GST Audit by Chartered accountant

[Archna Gupta]

Dear Experts

Please reply to following queries:

1. Please clarify whether GST audit under section 35(5) is to be done registration wise or PAN no. wise.

2. Are forms GSTR-9 and GSTR-9C available?

[Alkesh Jani]

Madam,

In my point of view your query may be taken up with GST via twitter for early and reliable reply.

Thanks

[YAGAY andSUN]

1) It will depend i.e. Section says Turnover but Rules says Aggregate Turnover. However in our view it is Registration wise.

2) Currently both Forms are not available. May be make available by next month.

[DR.MARIAPPAN GOVINDARAJAN]

We have to wait for this

[KASTURI SETHI]

It is registration wise. Act prevails over Rules.

[YAGAY andSUN]

We are in agreement with Kasturi Sir. 

[Archna Gupta]

But if audit is to be done on registration wise, that means we have to do audit of registered place of the state from where the turnover exceeds 2 crores and if this is the case then it will be compulsory for the assessee to maintain separate books of accounts for each state.

If any assessee has more than one registration in single state then separate books for each registration in a state.

What if the assessee is not maintaining separate books of accounts?

[YAGAY andSUN]

There is a specific provision for maintaining the separate books of account GSTIN wise in GST Laws.

[Archna Gupta]

please quote the section.

AI Summary

GST audit registration-wise: audits tied to each GST registration require GSTIN-wise books; forms not yet available. The discussion addresses whether GST audit under section 35(5) is registration-wise or PAN-wise, noting the statute references turnover while rules refer to aggregate turnover. The prevailing view in the thread favors registration-wise audits, with the position that the Act prevails over Rules and that taxpayers must maintain separate books on a GSTIN basis. The thread also records that Forms GSTR-9 and GSTR-9C were not yet available and that a specific statutory citation for the GSTIN-wise bookkeeping requirement was requested but not supplied.