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GSTR-9 is an annual return to be filed by all registered taxpayers under GST except a handful. It is an annual compilation of outward supplies, inward supplies, tax liability and input tax credit availed during a financial year. It is due to be filed by 31 December of the year following the particular financial year. For the first two financial years, the annual return filing has been extended several times.
31st July 2021
The CBIC has exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 20-21 from filing Form GSTR-9.
30th July 2021
The CBIC has notified changes to Sections 35(5) and 44 of the CGST Act. The requirement to get a GST audit and certification done by a CA/CMA now stands removed. Taxpayers with a turnover exceeding Rs.5 crore in the previous financial year are required to file Form GSTR-9C on a self-certification basis. This change is applicable from FY 20-21 onwards. Further, Form GSTR-9C will be modified to support self-certification by the taxpayer.
28th May 2021
As per the 43rd GST Council meeting outcome, GSTR-9 shall continue to be optional for taxpayers with turnover up to Rs.2 crore, whereas GSTR-9C can be self-certified by taxpayers with turnover less than or equal to Rs.5 crore from FY 2020-21 onwards.
9th March 2021
The Form GSTR-9A has been disabled from FY 2019-20 onwards for composition taxpayers due to the introduction of GSTR-4 (Annual return). However, the GSTR-9A is optional and can be filed for FY 2017-18 and FY 2018-19.
28th February 2021
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been further extended up to 31st March 2021.
30th December 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been extended up to 28th February 2021.
28th October 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2018-19 has been extended up to 31st December 2020.
It is an annual return to be filed by all registered taxpayers under GST irrespective of the turnover of an entity. The return consists of details such as inward/outward supplies, taxes paid, refund claimed, demand raised and ITC availed by the taxpayer. All registered taxpayers are required to file GSTR-9 except :
(Note: Composition taxpayers have to file GSTR-9A, and E-commerce operators have to file GSTR-9B.)
Cases where the business of an assessee is shifted from Regular to Composition or vice versa, the turnover and purchases have to be segregated in the following manner:
If CGST, SGST, and IGST are interchanged while reporting in GSTR-1, the same cannot be corrected while filing GSTR-9. Table 9 – Details of taxes paid of GSTR-9 cannot be edited except tax payable column. However, the assessee can correctly report the actual taxes payable under respective heads while updating Table 9, though, this correct reporting does not account for automatic intra-adjustment of tax under CGST, SGST, and IGST. The shortfall of tax needs to be paid off while filing GSTR-3B of the subsequent month or by filing DRC-03 and the taxes paid in excess erroneously can be claimed as a refund. Also, there is no interest liability on taxes shortly paid in such cases.
Table 4 of GSTR-9 requires details of both B2B and B2C supplies. In this case, the assessee has to report sales under B2B in Table 4, as this is the correct classification even though it was wrongly reported as B2C in GSTR-1.
If taxes are erroneously paid in excess in GSTR-3B, the same can be claimed as a refund (as per Section 54 of CGST Act) or be adjusted against tax payments of subsequent periods. But, the same cannot be claimed though GSTR-9. The refund needs to be claimed by making an application for the same on GST portal.
As the correct nature of sales in this case is without payment of taxes, the same should be reported in Table 5A and not Table 4C of GSTR-9. A correct reporting needs to be done in GSTR-9 irrespective of the fact that it was wrongly reported in GSTR-1 as ‘With payment of taxes’.
Non-execution of LUT is a procedural non-compliance. Such non-compliance cannot turn the nature of the transaction from ‘exports without payment of tax’ to ‘exports with payment of tax’. A taxpayer needs to report the transaction under Table 5 of GSTR-9 as “Exports without payment of tax”. Penal consequences, if any, need to be dealt with.
This transaction should be reported in Table 4A (in case supply is made to unregistered person) or Table 4B (in case the supply is made to registered person). Reporting under Table 4F is required only when the tax on advances is paid but the invoice is not issued.
An assessee should make a correct reporting under GSTR-9 by disclosing the reverse charge paid under Table 4G even though if there is incorrect reporting under GSTR-3B.
No, a refund of credit notes which cannot be adjusted in FY 2018-2019 (pertaining to FY 2017-2018) cannot be claimed as the incidence of tax on such supply has been passed to the recipient.
Yes, the values of GSTR-3B can be used for filing GSTR-9. A taxpayer can also edit the data flowing in from GSTR-3B except for Table No. 6A-Total amount of ITC availed.
No additional credit can be claimed in GSTR-9 which has not been claimed in GSTR-3B. However, credit claimed in TRAN-1 filed, can be reported in GSTR-9 under Table 6K/6L or Table 13, as applicable.
Majority of the details in the Tables of GSTR-9 will be auto-populated from GSTR-1 and GSTR-3B. A taxpayer can edit these auto-populated values but if the difference is more than 20%, the cells will be highlighted in red and a confirmation message will pop-up asking ‘if the taxpayer wants to proceed despite deviation.’ GST Authorities can issue a notice asking the assessee to reconcile the ITC claimed in GSTR-3B and system generated Form GSTR-2A. The differential tax amount, if any, may need to be paid.
