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Annual return requirements clarified: GSTR-9 scrutiny must reflect historical audit and ITC matching law, not post-amendment rules. For annual returns of FY 2017-18, 2018-19 and 2019-20, scrutiny must follow the pre-amendment UPGST/CGST regime: where the audit obligation and accompanying audited accounts and reconciliation statement applied, those were to be filed; assessment units must not raise objections or demand records inconsistent with the law as it stood for those years, must not issue GSTR-9C-related queries to taxpayers for whom it did not apply or who opted not to file GSTR-9, must not invoke matching/reversal provisions where no ITC was claimed, and must not seek TRAN-1/TRAN-2 evidence where those forms were not filed.
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<h1>Annual return requirements clarified: GSTR-9 scrutiny must reflect historical audit and ITC matching law, not post-amendment rules.</h1> For annual returns of FY 2017-18, 2018-19 and 2019-20, scrutiny must follow the pre-amendment UPGST/CGST regime: where the audit obligation and accompanying audited accounts and reconciliation statement applied, those were to be filed; assessment units must not raise objections or demand records inconsistent with the law as it stood for those years, must not issue GSTR-9C-related queries to taxpayers for whom it did not apply or who opted not to file GSTR-9, must not invoke matching/reversal provisions where no ITC was claimed, and must not seek TRAN-1/TRAN-2 evidence where those forms were not filed.
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