FAQs on Form GSTR 6-Return for Input Service Distributor (ISD)!

From April 1, 2025, the ISD mechanism has been made compulsory. Form GSTR-6 is a crucial monthly return that Input Service Distributors (ISDs) must file to distribute Input Tax Credit (ITC) among their units. Understanding its filing requirements, deadlines, and structure is essential for compliance with GST regulations. This FAQ guide aims to address common queries regarding Form GSTR-6, helping ISDs navigate the filing process seamlessly while avoiding penalties and errors.

Let's understand some FAQs about Form GSTR 6!

FAQs- Form GSTR 6:

 1. What is Form GSTR-6?

Form GSTR-6 is a monthly return to be filed by all the Input Service Distributors (ISD) for the distribution of credit (ITC) amongst its units.

2. Who needs to file Form GSTR-6 and is it mandatory to file this form?

Only those persons who are registered as Input Service Distributors (ISD) need to file Form GSTR-6. It is a mandatory return, to be filed on a monthly basis. A ‘Nil’ return must be filed in case no ITC is available for distribution or no ITC is being distributed during the month.

3. When do I need to file Form GSTR-6?

ISD Returns for month M can only be filed on or before the 13^th of month M+1 or the extended date, if any.

4. From where can I as a taxpayer file Form GSTR-6?

Form GSTR-6 can be accessed on the GST Portal, post login in the Returns Dashboard by the taxpayer.

The path is Services > Returns > Returns Dashboard.

5. Form GSTR-6 comprises which tables?

Form GSTR-6 comprises of following tables:

Form GSTR-6 Invoice Details:

1. Table 3: To enter details of input tax credit received for distribution.

2. Table 6B: To enter details of debit or credit notes received.

3. Table 6A: To make amendments to information furnished in earlier returns in Table 3.

4. Table 6C: To make amendments to debit or credit notes received.

Form GSTR-6 ITC Distribution:

5. Table 4: To view details of ITC available and eligible and ineligible ITC distributed.

6. Table 5, 8: To enter details of the distribution of input tax credit for ISD invoices and ISD Credit notes.

7. Table 9: To enter details of ITC available and eligible and ineligible ITC redistributed.

GSTR-6 - Other Details:

8. Table 10- Late Fee: To view Late Fee details for the return period.
Note: This tile can only be accessed after the return has been filed.

6. Can I file my ISD return if my counter-parties have not filed Form GSTR-1/5?

Yes, you can file your Form GSTR-6 return even if your counter-parties have not filed their respective Form GSTR-1 or Form GSTR-5.

7. Is there any Offline Tool for filing Form GSTR-6?

Yes, there is an offline tool for filing Form GSTR-6.

8. Is there any late fee in case of delayed filing of Form GSTR-6?

Yes, there is a late fee prescribed in Law.

9. Is there an Electronic Credit Ledger available for ISD Registrations?

No, there is no Electronic Credit Ledger maintained for ISD Registrants, since ISD has to only distribute credit available during a tax period.

10. As an ISD, am I liable to pay tax on a reverse charge basis? OR Is reverse charge applicable to ISDs?

No. Reverse charge liability is not applicable for an ISD person.

11. How do I allocate credit to my other units in Form GSTR 6?

Using Table 5 and Table 8 of Form GSTR-6, both eligible and ineligible ITC can be distributed to the units.

12. Can I amend the credit allocated to the units in Form GSTR 6 of earlier tax periods? If yes, how?

You can distribute the credit through the ISD invoice and provide the details in Table 5 and Table 8 of the Form GSTR-6, indicating both eligible and ineligible distribution to the units.

13. Can the date of filing of Form GSTR-6 be extended?

Yes, the date of filing of Form GSTR-6 can be extended by the Government through notification.

14. What are the pre-conditions for filing Form GSTR-6?

Pre-conditions for filing of Form GSTR-6 are:

· Recipient should be Registered as an ISD and should have an active GSTIN.

· Recipient should have valid login credentials (i.e., User ID and password).

· Recipient should have a valid and non-expired/ unrevoked Digital Signature Certificate (DSC which is mandatory for companies, LLPs and FLLPs).

