GSTR-9 Due Date Extended: Common issues faced by CAs while filing GSTR-9

The deadline to file GSTR-9 for FY 2023-24 is 31st December 2024. Currently, there is no extension on the due date. However, the deadline to file GSTR-9 has been extended a couple of times in the past for various reasons such as complexities in the form and filing. The CBIC had exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 21-22 from filing Form GSTR-9. The due date to file GSTR-9 & self-certified GSTR-9C for the FY 2020-21 was extended up to 28th February 2022. The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 had further been extended up to 31st March 2021. 

For CAs and businesses both, the last couple of GSTR-9 filings have been tiresome and complicated, trying to understand the intricate GSTR-9 form, while tallying their monthly and quarterly filed-returns with their books of accounts. Here is a list of reasons that have led to the extensions.

ITC mismatch between GSTR-2B/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/2B return, and the input tax credit auto-filled in table 8A in the GSTR-9.  Some reasons for the mismatch are-

• The final figures, after considering amendments must be reported in GSTR-9, as against the gross values appearing in the GSTR-2A/2B.
• 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.
• Differences in GST liability for FY 2022-23 but reported in FY 2023-24 upto specified time. 

Input Tax Credit classification 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 maintain a record of this bifurcation leading to undue stress of obtaining these details now, to avoid incorrectly reporting the same.   

Input Tax Credit claimed, but not reflecting in GSTR-2A/2B 

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 may not have been reflecting in the GSTR-2A/2B of several taxpayers. It would result in taxpayers receiving notices from the Tax Department.    

Goods imported in the financial year, but ITC claimed only in the next year

There is no separate field at present to report the input tax credit claimed in the year subsequent to the financial year on goods that were imported in the financial year. 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. 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.   

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 to caution the taxpayers about what both the fields mean, more clarity is needed with examples/ redressal of the accounting challenges.  

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 4th June 2019 used the words ‘additional outward supply’, with no mention of RCM, while the Central Tax notification released on 28th 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.  

Declaration of HSN summary for outward and inward Supplies 

HSN summary details with four digits HSN codes are required to be disclosed by suppliers for B2B supplies having a turnover upto Rs.5 crore. Whereas, it is six-digit HSN reporting for those with turnover above Rs.5 crore. This requirement is for both inward and outward supplies. Some taxpayers are relaxed from the requirement where inward supplies which in value independently account for less than 10% of the total value of inward 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. 

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.   

Strenuous process of upload of GSTR-9C

The process of uploading GSTR-9C is cumbersome and requires several technical steps which taxpayers are finding time-consuming and inconvenient. 

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.