The difference between auto-populated ITC details from GSTR-2A and those declared in GSTR-3B needs to be explained in GSTR-9 under the following 2 heads:
If any reversal of ITC was missed in past months GSTR-3B, the same can be done in subsequent months GSTR-3B. The same should be correctly reported in Table 7 of GSTR-9 and the excess liability created because of such reversal should be paid off.
Table 6B of GSTR-9 requires bifurcation of ITC into Capital goods, Inputs and Input Services. Books of accounts have to be maintained in a manner such that purchases attributable to output supply of goods, output services, and capital goods can be identified and thus ITC on the same can be differentiated. However, there is no difference in treatment of ITC between goods and services. Hence, such bifurcation may be dispensed with in the first year as the assessee may not have maintained books in the required manner due to non-requirement in GSTR-3B.
The missing outward supply details of GSTR-3B for the previous financial year should be correctly reported under Table 10 of GSTR-9. Such outward supply details should be net of credit/debit notes.
Table 13 requires details about ITC of goods/services received in the previous financial year but availed in the current financial year. Thus, only ITC claimed in the current year but related to the previous year needs to be reflected in Table 13 which does not include any reversals.
The excess claimed credit in GSTR-3B can be reversed by reporting such amount in Table 4(B)2 of GSTR-3B of the subsequent month. The same can also be disclosed in Part V Point 12 of GSTR-9.
Yes, stock transfers and cross charges under the same PAN are included in aggregate turnover. As per Section 2(6) of the CGST Act, the term aggregate turnover includes ‘inter-state supplies of persons having same PAN.’
HSN and SAC are standardized codes assigned to each identified goods/services respectively. These codes are linked to GST rates. So, at the time of filing an annual return, a taxpayer will have to select the HSN code and the system will automatically select the applicable rate. Wrong selection of HSN code will lead to varying tax liability. Also, one of the requirements of claiming ITC is that the invoice should be complete in all respects as mentioned in Section 31 which requires to mention HSN for goods and services on the invoice. So, if an assessee furnishes the incorrect HSN Code, this could impact the buyer’s claim of input tax credit.
If the recipient has filed GSTR-9 before filing of GSTR-1 by the supplier, the details of such invoices will be reflected for the supplier in GSTR-1A and the supplier should accept such invoices when he files his return. Only after acceptance of such invoice, a recipient taxpayer can claim ITC on the same.
The intricacies faced by various sectors in filing GSTR-9 are:
The government had extended the period for submitting declaration in Form GST TRAN-1 till 31st March 2019, for registered persons who could not submit the declaration due to technical difficulties on the common portal and whose cases are recommended by the Council. Such assessees could claim credit of earlier tax regime by submitting declaration in TRAN-1 before the extended due date.
The details of credit availed in TRAN-1 and TRAN-2 are to be reported under Table 6K and 6L of GSTR-9 respectively. As per GST Rules, the due date of filing an annual return is 31st December 2018, but in this case, the government has extended the due date to 30th June 2019. Thus, GSTR-9 can be filed after filing transition returns for the FY 2017-2018. However, in this case, the credit received on account of TRANS-1 and TRANS-2 should not be disclosed in 6K and 6L of GSTR-9 as the amount gets credited in the month in which transition returns were filed.
A NIL GSTR-9 annual return can be filed only if all of the below criteria are met for that financial year:
The term ‘no supply’ includes activities or transactions which are neither supply of goods nor supply of service as mentioned in Section 7(2) of CGST Act i.e:
GST Refund claimed during July 2017 to March 2018 should be reported in Table 15A. If the refund is sanctioned after 31st March 2018, the same is not reported in Table 15B. The cut-off date to report transactions under Table 15 is 31st March 2018.
Yes, a manual edit can be done to the auto-populated details in GSTR-9 except for the below- mentioned tables: Table No. 6A: Total amount of input tax credit availed through GSTR-3B Table No. 8A: ITC as per GSTR-2A Table No. 9: Details of tax paid Except tax payable column
As per the provisions of Section 44(1) of the CGST Act, every registered person is required to file GSTR-9. Thus, even if the status of the taxpayer is unregistered as on 31st March 2018 but was registered anytime between July 2017 to March 2018, he is required to file GSTR-9 for the period during which he was registered.
There is no similarity between GSTR-9A and GSTR-9C. GSTR-9A is the annual return form to be filed by Composition Dealers. GSTR-9C is a reconciliation statement between GSTR-9 and the annual audited financial statements.
GSTR-9 is an annual return under GST to be filed once every year only by registered taxpayers under GST under the Regular Scheme (Monthly/Quarterly). GSTR-9C is a reconciliation statement between GSTR-9 and the audited books of accounts.
If you have paid GST on the same invoice twice, you can adjust the tax amount while filing the next month’s GSTR-3B.
