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GST Liability to disclose in GSTR9c, Goods and Services Tax - GST

Issue Id: - 116160
Dated: 20-3-2020
By:- Suresh P
GST Liability to disclose in GSTR9c

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Dear Experts,

1.Where to show in GSTR-9C a taxable supply not being recorded in Books of accounts together with its GST (Qualification in Audit report exists for not paying or providing for it ).The same is also not mentioned in GSTR-9 also and GST is not paid via DRC 03.

2.If the client is not ready to pay such liability if the same is mentioned as per point 1 above, can the audit report be delivered by a qualification without paying such liability via DRC 03.?

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Showing Replies 1 to 2 of 2 Records

1 Dated: 21-3-2020
By:- Kashish Gupta

Dear Suresh Ji,

As per me, GSTR-9C is nothing but a statement of reconciliation of financial statements with GSTR-9. In section 44(2) as well, it has been very clearly mentioned that a registered person has to file Form GSTR-9C with

a) Copy of audited annual accounts, and

b) a reconciliation statement, reconciling the value of supplies declared in the GSTR-9 with audited annual financial statement

From above, it can be inferred that the expressions "accounts" and "financial statement" has been used differently and former expression has been defined under section 35(1) of the CGST Act/SGST, 2017 read with rule 56 of CGST/SGST Rules, 2017.

Therefore, the answers to your queries are as under:

a) No need to show such supplies in Form GSTR-9C

b) All your qualifications must form part of point a) i.e. audited annual accounts and not of Form GSTR-9C (including part A and B thereof).

2 Dated: 21-3-2020

Mr. Suresh,

At first place, as the GST Liability is admitted by you, same has to be paid via DRC-03 alongwith interest to avoid any penal action by department. This liability has to be paid irrespective of whether the same becomes part of GSTR-9C or not.

If you have recorded supply in your books of accounts and not in GSTR-1/GSTR-9 then the variance would come in turnover reconciliation in GSTR-9C (Table 5 & 7). Your auditor has to give reasons for same and create liability for tax payment. If you pay off tax via DRC-03 selcting casue of payment as GSTR-9C and apprise your auditor, then he will place the remarks in his GSTR-9C audit report. If you don't pay the liability, auditor can't shy away with the responsibility of hiding the turnover variance. He has to mention then in his qualification report that the tax payment is pending.


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