· Recipient should have with them an active mobile number which is indicated in their registration details furnished to GST Portal at the time of registration or amendment thereof for authentication through EVC.

· Recipient will have the option to file Form GSTR-6 for cancelled GSTINs for the period in which it was active.

15. What happens after Form GSTR-6 is filed?

After Form GSTR-6 is filed:

• ARN is generated on successful filing of the Form GSTR-6 Return.
• An SMS and an email are sent to the applicant on their registered mobile and email id.

16. What are the modes of signing Form GSTR-6?

You can file Form GSTR-6 using DSC, or EVC.

(a) Digital Signature Certificate (DSC)

Digital Signature Certificates (DSC) are the digital equivalent (that is electronic format) of physical or paper certificates. A digital certificate can be presented electronically to prove one’s identity, to access information or services on the Internet or to sign certain documents digitally. In India, DSC is issued by authorized Certifying Authorities. The GST Portal accepts PAN-based DSC’s only.

(b) Electronic Verification Code (EVC)

The Electronic Verification Code (EVC) authenticates the identity of the user at the GST Portal by generating an OTP. The OTP is sent to the mobile phone number of the registered mobile phone of the Authorized Signatory filled in part A of the Registration Application.

17. Can I preview Form GSTR-6 before submitting it?

Yes, you can preview Form GSTR-6 before submitting it on the GST Portal.

18. I have a credit note in CGST & SGST, with no Input Tax Credit available in CGST & SGST, but credit in IGST is available. Hence, credit available for distribution in CGST & SGST is negative, what will be the implications?

If the reversal of the Input Tax Credit exceeds the credit available under any of the major heads, during a tax period, then the sum under such head will become negative. The excess reversal, over available input tax credit is added to the liability. Consequentially the total credit available for distribution will be reduced accordingly.

Total credit available i.e. IGST+CGST+SGST will always be equal to the total credit to be distributed (IGST+CGST+SGST), including the liability due to negative credit. Hence, the total credit available for distribution will be the sum of -

I. Inward supplies received during the month (net of credit/debit notes and amendments of invoices and credit/debit notes).

II. Receipt of credit notes will reduce the ITC available for distribution while receipt of debit notes will increase the same.

III. Availability of ITC, due to issue of ISD credit notes to its units.

IV. Availability and distribution of Cess will always be the same as it is not cross-utilised with any of the major heads.

For example:-

1. Credit available in IGST - 1,08,000 INR
2. Negative credit available in CGST & SGST - 43,200 INR each (Amount of credit note is more than credit available in CGST & SGST)
3. Total credit available for distribution – [Sum of IGST=1,08,000, CGST= -43200 & SGST= -43200] = 21600 INR
4. Total input tax credit available for distribution i.e. 21600 INR only will be bifurcated to the eligible and ineligible credit.

19. Which State code is to be selected as the place of supply (PoS) in case of transportation of goods outside India, by a registered taxpayer on behalf of a registered recipient?

In case of supply of services (by a registered taxpayer) by way of transportation or courier of goods to a place outside India, the place of supply is the foreign country outside India (being the destination of such goods).

For reporting such transactions, where POS lies in a foreign country, the supplier of services (the registered taxpayer) needs to select the State code ‘96-Foreign Country’ from the list of codes.

The registered recipient of services will then be entitled to ITC, though POS lies outside the State of their registration, in case State code 96 is mentioned by of the supplier of services (the registered taxpayer) in their statement of outward supplies.

Illustration – Supplier of goods ‘A’ is registered in State ‘X’ in India and has got an order for supply from a foreign country ‘F’. Supplier ‘A’ asked another taxpayer ‘B’ registered in the same State ‘X’ to supply services (couriers etc.) for transportation of goods to the foreign country. Taxpayer ‘B’ will issue an invoice in the name of ‘A’ and mention POS as state code 96. Though both the taxpayers are located in the same State by virtue of POS as 96, the supply will be taxable under IGST and ITC will be available to taxpayer ‘A’ under IGST head.

20. What would be the type of supply when the State Code is selected as ‘96-Foreign Country’?

Supplies with Place of Supply selected as state code ‘96-Foreign Country’ will always be inter-State supply.