For B2C there will be a netoff impact but for B2B invoice and amendment is required to be shown separately.
You have to check the aggregate turnover at PAN level. If the annual turnover exceeds Rs 2 crore, GSTR-9C needs to be filed GSTIN-wise for the particular PAN. For businesses with an annual turnover of less than Rs 5 crore, filing of GSTR-9C for FY 2018-19 has been waived off.
No, it is not compulsory to give HSN code for turnover below Rs 1.5 crore.
The same can be declared in the subsequent GSTR-1 filing.
The same can be changed manually in Form GSTR-9.
The same will be reflected in the Electronic Cash ledger.
Yes, the same needs to be disclosed in the annual return.
No, GSTR-9 is a declaration form and no tax can be paid /refund can be generated through it.
For the Transporter, he will need to file his GSTR 1 showing the transaction as B2B (Reverse Charge).
There is no notification currently available for extension.
Table 8 will never show negative values Other than Imports from SEZ, as Table 8A and 8B are auto-populated and negative values can arise only in case the Table 8C value is greater than Table 8A .
No, we can not show Non-GST turnover in GSTR-9.
You have to carry forward the credit note of March 2019 to April 2019 GSTR-3B. there is no other option available as the GSTN does not accept negative values.
You can show the amendment data manually in Table 4 and 5 if the amendment pertains to the FY 2017-18, however, if the amendment pertains to FY 2018-19 for the period F.Y. 2017-18, you have to show the same in Table 10 and 11. This may attract a notice from the GST Department since you have not shown the amendment in GSTR-1 for the respective period.
There is nothing called hacks as far as warnings are concerned. You have to make sure that whatever you report in GSTR-9, you have proper documentation to support the same.
Turnover for GSTR-9C is the turnover as per the audited financial statements of the entity as compared with Turnover declared in GSTR-9.
The GSTN already has the records via GSTR-1 and GSTR-3B as to how much turnover you have for a FY. Based on these records, they will start issuing notices.
No, we cannot amend GSTR-9.
You can manually edit the entire GSTR-9 form except for a few auto-calculated cells.
It is very important that any unreconciled differences are adjusted before filing GSTR-9 as GSTR-9 cannot be revised. Any difference between the Sales Register and GSTR-1 returns filed can be manually edited in GSTR-9.
It will be reported in Table 9 of GSTR-9.
GSTR-3B for the previous periods are required to be filed before filing for the current month.
Yes, you can claim ITC for FY 2017-18 till March 2019 in the GSTR-3B return, and you can show the same in GSTR-9 too.
Please check your GSTN login. If you see GSTR-9 there, you have to file GSTR-9 return, otherwise, there is no need to file GSTR-9.
Yes, but we suggest you check the auto-filled details before filing as GSTR-9 cannot be revised. Besides, there are some Tables which have to be filled-in manually.
The GSTN currently requires in Table 9 of GSTR-9 the details of tax paid and declared during FY 2017-18.
You can make manual changes in the GSTR-9.
GSTN has not given any clarity for all the refunds sanctioned beyond 31.03.2018 belonging to FY 2017-18. Sanctions are required for refunds.
Yes, you can make manual changes in GSTR-9 and correct the Advances value.
Yes, if your turnover is above Rs 1.5 crores.
You can make these changes as GSTR-3B is summary level details.
Yes, you can make manual changes in GSTR-9.
It implies that the GSTR-2A of the purchaser is showing less input tax credit in FY 2018-19 for which he has already reduced the ITC in FY 2017-18 in his GSTR-3B return. In that case, the pull from GSTN will show the correct values in Table 6 of the purchaser when he files his GSTR-9.
You can add them in the next month/quarter GSTR-1 filing.
You have to make the payment in IGST first for FY 2017-18 and then declare the same in Table 9.
Table 8C will show negative values if Table 8A shows less value as compared to Table 8B and 8C. The portal will accept negative values.
You can file an auto-populated GSTR-9 form, but there are certain sections that are not auto-filled by the GSTN. Please check the same before filing GSTR-9 as it can not be revised.
Yes, transactions which were not disclosed while filing the GST returns of 2017-18, can be now reported while filing GSTR-9. Any liability arising out of these transactions need to be paid using form DRC-03. However, no new input tax credit can be claimed. Ex: Supplies made without consideration, goods that have been sent on approval basis, deemed supplies (goods sent to job workers not received back within the time specified of 1 or 3 years, as applicable), etc.
The GSTN auto-populates several tables in the GSTR-9 return for convenience and ease of filing for taxpayers. However, this does not necessarily mean that the auto-populated data is accurate. It is the duty of every taxpayer to verify this data with their books of accounts and their GST returns filed. If any figure is found to be inaccurate, then the figure as per the books of accounts/GST returns, whichever is correct, needs to be reported in the GSTR-9 return.
From July 2017 to March 2018, any payment which was made using form DRC-03 will not be accounted for in form GSTR-9, however, the same needs to be reported in the reconciliation statement i.e. form GSTR-9C.