GSTR-9 and GSTR-9C

[Vartik Choksi]

4 Queris with respect to GSTR-9 and GSTR-9C

A. On page no. 92 of Handbook on GST Annual Return issued by ICAI, in last line it is mentioned that “Values in Table 7A to 7H need to be entered if and only if credit has been availed in table 4A and reversed in 4B of Form GSTR-3B. We had not reversed any Input Tax Credit in 4B of GSTR 3B from July 2017 to March 2018 and April 2018 to March 2019. Now we want to reverse the credit under Rule 37, please guide how to reverse the said credit?

B. The expense/bill pertains to FY 2017-18. Instead of recognizing the ITC, the entire expenditure has been expensed out in FY 2017-18. On verification of GSTR-2A of FY 2017-18, it was observed that ITC was reflected on Portal but not shown as Recoverable in the accounts in FY 2017-18. Now in GSTR-3B of March 2019 the said ITC is taken. Whether the said amount of ITC is to be shown in GSTR 9 of FY 2017-18 or 2018-19?

C. In case of Cash system of accounting, the ITC has been claimed in the year of payment. However on GST Portal the ITC gets reflected in Table 8A of GSTR-9 as when the bill raised by the vendor. Now we had claimed the ITC in the year of payment. How to show the same in GSTR-9 and GSTR-9C so that the claim of ITC could not be lapsed

D. RCM on payment made to unregistered person has not been paid. Now if the liability is assessed and the payment of tax alongwith interest is paid through DRC-03 while filing GSTR-9. Whether we are eligible to take the input tax credit in FY 2019-20 since the payment was made in the current financial year?

[KASTURI SETHI]

(A) Now reversal of credit is by way of payment of tax via Form DRC-03.

(B) In 2018-19.

(C) Once reflected (auto populated) in Common Portal, It will not become time barred. Whether transaction pertains to 17-18 or 18-19 ?

(V) No. You cannot take credit of additional liability paid through Form DRC-03.

[Vartik Choksi]

Sir,

C. The transaction pertains to FY 2017-18 and reflected in GSTR-2A of FY 2017-18. Since we maintain the accounts on the cash basis we have claimed the same in the year of payment i.e. in FY 2018-19. In which line item the same should be reflected in GSTR-9 and GSTR-9C so that the same should not be lapsed.

AI Summary

GST Input Tax Credit reporting requires reversal by DRC payment form and specific GSTR-9 disclosures to avoid lapse. Reversal of un-reversed Input Tax Credit must be effected by payment through Form DRC-03; tax paid via DRC-03 does not permit taking corresponding input tax credit later. When accounts are maintained on a cash basis, ITC reflected on the portal for an earlier year but claimed in the year of payment must be shown in GSTR 9/GSTR 9C for the year in which the credit was actually claimed. Portal auto-population does not by itself time bar reporting.