Great question — and one that often trips up businesses in the construction and real estate sector. Let’s break this down step-by-step:
🔹 Can a construction company book revenue on the basis of provisions?
Yes — from an accounting standpoint, a construction company can recognize revenue based on provision (i.e., accrual basis) especially under Percentage of Completion Method (POCM) or as per Ind AS 115.
📌 This is done to match income and expenses in the correct period — even if billing hasn’t occurred yet.
BUT — this is purely for accounting (books of accounts), not for GST.
🔸 What’s the impact on billing and GST liability?
Here’s the key distinction:
Basis | Provision Entry (Books) | GST Liability |
Revenue Recognition | Based on stage of completion | Based on time of supply rules |
Billing | May not be done yet | No billing = no GST |
GST Payment | Not required on provision | Pay only when invoice is raised or payment received |
✅ GST is NOT payable merely on provision entries unless an invoice is issued or advance is received.
So, you book revenue in your financials, but you don’t pay GST unless a taxable event happens.
🔍 Will GSTR-9C and GSTR-9 show mismatches due to provision?
Yes, they can show mismatches — and that’s expected.
Here’s Why:
- GSTR-9/GSTR-9C pulls turnover based on actual outward supplies reported in GSTR-1 & 3B.
- Your books may show higher turnover (due to provision entries), which hasn’t yet been billed.
⚠️ This difference will appear in GSTR-9C Reconciliation — typically in Table 5B/5O (reconciliation of turnover).
🛠️ What Should Be Done?
✅ In GSTR-9C:
- Mention the provision-based revenue as a reconciliation item.
- Add a note like:
"Provision for unbilled revenue as per Percentage of Completion Method (not liable to GST as invoice not yet raised).”
✅ In Books:
- Maintain a clear trail between:
- Provision entries
- Actual billing
- GST invoices
📋 Summary:
Aspect | Provision-based Revenue |
Allowed in Books? | ✅ Yes (Ind AS 115 / Accrual) |
Billing Required? | ❌ Not yet |
GST Liability? | ❌ Not until invoice/advance |
GSTR-9 vs Books | 🔁 Difference will show — explain in GSTR-9C |
Risk of Penalty? | ❌ No, if well-documented |