Interest
No. GSTR-3B of delay
1 2-5-2020 12 Zero interest
2 20-5-2020 30 Zero interest for 15 days, thereafter
interest rate @ 9% p.a. for 15 days
3 20-6-2020 61 Zero interest for 15 days, thereafter
interest rate @ 9% p.a. for 46 days
4 24-6-2020 65 Zero interest for 15 days, thereafter
interest rate @ 9% p.a. for 50 days
5 30-6-2020 71 Zero interest for 15 days, thereafter interest
rate @ 9% p.a. for 50 days and interest rate
@ 18% p.a. for 6 days

Manner of calculation of interest for taxpayers having aggregate turnover below
Rs. 5 Cr.
4.1 For the taxpayers having aggregate turnover below Rs. 5 Crore,
notification No. 31/2020-Central Tax, dated 3-4-2020 provided a conditional NIL
rate of interest for the tax period of February, March and April, 2020. The
Government, vide notification no. 52/2020-Central Tax, dated 24-6-2020
provided the NIL rate of interest till specified dates in the said notification and
9% per annum thereafter till 30th September, 2020. Similar relaxation of reduced
rate of interest has been provided for the tax period of May, June and July, 2020
also for the said class of registered persons having aggregate turnover below Rs.
5 Crore in the preceding financial year. The notification, thus, provides NIL rate of
interest till specified dates and after the specified dates lower rate of 9% would apply till
30th September, 2020. After 30th September, 2020, normal rate of interest i.e. 18% per
annum shall be charged for any further period of delay in furnishing of the returns.
4.2 The calculation of interest in respect of this class of registered
persons for delayed filing of return for the month of March, 2020 (for registered
persons for whom the due date of filing was 22-4-2020) and June, 2020 (for
registered persons for whom the due date of filing is 22-7-2020) is as illustrated in
the Table below :
GST LAW TIMES  2nd July 2020  64