GST WEEKLY UPDATE : 49/2024-25 (09.03.2025) By CA Vipul Khandhar

-By CA Vipul Khandhar

1. Enhancements in Biometric Functionality – Allowing Directors to Opt for Biometric Authentication in Their Home State-Advisory:

You may be aware that new GST registration applicants who opt for Aadhaar authentication are required to undergo the process either through OTP verification or Biometric Authentication at a designated GST Suvidha Kendra (GSK), based on system-driven data analysis. To facilitate a seamless process, GSTN provides a slot booking facility, with the link shared in the intimation email sent to the applicant.

As per the existing system, applicants selected for Biometric Authentication must visit the designated GSK mapped to their jurisdiction. However, GSTN has now introduced an additional facility allowing certain Promoters/Directors to complete their Biometric Authentication at any GSK in their Home State.

This facility applies to individuals listed in the Promoter/Partner tab for the following types of businesses:

• Public Limited Company
• Private Limited Company
• Unlimited Company
• Foreign Company

Under this enhancement, such Promoters/Directors can now choose any available GSK within their Home State in India (as per REG-01) for Biometric Authentication.

Key Points to Note:

1. If a new registration application is selected for Biometric Authentication, an intimation email will be sent to the applicant. Eligible Promoters/Directors will be given the option to select any GSK in their Home State through this email.
2. To avail of this option, such Promoter/Director must follow the instructions provided in the intimation email and select a GSK within their home state.
3. The selection of a GSK in the Home State is a one-time facility and cannot be changed once selected. Promoters/Directors are advised to choose their GSK carefully.
4. This facility is currently available in 33 States/UTs where Biometric Authentication has been enabled. It will soon be extended to the remaining three states: Uttar Pradesh, Assam, and Sikkim. Such Promoters/Directors whose Home State is other than Uttar Pradesh, Assam, or Sikkim can opt for any GSK in their Home State.
5. Upon selection of a Home-State GSK, the Promoter/Director will receive an email confirmation, along with a new slot booking link.
6. Using the provided link, the Promoter/Director can book a slot at their convenience, subject to availability at the chosen GSK.
7. The required photo capture and Biometric Authentication process will be completed at the selected GSK in the Home State.
8. If a Promoter/Director has already completed the biometric process, they will not be required to undergo it again.
9. If the Promoter/Director and the Primary Authorized Signatory (PAS) are the same person, the Home-State GSK selection option will not be available. The PAS must visit the designated jurisdictional GSK for the required process, including document verification.
10. To ensure a smooth process, it is advised that the Promoter/Director completes Biometric Authentication before the Primary Authorized Signatory visits the GSK.
11. Opting for Biometric Authentication at a GSK in the home state is not mandatory. Promoters/Directors can visit their designated jurisdictional GSK if preferred.

Taxpayers are requested to follow this advisory for the smooth processing of their GST registration applications. 

2. The Government of Rajasthan, Commercial Taxes Department has issued Notification vide No. F.16(752)VAT/Tax/CCT/2025-26/822 dated February 27, 2025notifies the procedure for Amnesty Scheme-2025 for disposal of outstanding demand or disputed amount:

Applying for willingness: –

Registered, Cancelled and Unregistered Dealers/Persons may apply on the web portal of Commercial Taxes Department (www.rajtax.gov.in) for expressing their willingness to take benefit under the scheme using the link ‘Amnesty Scheme-2025‘.

Registered and Cancelled dealers need to login on RajTAX Portal using their Login ID (TIN) and Password. The unregistered dealers/persons can apply through the RajTAX portal without login.

Communication of outstanding demand(s)/disputed amount by assessing authority to the applicant: 

On submission of the task by the Assessing Authority, all the data pertaining to the demand/disputed amount shall be made available to the applicant. The registered dealer shall be able to view the same through his logins —> Amnesty Scheme-2025 —> Review AS-I filled by authority. Similarly, the unregistered dealers/persons shall be able to view the same by clicking on Amnesty Scheme-2025 —> Application by unregistered dealer/person —> Review AS-I filled by authority and track status, after entering their mobile number, email ID and acknowledgement number of AS-W and submitting the same.

The applicant shall have the option to choose from ‘Accept’, ‘Revert’ or ‘Not interested’ in the drop down box to act upon the received outstanding demand/disputed amount entered by the Assessing Authority. The applicant may avail benefit under the scheme for any number of demand/disputed amount out of multiple pending demand/disputed amount. Benefit for any demand or disputed amount shall be allowed in totality and not partially for an entry. However, if there are multiple entries of interest and sum total of same is more than rupees twenty five crore under any Act against an applicant, the benefit to the applicant shall be computed on sum total of all entries under category number 2 of Table. The applicant will be allowed to avail revert option two times only.

If the applicant agrees and accepts the final amount for payment as AS-I submitted by the Assessing Authority, then he is provided two options as per the Scheme. He has to pay the amount within 10 days from the day on which the Assessing Authority conveys the final amount required to be paid under the Scheme or before the last date of the Scheme i.e. 30-09-2025, whichever is later. The applicant may make the payment for all the entries by a single challan through e-GRAS Portal for all accepted demand or separately for each entry.

If the applicant has already paid the demand on e-GRAS portal, then he can enter the GRN of the payment in the column of GRN of AS-I Except the application which falls under the Clause 7(2) of the Amnesty Scheme-2025, for new applicant GRN of payments made on or after 19.02.2025 shall be accepted.

