WIRC Bulletin - December 2018




Ever since GST came into prominence with effect from 1st July, 2017, there were several anticipations for the GST audit and its reconciliation with the annual return, including linkage of the same with the erstwhile VAT regime or the Income Tax Return/Tax Audit Report. Some of the additions in the Tax Audit Report were also opined and notified by the Government, so that the payments made under GST regime commensurate with the Income Tax & Account Books such as reconciliations in respect of turnover, expenditures incurred, ITC availed, etc., however the same has been kept in abeyance till 31st March, 2019 for the very reason of it being burdensome for the companies to compile the enhanced requirements for tax audit post the close of the accounting period and statutory audits.


The much awaited Annual return (GSTR-9) was notified by CBIC vide Notification No. 39/2018 – Central Tax dated 04th September 2018.

It is to be clarified that Annual GST Return (GSTR 9) is a consolidation of returns filed and is no way reconciliation with books of accounts.



  1. A) Every person with a GSTIN needs to prepare Annual Returns, even if no transactions are carried out during 9-month financial year 2017-18.
  2. B) No such return is required by holders of registration as ISD, TDS-TCS, casual and non-resident taxable persons.
  3. C) Annual Return admits that GSTR 1 and GSTR 3B are in harmony with each other. That is, no turnover reported in GSTR 1 has been omitted in GSTR 3B while paying tax. And no turnover that is taxed in GSTR 3B has gone unreported in GSTR 1.
  4. D) Annual Return is not the place to rectify errors in the data reported in GSTR 1 / 3B. An important thing to keep in mind is that the form only asks for the details already declared in the returns filed so that means no new information can be furnished here.
  5. E) No new credit will be discovered and claimed in GSTR 9.




The Annual Return form GSTR-9 contains total 6 parts spread out in 19 Tables detailed below:

Part-I: Basic information of Tax payer in Tables 1 to 3 Part-IV: Details of Tax paid in Table 9
Part-II: Details of outward & inward supplies in Tables 4 & 5 Part-V: Details of transactions of 2017-18 reported in April-18 to Sep-18 in Tables 10 to 14
Part-III: Details of Input tax credit in Tables 6 to 8 Part-VI: Other information in Tables 15 to 19


  • Table 4 & 5 of the Annual Return

GSTR-9 requires the details of the outward supplies including ( Details of Advances on which tax is payable, Inward supply on which tax is payable on RCM basis , outward supply on which Tax is payable ) already declared in the returns (GSTR-1 & GSTR-3B) filed during the financial year.


  • Table 6 of the Annual Return

GSTR-9 asks for bifurcating Input Tax claimed in 3B into three heads viz. Inputs, Capital Goods, Input Services whereas there was no such requirement in GSTR-3B return. It also expects the dealers to bifurcate the ITC claimed under Section 9(3) & 9(4) in the same categories of Inputs, Capital Goods, Input Services


  • Table 7 of the Annual Return

GSTR-9 requires the dealer to enter the details of the reversal made under Rule 37, 39, 42, 43 & Section 17(5) which filing his GSTR-3B returns. However any dealer who now wants to make the reversals or want to declare the same who had not done it in 3B return cannot do so.


  • Table No.8 of the Annual return

GSTR-9 takes the values of GSTR-2A as the base for allowing the ITC to the dealers. So suppose a dealer has claimed ITC in his 3B return which is more than the one reflecting in the GSTR-2A the form will show negative figure in column No. 8D.

  • Table No.10 & 11 of the Annual return

The details in relation to any amendments (addition/deletion) made in the returns filed for the current Financial Year which was pertaining to any supplies declared in the returns of the earlier Financial Year is required to be shown here. However, the same should be shown net of any debit or credit notes.


  • Table 13 of the Annual Return

The details of ITC pertaining to goods/services received in the previous Financial Year but which has been taken in the returns filed for the current Financial Year shall be declared here.


  • Table 15 of the Annual Return

GSTR-9 requires a dealer to bifurcate the refund applied by a dealer into Refund sanctioned, Refund rejected and Refund pending and also ask for the details of Total Tax Demands, Tax Demand Paid & Demands pending.


  • Table 17 & 18 of the the Annual Return

GSTR-9 requires dealers to upload Rate Wise HSN wise summary not only of the outward supplies but also of the inward supplies received.




  • List of tax invoices issued during the period and reconciliation of the same with books of accounts, this also should be reconciled with the turnover declared in the audited financial statements. This should be made each GSTIN statewise by the company.


  • List of debit/credit notes issued during the period and reconciliation of the same with books of accounts.


  • In case company has the different units/branch all over India, then the stock transfer between -units/branches also to be reconciled with the books.


  • Reconciliation of advances received and GST paid for goods & services during 1July 1 to 15th November 2017 and advances received for services and GST paid for that from 15th November 2017 to 31ST March 2018.


  • Reconciliation of E-Way bill data with the tax invoices issued during the period GSTIN statewise


  • Reconciliation of HSN wise summary with the issued tax invoices


  • Reconciliation discount given to the customer with purpose and recheck if the same under GST act allowed or not.


  • List of Purchase & other service bills accounted during the period & Input credit taken on the same and further reconciliation with the books and returns.


