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All registered taxpayers under GST are required to file an annual return in Form GSTR-9 irrespective of the turnover of an entity. Filing GSTR-1 and GSTR-3B is mandatory before filing the annual return. The annual return is a compilation of data filled in GSTR-1 and GSTR-3B.
Even if a taxpayer identifies that certain data is incorrect in GSTR-1/GSTR-3B, the same cannot be corrected in GSTR-9. The intent of the form is just the aggregation of data and not rectification. However, the books of accounts of an entity should be in line with the returns filed. This can be done by way of reconciliation.
Under the GST Law, it has become very important to reconcile the returns
GSTR-2B or GSTR-2A and GSTR-3B, as the taxpayer can claim ITC on a particular invoice only if that invoice is present in the
GSTR-2B or GSTR-2A. This matching concept helps the Department in verifying whether all transactions which occurred in a particular time period are correctly recorded and posted in the summary return GSTR-3B. The table below explains the action points in case of mismatches:
|1.||Excess credit is declared||GSTR-2A||ITC is not claimed by the recipient in GSTR-3B.||He should claim the missing ITC in the month in which discrepancy is identified.|
|The supplier has shown excess outward supplies in GSTR-1.||He should rectify the same in GSTR-1 of the month in which discrepancy is identified.|
|2.||Less credit is declared||GSTR-2A||The supplier failed to upload the invoice.||The supplier is asked to rectify the same in the return of the month in which the discrepancy is identified. If the supplier fails to do so, the ITC claimed by the recipient gets added to the output tax liability in the next month.|
|Duplicate credit claimed by the recipient in GSTR-3B.||If the recipient has already corrected the same, no further action is required. If not, the excess ITC claimed is added to the output tax liability of next month.|
Note: In both the above cases, the difference between ITC details from GSTR-2A and GSTR-3B needs to be explained in GSTR-9 under the following 2 heads:
In this case, a taxpayer needs to perform the following two reconciliations:
This reconciliation requires dynamic data as the data filled in GSTR-2A/2B is as provided by its vendors. Every time a single vendor files GSTR-1 or makes any amendment to it, the data changes and reconciliation needs to be done again.
Step 1: Identify the invoices recorded only in the books of accounts and not the GST portal (GSTR-2A) as well as the invoices available on the portal i.e GSTR-2A and not recorded in books.
Step 2: This invoice mismatch may happen due to any of the following reasons:
Step 3: Taking action on such mismatches as mentioned in the above Table.
This reconciliation requires static data as the same needs to be prepared and recorded by the organisation itself.
Step 1: Check whether all GST challans paid by the organisation are correctly recorded in the respective Payables ledger.
Step 2: Match ITC claimed in GSTR-3B with that recorded in the books of accounts. Pass an adjustment entry in case of mismatch.
Step 3: Match GST output claimed in GSTR-3B with that recorded in the books of accounts. Pass an adjustment entry in case of mismatch.
Step 4: Match the Electronic Credit Ledger with the Trial Balance.
Step 5: Any errors in GSTR-3B need to be rectified in subsequent months return.