Generation of Form AS-II: –

Where final amount is not reverted, the applicant after making the payment for the accepted demand(s)/ disputed amount shall submit the AS-I. At this stage, a provisional AS-II shall be auto generated at the dealer’s ID and simultaneously a task will be created on the Assessing Authority for pending DCR adjustment. Except litigation cases, the Assessing Authority shall approve the task and make the necessary adjustments in the DCR. Once the task is approved by the Assessing Authority, Form AS-II shall be generated at the dealer’s ID.

The Assessing Authority shall forward the copy of Form AS-II to the Deputy Commissioner (Administration) concerned and he shall also forward the copy of Form AS-II to the Commissioner, in the cases where total amount of waiver is above rupees ten lac. 

Withdrawal of litigation: –

In case of any pending litigation(s) in respect of outstanding demand or disputed amount the applicant shall make the payment of requisite amount and will submit AS-I. Simultaneously, applicant may upload the proof of withdrawal of legal cases/litigation(s) at the time of submitting AS-I or he may submit manually to the concerned Assessing Authority within 15 days of submission of AS-I.

After receipt of proof of withdrawal of legal cases/litigation(s) from the applicant, Assessing Authority shall approve the task, if it is found in order and give adjustment in DCR. When the proof of withdrawal of litigation is submitted manually in the office, the Assessing Authority shall upload the same in the pending task for approving AS-II.

In case, applicant fails to submit proof of withdrawal of litigation, the Assessing Authority shall move an application to concerned Court that the case is rendered infructuous as the applicant has taken benefit of the scheme and shall proceed further to upload it in the pending task for approving AS-II.

In all cases pending for proof of withdrawal of litigation, the adjustment of reduction of demand in the DCR shall be given only after the submission of withdrawal application or intimation to the concerned Court.

3. As FY 2024-25 comes to an end, businesses must take proactive steps to ensure a seamless transition to FY 2025-26 and remain in full compliance with GST regulations. Here’s a comprehensive guide on the key activities to consider:

GST Returns and Adjustments:

Reconcile GSTR-1 with GSTR-3B.

Adjust taxes paid on advances in books and GST returns.

Verify 6-digit HSN reporting if turnover exceeds ₹5 crores.

Input Tax Credit (ITC) Checks:

Reconcile books with GSTR-2B and GSTR-3B.

Follow up with vendors for missing ITC invoices.

Reverse ITC for free samples as per Rule 42/43.

Ensure ITC closing balance matches the electronic credit ledger (ECL).

Check the two-year time limit for refunds.

Reverse Charge Mechanism (RCM) Compliance:

Ensure self-invoicing for reverse charge supplies.

Verify RCM applicability on services like rent-a-cab, directorship fees, legal fees, and import of services.

Outward GST Compliance:

Reconcile revenue between books and GST returns.

Identify GST liability on other incomes.

Discharge GST on liabilities written off.

Ensure e-invoicing compliance if aggregate turnover exceeds ₹5 Crore, with a 30-day generation limit for turnover above ₹10 Crore.

ISD Compliance:

Distribute common Input Tax Credit (ITC) through Input Service Distributor (ISD) based on turnover.

File a monthly GSTR-6 return and ensure invoices for services are raised.

Other Key Year-End Compliances:

Renew LUT for exports.

Implement a new 16-digit invoice series.

File annual RoDTEP return for FY 2023-24 by March 31, 2025.

Update IEC on the DGFT portal (April-June).

Annual Closure of Books of Accounts:

File LUT for zero-rated supplies for FY 2025-26 by March 31, 2025.

Opt-in for GST Composition Scheme for FY 2025-26 by March 31, 2025.

Opt-in or out of QRMP for FY 2025-26 by April 30, 2025.

Obtain declarations from Goods Transport Agency (GTA) for opting to pay GST under Forward Charge for FY 2025-26.

Reset invoice number series.

Recalculate aggregate turnover of FY 2024-25 for various compliances.

Reconciliation of Supplies:

Reconcile turnover as per books of accounts vs turnover as per GST returns.

Reconcile physical stock vs stock as per books of accounts.

Match closing balance of ITC as per books with the GST portal.

Reconcile pending ITC not matched with GSTR-2B.

Reversal of ITC:

Calculate the reversal of ITC as per Rule 42 for exempted supplies and account for any excess or short reversal in GST returns for March 2025.

Reverse ITC for unpaid vendors after 180 days as per Rule 37, along with interest .

E-invoice Registration:

Businesses with aggregate turnover exceeding ₹5 crores during FY 2024-25 must generate e-invoices from April 1, 2025.

Export of Goods/Services:

Ensure inward remittances comply with FEMA regulations to avoid refund reversals.

             By adhering to this checklist, businesses can navigate GST compliance effectively and ensure a smooth transition into the new financial year.

Disclaimer:

This publication contains information for general guidance only. It is not intended to address the circumstances of any particular individual or entity. Although the best of endeavour has been made to provide the provisions in a simpler and accurate form, there is no substitute to detailed research with regard to the specific situation of a particular individual or entity. We do not accept any responsibility for loss incurred by any person for acting or refraining to act as a result of any matter in this publication.

(Author is a well known Chartered Accountant practicing on direct and indirect taxes at Ahmedabad)