All about GSTR-9 & GSTR-9C for FY 2019-20

[pratish goel]

ALL ABOUT GSTR-9 & GSTR-9C REPORTING REQUIREMENTS

FOR FY 2019-20

Recently financial budget 2021 has proposed to omit the provision section 35(5) and amend the section 44 of CGST Act, 2017. After acceptance of bill by president of India GST audit need not to file. Recently CBIC clarified through retweet on tweeter that “Section 35 and 44 of CGST Act are proposed to be amended in Finance Bill, 2021. However, these proposals will come into effect from a date to be notified later. For FY 2019-20, the existing provisions shall continue.”

GSTR-9

• Form GSTR-9 is an annual return which is required to be filed as per section 44 read with rule 80(1) of CGST rules, 2017. Initially annual return was required to be filed by every registered person irrespective the amount of turnover. Thereafter CBIC issued Notification No. 47/2019 and 77/2020- Central Tax gives benefit of optional filing of annual return for registered person whose aggregate turnover in a financial year does not exceed ₹ 2 crore, for F.Y. 2017-18, F.Y. 2018-19 and FY 2019-20 as well.

GSTR-9C

• Form GSTR-9C is a statement of reconciliation between the annual return GSTR-9 filed and the amount as per the audited financial statement of the taxpayer. GSTR-9C is required to file by the taxpayer as per section 35(5) read with rule 80(3) of CGST rules, 2017. Initially annual return was required to be filed by every registered person having turnover exceeding ₹ 2 Cr. Thereafter CBIC issued Notification No. 16/2020- Central tax dated 23^rd March, 2020 to revise the threshold limit to ₹ 5 Cr. For F.Y. 2018-19 & onwards.

Applicability of GSTR-9 & GSTR-9C for FY 2019-20

Table No	Particulars	GSTR-9	GSTR-9C
	Turnover up to ₹ 2 Cr.	Optional	Optional
	Turnover more than ₹ 2 Cr. And up to ₹ 5 Cr.	Mandatory	Optional
	Turnover more than ₹ 5 Cr.	Mandatory	Mandatory

Table-wise details requirement in form GSTR-9

Forms contain tables which are required to be filled by the taxpayers. As the GST is new for all, there are lots of confusions amongst the taxpayer regarding collection of data and how to fill the tables. CBIC issued notification 74/2019 and amended the form GSTR-9 and GSTR-9C and made some tables, clause of the form optional. Table-wise details required is as below:

Table No.	Particulars	FY 2019-20
4.	Details of advances, inwards and outward supplies on which tax is payable as declared in returns filed during the FY. Table 4A, B, C, D, E, F	Mandatory
	Table I, J, K, L	There is an option to fill these details separately or can be clubbed with Table 4B to 4E.
5.	Details of outward supplies on which tax is not payable made during the financial year- Table 5 A, B, C	Mandatory
	Table 5 D, E, F	The consolidated details can be disclosed in the exempted row.
	Table 5 H, I, J, K	There is an option to fill these details separately or can be clubbed with Table 5A to 5F
6.	Details of ITC availed as declared in the returns during the financial year. 6A, Others	Mandatory
	6B, 6C, 6D, 6E	For Input and input services there is option to provide breakup or total in inputs only. Capital Goods should be shown separately. There is an option to either report in Table 6C and in Table 6D separately or report the consolidated details of Table 6C and 6D in Table 6D only
7.	Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year 7A, 7B, 7C, 7D, 7E	Either fill separately or report the entire amount in 7H only
	7F, 7G, 7H	Mandatory
8.	Others ITC related information	Mandatory
9.	Details of tax paid as declared in returns filed during the financial year	Mandatory
10 & 11	Supplies / tax declared/reduced through Amendments (+) (-) (net of credit /debit notes)	Mandatory
12 & 13	Reversal of ITC availed during previous financial year and ITC availed for the previous financial year.	Optional
15	Particulars of demand and refund	Optional
16	Information on supplies received from composition taxpayers, deemed supply under section 143 and goods sent on approval basis.	Optional
17	HSN wise summary of outward Supplies	Optional
18	HSN wise summary of inward supplies	Optional

Table-wise details requirement in form GSTR-9C

Table No.	Particulars	FY 2019-20
5	Reconciliation of Gross Turnover 5A is mandatory Net 5B to 5N can show in 5O	Mandatory
7	Reconciliation of Taxable Turnover	Mandatory
9	Reconciliation of Tax paid	Mandatory
11	Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10 above)	Mandatory
12	Reconciliation of Net Input Tax Credit (ITC) 12A	Mandatory
	12B, 12C	Optional
14	Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account	Optional
16	Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)	Mandatory