Table Wise Analysis of GST Annual Return Form

Ever since GST came into prominence with effect from 1stJuly, 2017, there were several anticipations for the GST audit and its reconciliation with the annual return, including linkage of the same with the erstwhile VAT regime or the Income Tax Return/Tax Audit Report. Some of the additions in the Tax Audit Report were also opined and notified by the Government, so that the payments made under GST regime commensurate with the Income Tax & Account Books such as reconciliations in respect of turnover, expenditures incurred, ITC availed, etc., however the same has been kept in abeyance till 31st March, 2019 for the very reason of it being burdensome for the companies to compile the enhanced requirements for tax audit post the close of the accounting period and statutory audits.

GST Annual Return Update

Extension in Due Date for F.Y 2018-19 – Extended from 31st March 2020 to 30th June 2020Relaxation to MSMEs– The taxpayers having aggregate turnover below Rs. 5 crores need not require to file GSTR 9C for F.Y 2018-19{i.e. they are exempted from filing of GST Audit} Waiver of Late fee- Late fee has been waived for delay in filling of GST Annual Annual return and the Reconciliation Statement for financial year 2017-18 and 2018-19 for taxpayers with aggregate turnover less than Rs. 2 crores

Points to Remember

A) Every person with a GSTIN needs to prepare Annual Returns, even if no transactions are carried out during 9-month financial year 2018-19. B) No such return is required by holders of registration as ISD, TDS-TCS, casual and non-resident taxable persons. C) Annual Return admits that GSTR 1 and GSTR 3B are in harmony with each other. That is, no turnover reported in GSTR 1 has been omitted in GSTR 3B while paying tax. And no turnover that is taxed in GSTR 3B has gone unreported in GSTR 1. D) Annual Return is not the place to rectify errors in the data reported in GSTR 1 / 3B.An important thing to keep in mind is that the form only asks for the details already declared in the returns filed so that means no new information can be furnished here. E) No new credit will be discovered and claimed in GSTR 9.

TABLE WISE ANALYSIS OF GSTR ANNUAL RETURN

The Annual Return form GSTR-9 contains total 6 parts spread out in 19 Tables detailed below: table Table 4 & 5 of the Annual Return GSTR-9 requires the details of the outward supplies including ( Details of Advances on which tax is payable, Inward supply on which tax is payable on RCM basis, outward supply on which Tax is payable) already declared in the returns (GSTR-1 & GSTR-3B) filed during the financial year. Table 6 of the Annual Return GSTR-9 asks for bifurcating Input Tax claimed in 3B into three heads viz. Inputs, Capital Goods, Input Services whereas there was no such requirement in GSTR-3B return. It also expects the dealers to bifurcate the ITC claimed under Section 9(3) & 9(4) in the same categories of Inputs, Capital Goods, Input Services Table 7 of the Annual Return GSTR-9 requires the dealer to enter the details of the reversal made under Rule 37, 39, 42, 43 & Section 17(5) which filing his GSTR-3B returns. However any dealer who now wants to make the reversals or want to declare the same who had not done it in 3B return cannot do so. Table No.8 of the Annual return GSTR-9 takes the values of GSTR-2A as the base for allowing the ITC to the dealers. So suppose a dealer has claimed ITC in his 3B return which is more than the one reflecting in the GSTR 2A the form will show negative figure in column No. 8D. Table No.10 & 11 of the Annual return The details in relation to any amendments (addition/deletion) made in the returns filed for the current Financial Year which was pertaining to any supplies declared in the returns of the earlier Financial Year is required to be shown here. However, the same should be shown net of any debit or credit notes. Table 13 of the Annual Return The details of ITC pertaining to goods/services received in the previous Financial Year but which has been taken in the returns filed for the current Financial Year shall be declared here. Table 15 of the Annual Return GSTR-9 requires a dealer to bifurcate the refund applied by a dealer into Refund sanctioned, Refund rejected and Refund pending and also ask for the details of Total Tax Demands, Tax Demand Paid & Demands pending. Table 17 & 18 of the the Annual Return GSTR-9 requires dealers to upload Rate Wise HSN wise summary not only of the outward supplies but also of the inward supplies received.