21. In which tables of Form GSTR-6 the State Code as ‘96-Foreign Country’ will be available for selection from the dropdowns?

The state code ’96-Foreign Country’ will be available for selection in the existing list of Place of Supply (POS) drop-down in the following tables of Form GSTR-6:

i. B2B (Table 3)

ii. B2B Amendments (Table 6A)

22. What is the difference between Form GSTR-6 before and after delinking of Credit/ Debit Notes?

23. I have already saved Debit/ Credit note details online, before delinking of Debit/ Credit Note with invoice details, but have not filed the returns. What will happen to such saved Debit/ Credit note details?

If you have saved Credit/ Debit Note details, before delinking of Credit/ Debit Note with invoice details, it will be saved in old format only and the same can be used to submit the details, as it is. (It will appear in a new format if you try to edit and save the same again).

Post-delinking of Credit/ Debit Note with invoice details, you can edit the saved Credit/ Debit note in post-delinking format only (Original Invoice Number and Date will not be available and entering POS is mandatory).

Note: In case you are filing the return without editing the saved record, it will be filed in the old format only.

24. I have generated the JSON file from an old Excel utility before delinking of Credit/ Debit Note but have not uploaded it on the GST Portal. Can I upload the same after delinking of Debit/ Credit Note?

No, you cannot upload the JSON file generated before delinking of Credit/ Debit Note. You need to update the details manually in the new offline Excel utility again and then generate the new JSON file to upload it onto the GST Portal.

25. I have already filed Form GSTR-6 for a particular tax period before delinking of Credit/ Debit Note. Do I need to file Form GSTR-6 again for that tax period post-delinking of the Debit/ Credit Note?

If you have already filed Form GSTR-6 for a particular tax period, before delinking of Credit/ Debit Note with invoice details, there is no need to file Form GSTR-6 again, for that tax period.

26. Uploaded invoices are not visible on Form GSTR-6. How can I proceed to file GSTR-6?

If uploaded invoices are not visible, perform the following steps:

1. Navigate to Table 4 - Total ITC available and Eligible ITC/Ineligible ITC distributed.
2. Click on the Calculate ITC button in the table.
3. Click on the small Refresh button on the right corner in the screen.
4. Offset the ITC correctly and click on the Save button.
5. Click on the Back button and go back to the Dashboard.
6. Click on the PROCEED TO FILE button.
7. Click on the small Refresh button on the right corner of your screen.
8. Once the status on the header says - Ready to file, all your invoices will be visible.

27. What happens if I add invoices/debit notes/credit notes which are dated after the date of cancellation of registration of supplier?

You cannot add invoices/debit notes/credit notes which are dated after the date of cancellation of registration of supplier. They should be dated on or after the date of grant of registration of supplier and before the effective date of cancellation of registration of supplier.

Similarly, in the case of amendment tables, revised invoices/debit/credit notes should be dated on or after the date of grant of registration of supplier and before the effective date of cancellation of registration of supplier.

28. What happens if I add invoices/debit notes/credit notes which are dated after my registration is cancelled?

You cannot add invoices/debit notes/credit notes which are dated after your registration is cancelled. They should be dated on or after your registration grant date and before your registration is cancelled.

Similarly, in the case of amendment tables, revised invoices/debit/credit notes should be dated on or after your registration grant date and before your registration is cancelled.

29. Will the applicable late fee for a tax period be carried forward to the next period?

Since the filing of form GSTR-6 is now a one-step process where Form GSTR-6 is frozen only on filing of the return, therefore, the late fee will be for the current period only and will not be carried forward to the next period.  

30. What happens in case there is insufficient balance to pay off the liabilities?

In case of insufficient balance, you can add balance by creating challan to pay off your liabilities.

Conclusion

Filing Form GSTR-6 accurately and on time is essential for proper ITC distribution and GST compliance. This guide has covered key aspects, from eligibility and filing process to amendments and penalties. Staying updated with GST regulations and using available tools like the offline utility can ensure a smooth filing experience. For further clarifications, always refer to official GST notifications or seek professional advice.

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