Checklist for GST Annual return and reconciliation statement

By | November 17, 2018
Print Friendly, PDF & Email
(Last Updated On: November 17, 2018)

Checklist for GST Annual return and reconciliation statement

, Government has notified the formats for Annual Return (GSTR-9) and Reconciliation (GSTR-9C).

Annual return is divided into 6 parts with 19 tables, which requires taxpayers to report summary of outward supplies, inward supplies, tax paid, particulars of demands and refunds, HSN summary etc

Identify Turnover

It may be noted that annual return in Form GSTR-9 is required to be filed by all assessees except casual taxable person, Input Service Distributor, Non-Resident Taxable Persons, Persons paying TDS/TCS and electronic e-commerce operator. Further, composition dealers are required to file annual return in GSTR-9A. However, Reconciliation in GSTR-9C is required to be filed under section 35(5) of the CGST Act, 2017 by every registered person whose turnover during a financial year exceeds the prescribed limit of Rs. 2 Crores. 

CGST Act defines  the word ‘turnover’ and not ‘aggregate turnover’.

Rule 80(3) of the CGST Rules, 2017 states that every registered person whose aggregate turnover during a financial year exceeds two crore rupees shall get his accounts audited as specified in section 35(5) of the CGST Act, 2017 and shall furnish reconciliation statement in Form GSTR-9C. Now, the question arises is whether a company having registration in 6 different States on same PAN, wherein the turnover of only 2 States exceeds Rs. 2 Crores is required to get its accounts audited for all 6 States and file reconciliation for all 6 States?

If the term ‘aggregate turnover‘ is placed, then reconciliation is to be filed for all 6 States whereas if term ‘turnover’ is considered, reconciliation is to be filed for only 2 States. 

Suggestion : In order to avoid non compliance it is suggested to have Audit of all branches in 6 states.

 Bifurcation of input tax credit

Bifurcation of input tax credit is required to be done  into followings

  • Inputs,
  • Capital Goods and
  • Input Services.

It is important to note that such classification was not required in GSTR-3B. This is a new bifurcation that a taxpayer would need to make.

Since implementation of GST, no assessee has segregated their credit as the input tax credit is admissible in GSTR 3B in one go for all inputs including capital goods.

 

Bifurcation of tax paid under reverse charge

Bifurcation of following is also required :-

  • Tax paid under reverse charge mechanism pertaining to registered person and
  • Tax paid under reverse charge mechanism pertaining to  unregistered persons.

The bifurcation of GST paid under reverse charge mechanism with respect to purchases made from unregistered persons under section 9(4) of the CGST Act, 2017 is to be made upto 12.10.2017.

Apart from this, with respect to GST paid under reverse charge for notified services under section 9(3) of the CGST Act, 2017, bifurcation is to be made of GST paid for services availed from registered and unregistered persons.

Note: For GST paid on freight , the assessees need to keep track about the registration status of the transporter, whether they are registered or not.

HSN wise summary of inward supplies

Reporting HSN wise summary of inward supplies is required in GST Annual Return

Table 18 of GSTR-9 mandates taxpayers to report HSN wise details of inward supplies. Taxpayers again will have to note that such HSN wise details for inward supplies was not required to be reported in GSTR-3B. This again is a new requirement as HSN codes were being given only for output supplies and not for inward.

Following are the issues to be decided

  • whether HSN summary of all inward supplies is to be given or only principal supplies is to be reported?
  • Whether HSN summary is also required to be made even in cases where no ITC is being availed by the assessee?
  • Whether HSN summary is to be given even for ITC that has lapsed or where credit has been fully reversed?
  • Whether exempted/Nil rated inward supplies are to be included in HSN summary as the Column no. 4 of table 18 mentions Taxable Value of inward supplies?

Bifurcation of outward supplies

Bifurcation of outward supplies on which tax is not payable under the following categories

  • exempted,
  • nil rated and
  • Non-GST supply.

Reference has also been made to a new term ‘NO SUPPLY’ which is nowhere defined in the GST Law. It may be ‘No Supply Goods or Services’ are probably that are mentioned in Schedule III of the CGST Act, 2017. The Government should clarify the meaning of ‘No Supply’ so that there is no confusion or wrong reporting by the assessees.

Reporting of previous year Transactions in next Financial Year

 Part V of GSTR-9 requires taxpayers to provide details of transactions reported between April’18 to September’18, which pertains to FY 2017-18. For instance, credit note/debit note issued between April’18 to September’18 for invoices issued in FY 2017-18.

Classification of Suppliers

Following supplies are required to be reported separately in GSTR 9 (Sr N0 16)

  • Inward supplies from composition dealers,
  • deemed supply from job workers
  • Goods sent on approval basis but not returned
 Thus, one needs to be very sure of the profile of the supplier in order to correctly classify them for the purpose of Annual Return.

Reclaim of Input Tax Credit

Input tax credit reversed and reclaimed in FY 2017-18 to be separately reported in Table 6H of GSTR-9. For e.g. ITC is reversed on account of non-payment of consideration within 180 days. Subsequently, when the payment is made the said ITC is re-claimed. In this case, thus far, dealers were reclaiming the credit under the normal ITC. However, for the purpose of Annual return, such re-claimed credit of ITC needs to be identified an disclosed separately.

Reconciliation between the credit claimed in GSTR-3B and GSTR-2A

Table 8 of GSTR-9 requires taxpayers to report the reconciliation between the credit claimed in GSTR-3B and GSTR-2A available on GST portal.

No Rectification of errors done in filing GST returns

From prima facie perusal of the Annual Return format, it appears that any additional liability arising out of error/omission in GSTR-1 and GSTR-3B cannot be paid at the time of filing annual return. This could be a setback as Industry was looking forward to rectifying all inadvertent mistakes at the time of filing the annual return

Important Note : Keep all the additional details asked in GSTR 9 (GST Annual Return)  readyso that GSTR 9 can be filed on time.

 

Direct Taxes Ready Reckoner
Service Tax Ready Reckoner
Company Law Ready Reckoner
tax deduction at source

Leave a Reply

Your email address will not be published. Required fields are marked *