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Simplification of Annual Return GSTR – 9, 9C and extension of filing date

  • Nov 26, 2019 | Viren Shah

In a welcome move, although bit late, the Central Board of Indirect Taxes and Customs (‘CBIC’) has relaxed many of the challenges faced by the taxpayers while filing the annual return and reconciliation form, vide Notification no. 56/2019 - Central Tax dated 14 November 2019. 

Further, the CBIC have issued order no. 8/2019 - Central Tax dated 14 November 2019 for extending the due date of filing Annual Return (GSTR - 9) and Reconciliation Statement (GSTR - 9C). The due date for filing of annual return and audit report has been extended for Financial Year (‘FY’) 2017-2018 from 30 November 2019 to 31 December 2019. Separately, for FY 2018-2019, the due date has been extended from 31 December 2019 to 31 March 2020.

With respect to certification requirement (GSTR - 9C), auditor is now required to provide a ‘true and fair’ view of the reconciliation statement as against the previous requirement to provide ‘true and correct’ certification. 

Given below is gist of the simplification announced by the CBIC vide Notification no. 56/2019:

Part I - Annual Return (GSTR - 9)

Sr. No. Particulars Table Nos. Relaxation / Simplification
1 Outward supplies on which tax is payable
  • 4B - B2B supplies to registered persons
  • 4C - Zero rated supply on payment of tax [except supplies to Special Economic Zone (‘SEZ’)]
  • 4D - Supply to SEZs on payment of tax
  • 4E - Deemed exports
Option to declare details net of debit notes, credit notes and amendments

2

Outward supplies on which tax is not payable

  • 5A - Zero rated supply without payment of tax
  • 5B - Supply to SEZs without payment of tax
  • 5C - Supplies on which tax is to be paid by the recipient on RCM
  • 5D - Exempted
  • 5E - Nil Rated
  • 5F - Non-GST supply (includes no supply)
Option to declare details net of debit notes, credit notes and amendments
  • 5D - Exempted
  • 5E - Nil Rated
  • 5F - Non-GST supply (includes no supply)
Option to declare consolidated details in Table 5D
3 Input Tax Credit (‘ITC’) availed
  • 6B - Inward supplies
  • 6C - Inward supplies received from unregistered persons liable to RCM on which tax is paid and ITC availed
  • 6D - Inward supplies received from registered persons liable to RCM on which tax is paid and ITC availed
  • 6E - Import of goods (including supplies from SEZs)
Consolidated information with respect to ITC availed on inputs, capital goods and input services can now be reported under a common heading - ‘Inputs’
   
  • 6C - Inward supplies received from unregistered persons liable to RCM on which tax is paid and ITC availed
  • 6D - Inward supplies received from registered persons liable to RCM on which tax is paid and ITC availed
Consolidated ITC availed under RCM can be reported in a single row i.e. Table 6D
4 ITC reversed and ineligible ITC
  • 7A - As per Rule 37
  • 7B - As per Rule 39
  • 7C - As per Rule 42
  • 7D - As per Rule 43
  • 7E - As per Section 17(5)
Consolidated ITC reversals can now be reported under a single row i.e. Table 7H - Other reversals

Reversal on account of TRAN-1 credit (Table 7F) and TRAN-2 (Table 7G) to be mandatorily reported
5 Other ITC related information
  • 8A - ITC as per GSTR 2A
  • 8B - ITC as per sum total of 6(B) and 6(H)
  • 8C - ITC on inward supplies received during the respective FYs, but availed subsequently
    • FY 2017-2018 availed between April 2018 to March 2019
    • FY 2018-2019 availed between April 2019 to September 2019
  • 8D - Difference
Option available to registered person to upload details of the entries in pdf format, in Form GSTR 9C
6

Others

  • 12 - Reversal of ITC availed during previous FY
  • 13 - ITC availed for the previous FY
  • 15 - Particulars of demands and refunds
  • 16 - Information on supplies received from composition taxpayers, deemed supply under Section 143 and goods send on approval basis
  • 17 - HSN wise summary of outward supplies
  • 18 - HSN wise summary of inward supplies
Option available to registered person to not fill details

Part II - Reconciliation Statement (GSTR - 9C)

Sr. No. Particulars Table Nos. Relaxation / Simplification
1

Reconciliation of Gross Turnover

  • 5B to 5N
It has been made optional. However, in case adjustment is required to be reported, the same may be reported in Table 5O - Adjustments in turnover due to reasons not listed above
2 Reconciliation of Net ITC
  • 12B - ITC booked in earlier FYs claimed in current FY
  • 12C - ITC booked in current FY claimed in subsequent FYs
It has been made optional
3 Reconciliation of ITC declared in Annual Return with ITC availed vis-a-vis expenses as per audited financial statement
  • 14
It has been made optional

Based on the above, it will be noticed that most of the reconciliation requirements have been made optional, however it is better that the taxpayer continues to maintain the required reconciliations as the same may be required during the audit, if any, conducted by the Revenue Authorities. 

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Avalara Author
Viren Shah
Avalara Author Viren Shah
Viren Shah, a member of the Institute of Chartered Accountants of India and a Bachelor of Commerce from Mumbai University, has experience of more than a decade in Corporate and International Taxation. He specializes in Domestic and International Taxation, with specific emphasis on cross border transactions and exchange control laws with respect to inbound and outbound investments. He has vast experience in advising companies across various sectors such as payment, media & entertainment, technology, advertising, infrastructure, in various aspects of corporate and international taxation.