GSTR 9 - Important clarifications from the government on filing of GST annual return

GSTR 9 is creating havoc in the industry due to unlimited mismatches and limited time for filing the same. Further, due to various other returns, and finalization of accounts, it has become even more difficult.

GSTR 9 or the annual return for the financial year 2017-18 has to be filed as per the new timelines, but because of so much confusion regarding the mismatches; it becomes a little difficult for industry and professionals to file them correctly.

Hence, in order to remove ambiguity around the GSTR 9, the government has come up with certain clarifications which are as follows;

How to report the transactions declared in financial year2018-19 but belonged to financial year 2017-18?

Particulars of the transactions for FY 2017-18 declared in returns between April 2018 to March 2019 shall be declared in Pt. V of FORM GSTR-9. Such particulars may contain details of amendments furnished in Table 10 and Table 11 of FORM GSTR-1.

How to report transaction of supplies which are showed in GSTR-3B of financial year 2018-19 but belonged to GSTR-3B of financial year 2017-18?

It may be noted that irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a supply in Pt. II or Pt. V is essentially driven by when was tax paid through FORM GSTR-3B in respect of such supplies. If the tax on such supply was paid through FORM GSTR-3B between July 2017 to March 2018 then such supply shall be declared in Pt. II and if the tax was paid through FORM GSTR3B between April 2018 to March 2019 then such supply shall be declared in Pt. V of FORM GSTR-9.
 

How to report additional supplies which are neither reported in GSTR-1 nor in GSTR-3B?

Any additional outward supply which was not declared by the registered person in FORM GSTR-1 and FORM GSTR-3B shall be declared in Pt.II of the FORM GSTR-9. Such additional liability shall be computed in Pt.IV and the gap between the “tax payable” and “Paid through cash” column of FORM GSTR-9 shall be paid through FORM DRC-03.

FORM DRC – 03 is a payment form in which a taxpayer can pay the tax by raising its liability voluntarily or in response to the show-cause notice (SCN).

How to correct the mismatch when supplies are not reported in GSTR-1 but their tax has been paid in GSTR-3B?

Many taxpayers have reported a mismatch between auto-populated data and the actual entry in their books of accounts or returns. One common challenge reported by taxpayer is in Table 4 of FORM GSTR-9 where details may have been missed in FORM GSTR-1 but the tax was already paid in FORM GSTR-3B and therefore taxpayers see a mismatch between auto-populated data and data in FORM GSTR-3B. It may be noted that auto-population is functionality provided to taxpayers for facilitation purposes, taxpayers shall report the data as per their books of account or returns filed during the financial year.

How to avoid lapsing of ITC when IGST paid at the time of import has been availed in FY 2018-19?

Many taxpayers have represented that Table 8 has no row to fill in credit of IGST paid at the time of import of goods but availed in the return of April 2018 to March 2019.

Due to this, there are apprehensions that credit which was availed between April 2018 to March 2019 but not reported in the annual return may lapse. For this particular entry, taxpayers are advised to fill in their entire credit availed on import of goods from July 2017 to March 2019 in Table 6(E) of FORM GSTR-9 itself.

How to report the transactions or supplies on which GST has been paid using the DRC–03?

Payments made through FORM DRC-03 for any supplies relating to period between July 2017 to March 2018 will not be accounted for in FORM GSTR-9 but shall be reported during reconciliation in FORM GSTR-9C.

Conclusion

If you are facing any issues while filing the GSTR 9, contact us today.

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