Gstr-9: Filing The First-ever Annual Return For Financial Year 2017-18

Apr 01, 2019 By Admin

GSTR 9, the annual return to be filed once in a year by the registered taxpayers under GST has got extension till June 30, 2019. Being filed for the first time, there’s a lot of fuzz with taxpayers regarding it. GSTR 9 consists of details regarding the supplies made and received during the year under different GST heads i.e. CGST, SGST and IGST. It consolidates the information furnished in the monthly or quarterly returns during the assessment year.

The filing of the first annual return for FY 2017-18 is due in three months. It covers a period of nine months from July 2017 to March 2018. Many taxpayers still dread the preparation of annual return forms because the declaration of information in the annual returns has multiple implications, which needs extensive consideration before filing the return.

The last date has been extended to June 30, 2019, but it is important to know that GST Annual returns cannot be revised once filed. Moreover, any incorrect information can attract tax demands and interest or even penalties; leave alone the long-term litigations that can follow years later.

GSTR-9 is an annual summary of the sales; tax paid thereon, purchases, input tax credit (ITC) claimed, ineligible credits, demands and refunds. If the form were just a replica of the monthly GSTR-3B summarized at a yearly level, it would have been an easy task. Using monthly GSTR-3Bs already filed by a taxpayer, the annual form could be auto-populated for the twelve months of the financial year. However, being the first and perhaps the last GSTR-9 format under the present set up of GSTR-1 and GST.

One can tackle the hefty process of matching figures and facts with the help of a sturdy reconciliation tool that can easily identify mismatches, duplication of entries, match credit/ debit notes against respective invoices and so on. Hence, taxpayers can reduce the hard work with the help of smart software and timely management of their ledgers and books with the help of a certified Chartered Accountant.

Let’s take few question-answers we have been asked these days about GSTR 9:

1. Who all are required to file GSTR-9?
All registered taxable persons under GST must file GSTR-9. However, the following persons are not required to file GSTR-9:

• Casual Taxable Person
• Input Service Distributor
• Non-resident taxable persons
• Persons paying TDS

2. What are the various types of annual returns?
There are four types of annual returns:

• GSTR 9: GSTR 9 should be filed by the regular taxpayers filing GSTR 1, and GSTR 3B.
• GSTR 9A: GSTR 9A should be filed by the persons registered under composition scheme under GST.
• GSTR 9B: GSTR 9B should be filed by the e-commerce operators who have filed GSTR 8 during the financial year.
• GSTR 9C: GSTR 9C should be filed by the taxpayers whose annual turnover exceeds Rs. 2 crores during the financial year. All such taxpayers are also required to get their accounts audited and file a copy of audited annual accounts and reconciliation statement of tax already paid and tax payable as per audited accounts along with GSTR 9C.

3. What is GSTR-9C?
GSTR-9C is a statement of reconciliation between the annual returns in GSTR-9 filed for the fiscal year 2017-18 and the figures as per Audited Annual Financial Statements of the taxpayer. The CA then certifies it and it can be considered to be similar to that of a tax audit report furnished under the Income tax act. It will consist of gross and taxable turnover as per the Books reconciled with the respective figures as per the consolidation of all the GST returns for an FY. Hence, any differences arising from this reconciliation exercise will be reported here along with the reasons for the same.
The certified statement shall be issued for every GSTIN. Hence, for a PAN there can be several reports of GSTR-9C.

4. Who must prepare & submit GSTR-9C?
GSTR-9C must be prepared and certified by the Chartered Accountant or Cost Accountant. It must be filed on the GST portal or through facilitation center by the taxpayer along with other documents such as the copy of the Audited Accounts and Annual returns in GSTR-9. This statement is applicable to all those taxpayers who must get their Annual Accounts audited under the GST laws. Audit applies to those registered persons whose Annual aggregate turnover exceeds Rs 2 crores in that FY, here being FY 2017-18.

5. What are the contents in the GSTR-9C?
The GSTR-9C consists of two main parts:
(a) Reconciliation Statement
(b) Certification

(a) Reconciliation Statement
The figures in the audited financial statements are at PAN level. Hence, the turnover, Tax paid and ITC earned on a particular GSTIN(or State/UT) must be pulled out from the audited accounts of the organization as a whole.
The Reconciliation Statement is divided into five parts as follows:

(i) Basic details: Consists of FY, GSTIN, Legal Name and Trade Name. Must also mention if he is subject to audit under any other law.
(ii) Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9)-
This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that mostly the Audited Financial statement is at a PAN level. This might require the break up of the audited financial statement at GSTIN level for reporting in GSTR-9C.
(iii) Reconciliation of tax paid-
This section requires GST rate-wise reporting of the tax liability that arose in FY 2017-18 as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to reconciled differences noticed upon reconciliation.
(iv) Reconciliation of Input Tax Credit (ITC)-
This part consists the reconciliation of input tax credit availed and utilized by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement. Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any.
(v) Auditor’s recommendation on additional Liability due to non-reconciliation-
Here, the Auditor must report any tax liability identified through the reconciliation exercise and GST audit, pending for payment by the taxpayer. This can be non-reconciliation of turnover or ITC on account of :
• Amount paid for supplies not included in the Annual Returns(GSTR-9)
• Erroneous Refund to be paid back
• Other Outstanding demands to be settled
Lastly, the instructions to the format of GSTR-9C specifies that an option will be given to taxpayers to settle taxes as recommended by the auditor at the end of the reconciliation statement.

(b) Certification
The same CA who conducted the GST audit can certify the GSTR-9C or any other CA who did not conduct the GST Audit for that particular GSTIN can also certify it The difference between the both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format of Part-B for certification report will vary depending on who the certifier is.

6. What is per day Penalty for the late filing of GSTR-9 form?
Late fees for late filing of GSTR 9 is Rs. 100 per day per act up to a maximum of an amount calculated at a quarter percent of the taxpayer turnover in the state or union territory. Thus it is Rs 100 under CGST & 100 under SGST, the total penalty is Rs 200 per day of default. There is no late fee on IGST.

7. What are the details required in the GSTR-9 form?
Parts of the GSTR-9 Information required:

Part-I:Basic details of the taxpayer. This detail will be auto-populated.
Part-II:Details of Outward and Inward supplies declared during the financial year (FY). This detail must be picked up by consolidating summary from all GST returns filed in previous FY.
Part-III:Details of ITC declared in returns filed during the FY. This will be summarized value picked up from all the GST returns filed in previous FY.
Part-IV:Details of tax paid as declared in returns filed during the FY.
Part-V:Particulars of the transactions for the previous FY declared in returns of April to September of current FY or up to the date of filing of annual returns of previous FY whichever is earlier. Usually, the summary of amendment or omission entries belonging to previous FY but reported in Current FY would be segregated and declared here.
Part-VI:Other Information comprising details of:
• GST demands & refunds.
• HSN wise summary information of the quantity of goods supplied. and received with its corresponding Tax details against each HSN code.
• Late fees payable and paid details.
• Segregation of inward supplies received from different categories of taxpayers like Composition dealers, deemed supply and goods supplied on approval basis.

Published by : RAKESH KANWAR & CO.
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