List of Optional Tables in GST Annual Return for F.Y. 2019-20 in Form GSTR-9 & 9C

[Ganeshan Kalyani]

As per section 44(1) of CGST Act, 2017, every registered person shall furnish through online mode an annual return for every financial year in prescribed forms on or before 31st day of December following the end of such financial year.

The person exempted to file annual return are Input Service Distributor (ISD), a person paying tax under section 51 (person liable to deduct TDS) or section 52 (person liable to collect TCS), a casual taxable person and a non-resident taxable person.

As per the above stated provision the due date for filing annual return for F.Y. 2019-20 was 31.12.2020. However, due to the fact that FY 2018-19 was to be filed by 30.12.2020, the due date for FY 2019-20 is extended till 28.02.2021 vide notification no. 95/2020 - Central Tax dated 30.12.2020. 

Sec 44(1) was amended vide notification no. 47/2019 – Central Tax dated 09.10.2019 to provide option to taxpayers whose aggregate turnover did not exceed two crore rupees in FY 2017-18 and 2018-19 for filing of annual return. The same option from filing of annual return in Form GSTR-9 is also given for FY 2019-20 vide notification 77/2020 – Central Tax dated 15.10.2020. Thus, the taxpayer whose turnover did not exceed two crore rupees in FY 2019-20 need not file annual return. 

Further, section 35(5) read with rule 80(3) states that for FY 2019-20 every registered person whose aggregate turnover exceeds five crore rupees shall get his accounts audited by a Chartered Accountants or a Cost Accountants. This indicates that the taxpayers whose turnover did not exceeded five crore rupees need not get his accounts audited for the said financial year. The proviso to rule 80(3) provides that such relief is only for FY 2019-20. That means for subsequent years the turnover limit for getting the books audited from a Chartered Accountants or a Cost Accountants is two crore rupees.

From the above stated provision, it is understood that taxpayers whose aggregate turnover did not exceed two crore rupees need not file annual return. And, taxpayers whose aggregate turnover exceeds two crore rupees but is below five crore rupees then the annual return is required to filed. And, all taxpayers whose turnover exceeds five crore rupees must file annual return and as well as get his accounts audited by Chartered Accountants or a Cost Accountants. This is presented in a tabular form as below for better understanding.

Turnover	GSTR-9	GSTR-9C
Up to 2 Crore	Optional	Optional
2 Crore to 5 Crore	Mandatory	Optional
5 Crore and above	Mandatory	Mandatory

Following tables are optional in Form GSTR-9 and 9C for filing for FY 2019-20:

1. There is an option in furnishing the input tax credit in table 6B, 6C, 6D, 6E of GSTR-9, into two heads instead of three. ITC on capital goods will have to be furnished separately and, ‘inputs’ and ‘input services’ can be either shown separately or in ‘inputs’ itself. 

2. Also, there is an option to furnish the input tax credit details either in table 6C and 6D or in 6D only. 

3. The ITC reversal in table 7 can either be shown separately in 7A, 7B, 7C, 7D, 7E, 7F, 7G or it can be shown in 7H itself.

4. Table 8A contains details of ITC auto-populated from GSTR-2A as on 01.11.2020.

5. Table 15A, 15B, 15C & 15D, pertaining to the details of refund claimed, refund sanctioned etc. is optional. 

6. Table 15E, 15F & 15G pertaining to demands of taxes etc. is optional.

7. Table 16A pertaining to detail of purchase from composition dealer is optional.

8. Table 16B pertaining to deemed supply to job-worker is optional

9. Table 16C pertaining to deemed supply of goods sent on approval basis is optional

10. Table 17 & 18 pertaining to HSN summary for outward supplies and inward supplies is optional.

11. Table 14 of GSTR-9C is optional. This table asks for reconciliation of ITC declared in GSTR-9 with ITC availed on expenses as per audited annual financial statement or as per books.

The above optional tables are notified for FY 2019-20 vide notification no. 79/2020 – Central Tax dated 15.10.2020.

Author’s view:

The taxpayers whose turnover is more than five crore rupees need to start the preparation of annual return now itself as the time left is only one month. The due date is 28.02.2021. Also, appointment of auditor should be done soon and the auditing task should also be initiated. As seen above various tables are optional for furnishing the details in GSTR-9 & 9C. Therefore, the taxpayer may wisely choose to avail the benefit of the same and file return with only mandatory fields.