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Ever since GSTR-9 & GSTR-9C forms have been released by CBIC, there has been persistent confusions surrounding who must file these forms and whether the details required for both are the same or not.Not any more…

Latest Update on GSTR-9 and GSTR-9C

Update as on 14th March 2020*

1) The due date for filing GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2018-19 is extended to June 30, 2020.

2) For businesses with an annual turnover of less than Rs 5 crore, filing of GSTR-9C for FY 2018-19 to be waived off.

3) For businesses with less than Rs 2 crore aggregate turnover in FY 2017-18 and FY 2018-19, no late fee will be charged for the delayed filing of GSTR-9.

*Subject to CBIC notification

Update as on 3 February 2020

The due date for Form GSTR-9 and GSTR-9C has been again pushed to 5th and 7th of February 2020 by a CBIC notification as follows:

1) 5th February 2020:
Chandigarh, Delhi, Gujarat, Haryana, Jammu and Kashmir, Ladakh, Punjab, Rajasthan, Tamil Nadu, Uttar Pradesh,
Uttarakhand

2) 7th February 2020:
Andaman and Nicobar Islands, Andhra Pradesh, Arunachal Pradesh, Assam, Bihar, Chhattisgarh, Dadra and Nagar Haveli and Daman and Diu, Goa, Himachal Pradesh,Jharkhand, Karnataka, Kerala, Lakshadweep, Madhya Pradesh, Maharashtra, Manipur, Meghalaya, Mizoram, Nagaland, Odisha, Puducherry, Sikkim, Telangana, Tripura, West Bengal and Other Territory

The States or Union Territories have been regrouped as follows:

The date for filing GSTR-9 and GSTR-9C for all States or Union Territories earlier due on 3rd February 2020 has been pushed to 7th February 2020, except Tamil Nadu. The due date in Tamil Nadu is extended to 5th February 2020.

The date for filing GSTR-9 and GSTR-9C for all States or Union Territories earlier due on 5th February 2020 remains unchanged except for the addition of Ladakh. The due date for the state of Himachal Pradesh is now pushed to 7th February 2020. Also, the due date for taxpayers in Uttar Pradesh, earlier being 7th February 2020 is now preponed to 5th February 2020.

The last date of 7th February 2020 is unchanged for the remaining States or Union Territories earlier falling under this group, with the addition of Himachal Pradesh and removal of Uttar Pradesh.

Update as on 31 January 2020

The due date for Form GSTR-9 and GSTR-9C has been further pushed to 3rd, 5th and 7th of February 2020 as follows:
1) 3rd February 2020:
Maharashtra, Karnataka, Goa, Kerala, Tamil Nadu, Puducherry, Telangana, Andhra Pradesh, Other Territories

2) 5th February 2020:
Jammu and Kashmir, Himachal Pradesh, Punjab, Chandigarh, Uttarakhand, Haryana, Delhi, Rajasthan, Gujarat

3) 7th February 2020:
Bihar, Sikkim, Arunachal Pradesh, Nagaland, Manipur, Mizoram, Tripura, Meghalaya, Assam, West Bengal, Andaman & Nicobar Islands, Jharkhand, Odisha, Chhattisgarh, Dadra and Nagar Haveli and Daman and Diu, Lakshadweep, Madhya Pradesh, Uttar Pradesh

Note: CBIC Notification was not issued

 

Here is a quick comparison of GSTR-9 & GSTR-9C:

 

Points of comparison GSTR-9
Annual Return
GSTR-9C
Reconciliation Statement
Nature Informational/ a consolidation of all GST returns  Analytical statement on GST returns certified by GST Auditor/ CA/CMA for GST authorities to take necessary action
Who must file GST Registered taxpayer GST registered taxpayer to whom GST audit is applicable
Not applicable to Casual Taxable Person
Non-Resident Taxable Person
Input Service Distributor
Unique Identification Number Holders
Online Information and Database Access Retrieval Service providers
Composition Dealers
Persons subject to TCS or TDS provisions
Those mentioned under GSTR-9 but also a registered person whose aggregate turnover in an FY is less than Rs. 2 Crores
Due date for filing 31 December of next FY* 31 December of next FY* *, either with or after filing GSTR-9
Late fees & penalty Late fees of Rs 200 per day of delay subject to a maximum cap of an amount at 0.25% of total turnover in respective State/UT No specific provision, Hence, subject to a general penalty of Rs 25,000
Filing of the return On GST portal or through facilitation centre On GST portal or through facilitation centre at the time of or after filing GSTR-9
Format of the return Consolidated summary details of the turnover, ITC and tax paid, late fees as per the GST returns filed between July 2017 and March 2018 along with its amendments made between April 2018 and September 2018.

Further, declaration of demands/ refunds, supplies from composition dealers, Job works, goods sent on an approval basis, HSN wise summary of outward and inward supplies, late fees payable is required.

Part-A -Reporting of reconciliation needed between turnover, tax paid and ITC. Report on Auditor’s recommendation of any additional tax liability.

Part -B -Certificate by GST Auditor/ CA/ CMA

Who must certify/ attest No certification required by CA/CMA but must be attested by the taxpayer using a digital signature Certification of GST Auditor is required who is either a CA/CMA through digital signature and must be attested by the taxpayer using a digital signature
Annexures No annexures to be attached Annexure of Audited financial statement is required

*The due date for filing GSTR-9, GSTR-9C has been extended to 31st December and 31st March 2020 for FY 2017-18 and FY 2018-19 respectively.
**GSTR-9A filing for composition taxpayers waived off for FY 2017-18 and FY 2018-19.

Hence, GSTR-9 is the annual return to be filed by every GST registered taxpayer irrespective of their turnover^.

^GSTR-9 filing for businesses with turnover up to Rs 2 crore made optional for FY 2017-18 and FY 2018-19.

 

Whereas GSTR-9C is the reconciliation statement to be submitted by those GST registered taxpayers to whom GST audit applies. GST Audit applies to those taxpayers whose turnover exceeds Rs. 2 crores. Audited financial statements must be filed by the taxpayers along with this after obtaining certification from the auditor or a Chartered Accountant or a CMA.

 

FY 2017-18 is the first financial year for filing annual returns and GST audit, ClearTax GST helps you with the end-to-end compliance for GST ranging from invoicing solutions to filing of GSTR -9.

 

 

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