  • Ensure all the input credit taken bills are uploaded by the suppliers and it is reflecting in the GSTR-2A.


  • Reconciliation of input credit availed and also ensure all the availed credits are eligible as per the act and the ineligible credits, common credits are reversed & accounted properly.


  • Details of input credit taken on the fixed assets and


  • Reconciliation of Reverse charge GST (RCM) payable till the applicable date on all the applicable expenses and paid the same.


  • Reconciliation of monthly GST returns with the books of accounts and all the taxable, exempted & non GST turn over declared in the returns if any differences, reason for the same.


  • Check and ensure input credit taken supplier invoices paid within 180 days, if not the same input to be reversed.


  • All the credit taken on TRAN-1 credit reflecting in the GST portal and there is no issue on that.


  • In case any refund application filed with the department and eligibility & status of the same.




Q1) Who is required to file GSTR-9? Is there any threshold limit of Turnover for exemption to file GSTR-9?


As per Legal provision of Section 44(1) of CGST Act, every registered person shall be required to file GSTR-9. Hence, irrespective of the Turnover, every registered person under GST is required to file GSTR-9.


Q2) Who is not required to file GSTR-9?


Following persons are not required to file


– an Input Service Distributor,

– a person paying tax under section 51 (TDS) or

section 52 (TCS),

– a casual taxable person and

– a non-resident taxable person.


Q3) Whether a Taxpayer shall be required to file GSTR-9 even though his registration has been cancelled before 31st March 2018? Whether answer remains the same if his application for cancellation was pending as on 31st March 2018?


As per Legal provision of Section 44(1) of CGST Act, every registered person shall be required to file GSTR-9. Hence, even if the status of taxpayer is not registered as on 31st March 2018 but he was registered between July-17 to March-18, he shall be required to file GSTR-9 providing details for the period during which he was registered.

Similarly, if a taxpayer had applied for cancellation of registration but the application was pending as on 31st March 2018, he shall be required to file GSTR-9


Q4) What will be source of information for filling up GSTR-9?


GSTR-9 is merely a compilation of data filed in GSTR-3B and GSTR-1. As per the instructions of the form GSTR-9, it is stated that information of outward supplies ‘may’ be derived from Form GSTR 1. Inward supplies, input tax credit and the net tax paid in cash are to be gathered from Form GSTR 3B.


Q5) If taxpayer has identified some information which are missed to be reported in GSTR-3B or GSTR-1, whether the same can be added while filing GSTR-9?


GSTR-9 is a merely compilation of data filed in GSTR-3B and GSTR-1 and no other information can be incorporated in GSTR-9. Even if a taxpayer has identified data fed in GSTR-1 / GSTR-3B as incorrect, still the same data is to be taken for reporting in annual return


Q6) If no other information can be furnished in GSTR-9 over and above what is stated in GSTR-1 and GSTR-3B, then how can the taxpayer pay the tax liability in case he identifies certain liabilities which are missed to be reported?


If there is any additional liability missed to be reported in GSTR-1 / GSTR-3B pertaining to 2017-18, the same will be reported in subsequent GSTR-1 / GSTR-3B up to September 2018. However, if the same is missed to be reported in GSTR-1 / GSTR-3B up to September 2018, as of now there is no clarity provided by Government whether the same can be paid through GSTR-3B or DRC-03.


Q7) Where to report stock transfer made to another branch situated in another state if both are registered?


Since both branches are registered persons for a particular state, these transactions are to be reported in supplies made to registered person (B2B) Table 4B.


Q8) Whether any ITC pertains to FY 2017-18 but claimed subsequently in GSTR-3B of April-18 to September-18 will be reported in Table-6?


No. Even though ITC belongs to FY 2017-18, the same will not be reported here. Only ITC claimed up to March-2018 in GSTR-3B will be reported here

Q9) GST Refund is claimed before March-18 but sanctioned in April-18. How to report such kind of situation in Part VI Table-15?


GST Refund claimed during July-17 to March-18 is to be reported in Table-15A. If refund is sanctioned after March-18 then that is not to be reported in Table-15B.


Q10) Taxpayer has received a notice from its jurisdiction range office that there is a tax difference between GSTR-1 vs GSTR-3B / GSTR-3B vs GSTR-2A. Whether such tax differences are to be reported in total demand of tax in Table-15E?


No, demand of tax for which an order confirming the demand has been issued by adjudicating authority shall be reported in Table-15E. Only notice received asking for reasons / reconciliation of tax differences between returns filed cannot be said to be an order confirming demand of tax.


Q11) Whether GSTR-9 can be revised?


No such option has been provided in the law till now.


Q12) How much late fee is payable for late filing of GSTR-9?


As per section 47(2) of CGST Act, Late fee for belated filing of GSTR-9 is Rs.100 per day subject to maximum of 0.25% of turnover in a state/UT. Similar provision is there in SGST Act also. Hence, in total there will be late fee of Rs.200 per day subject to 0.50% of turnover.


Under the GST law, the provisions related to Annual Return are complex and need some more clarity on various aspects, which are likely to come in due course and we also look forward to some relaxation for small taxpayers.

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