The deadline to file GSTR-9 has gotten extended* (again!) since its initial filing due date which was the 31st December 2018. For CAs and businesses both, the last 18 months have been a confusing and complex period, trying to understand the intricate GSTR-9 form, while tallying their monthly and quarterly filed-returns with their books of accounts. But what were some of the issues faced by CAs that led to this extension for the fourth time?
1. ITC mismatch between GSTR-2A and Table 8A of GSTR-9
This is an area that has caused a lot of pain for taxpayers due to the mismatch between the input tax credit appearing in the auto-generated GSTR-2A return, and the input tax credit auto-filled in table 8A in the GSTR-9.
Some reasons for the mismatch are-
- Input tax credit on supplies relating to FY 17-18 will not get auto-populated in GSTR-9, if the same has been declared beyond the 30th of April, 2019.
- The final figures, after considering amendments have been reported in GSTR-9, as against the gross values appearing in the GSTR-2A.
- Input tax credit relating to invoices for such period the recipient taxpayer was under the Composition Scheme are not appearing in GSTR-9.
- Input tax credit on invoices where the place of supply lies in the supplier taxpayer’s state instead of the recipient taxpayer’s state has been excluded in GSTR-9.
2. Input Tax Credit bifurcation needed in GSTR-9 and GSTR-9C
Form GSTR-9 requires the bifurcation of all input tax credit availed from inputs, input services and capital goods. This, in turn, requires a complete and thorough analysis of the books of accounts of a taxpayer, in addition to verification by the concerned auditor. Not all taxpayers would have kept a record of this bifurcation leading to undue stress of obtaining these details now, to avoid incorrectly reporting the same.
3. Input Tax Credit claimed, but not reflecting in GSTR-2A
Over the period of FY 17-18, while filing their GSTR-3B returns, taxpayers have claimed input tax credit as eligible under the CGST Act. However, there is a lot of input tax credit which is still not reflecting in the GSTR-2A of several taxpayers. The question that arises here is whether such input tax credit will be deemed ineligible, and would result in taxpayers receiving notices from the Tax Department, without a fair opportunity to prove the genuineness of such credit.
4. Goods imported in FY 17-18, but ITC claimed only in FY 18-19
There is no separate field at present to report the input tax credit claimed in FY 18-19 on goods that were imported in the previous FY 17-18. While the government has clarified that such input tax credit shall be reported in table 6(E) of GSTR-9, this is for the entire credit availed between July 2017 and March 2019. Since the auditors need to prepare their reconciliation statement based on this information as well, it would have been easier for taxpayers to report this data separately and more accurately.
5. Overlapping of figures in Table 6(B) and 6(H)
Table 6(B) requires the reporting of all inward supplies and input tax credit availed during the financial year, other than imports and inward supplies liable to reverse charge. Table 6(H) on the other hand, requires the reporting of input tax credit which had been availed, reversed and later reclaimed during the same financial year. This has led to the overlapping of figures between tables 6(B) and 6(H) of the GSTR-9. Although a government clarification has been issued for cautioning the taxpayers about what both the fields mean, more clarity is needed with examples/ redressal of the accounting challenges.
6. Disclosure of RCM liability in GSTR-9
The clarification released by the CBIC on the disclosure of liability under RCM, due for FY 17-18, but paid in FY 18-19, has been unclear. This is because the press release on the 4th of June 2019 used the words ‘additional outward supply’, with no mention of RCM, while the Central Tax notification released on the 28th of June, 2019 uses the words ‘additional liability’. While taxpayers are supposed to report the total of such undisclosed liability under table 4(G) of GSTR-9, the corresponding tax portion of such liability needs to be declared under ‘Tax Payable’ in table 9.
7. Declaration of HSN summary for outward and inward Supplies
HSN summary details are required to be disclosed mandatorily by suppliers having a turnover above Rs.1.5 crore. This requirement is for both inward and outward supplies. This has caused unnecessary hassles for taxpayers who had not been maintaining this data in the past and will now need to spend a lot of additional time and effort in order to obtain and report these details.
8. No clarity on filling Table 4F of GSTR-9
Table 4(F) of the GSTR-9 is for disclosing all advances on which tax has been paid, but where invoices have not been issued. The clarification for filling up this table states that the source of information should be table 11(A) of the GSTR-1 returns. This holds good only at a monthly level because, at an annual level, adjustments made during the year need to be considered. This means data should also be sourced from table 11(B) of the GSTR-1 returns.
9. Strenuous process of upload of GSTR-9C
The process of uploading GSTR-9C is cumbersome and requires several technical steps which auditors are finding time-consuming and inconvenient. In addition to the process involved, there are other issues while filing GSTR-9C where the address details of the statutory auditor are not getting captured accurately, nor can the auditor enter his qualifications entirely due to word limitations.
10. Other issues faced while filing GSTR-9
In addition to the above, there are other issues taxpayers have been facing while filing their GSTR-9-
- Negative values copy-pasted in GSTR-9/9C offline utility are allowed only in tables 5(M), 5(N) and 5(O). While negative values can be copied elsewhere, and the JSON gets generated, the GSTN does not process the same.
- Even though there is no error detected, the JSON file is not getting uploaded.
- In some cases, there have been 2 final PDF copies of the GSTR-9 filed return. The GSTN portal is yet to resolve the issue.
- The set-off under DRC-03 has been done, but taxpayers are still unable to file the same.
- The DRC-03 is not getting reflected on the common portal in some cases.
- The splitting/bifurcation of the expense ledger in GSTR-9C is a very time-consuming process and with no known relevance.