Clarification about GSTR 9 & 9C (Press Release dt. 03.07.2019)

[Ashwarya Agarwal]

CBIC has come up with its 2nd Press Release dt. 03.07.2019, wherein it has tried to clarify certain issues faced by taxpayer in filing of GST Anuual Return & GST reconciliation in Form GSTR 9 & 9C respectively. Some important clarification is summarised as below:

Primary data source for declaration in annual return

1. Ideally, information in FORM GSTR-1, FORM GSTR-3B and books of accounts should be synchronous and the values should match across different forms and the books of accounts. If the same does not match, any output tax payable may be declared in Annual return and paid through DRC-03. Any excess paid tax may be declared in annual return and claimed as refund (if eligible);

2. No ITC can be reversed or availed through the annual return. any ITC to be reversed, can be done through DRC 03;  

Aggregate Turnover for GSTR 9C

3. The aggregate turnover for this purpose shall be reckoned for the period July, 2017 to March, 2018;

4. The turnover of all the registrations having the same PAN is to be used for determining the requirement of filing of reconciliation statement;

Input Tax Credit

5. Figures in Table 8A of Form GSTR-9 are auto-populated only for those Form GSTR-1 filed by the suppliers by 30.04.2019. Thus, ITC on supplies made during the financial year 2017-18, if reported beyond the said date by supplier, it will not get auto-populated in said Table 8A. This will lead to difference in figure as per GSTR 2A and table 8A of GSTR 9;

6. Difference in figure of ITC availed as per table 4A of GSTR 3B and table 8A of GSTR 9 should be considered as lapsed, as the deadline has already passed and the taxpayer cannot avail such credit now;

7. Similarly figure in table 8J of GSTR 9 (ITC on import) should also be considered as lapsed, as the deadline has already passed and the taxpayer cannot avail such credit now;

Details of HSN of Inward Supply, Exempted, NIL rated and Non GST supply

8. Considering the challenges faced by taxpayers in providing these details, it is advised to provide data to the best of knowledge and records. This data is only for information purpose, as there is no tax payable. Any reasonable/explainable variations in the information reported in these tables will not be viewed adversely; 

Treatment of Credit Notes / Debit Notes issued during FY 2018-19 for FY 2017-18

9. It is important to note that no CN which has a GST implication could be issued after the month of September 2018 for any supply pertaining to FY 2017-18. Any CN issued after that was commercial / financial CN with no GST impact. 

Any CN / DN related to any supply pertaining to FY 2017-18,  issued in FY 2018-19 within prescribe time and disclosed in return filed for FY 2018-19, than it is to be shown in table 10 / 11 of GSTR 9 and  Table 5O of the reconciliation statement in GSTR-9C. 

Reconciliation of ITC availed on expenses (Table 14 of GSTR 9C)

10. It is clarified that only those expenses are to be reconciled where ITC has been availed. Further, the list of expenses given in Table 14 is a representative list of heads under which ITC may have been availed. The taxpayer has the option to add any head of expenses.   

Note: The role of a CA or CMA with respect to the reconciliation statement is limited to reconciling the values declared in annual return (GSTR-9) with the Audited annual accounts of the taxpayer. However GSTR 9 should be prepared very cautiously, considering any tax short-pai or not-paid or any ITC to be reversed.

I hope you find the same helpful.