TaxTMI 
TaxTMI 
Annual returns in GSTR 9 - clarifications
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....03.07.2019 taking note of the difficulties faced in filing the information in the various Tables of the GSTR 9. In order to assist the taxpayers, all the clarifications issued regarding the annual returns (GSTR 9) and the reconciliation statement (GSTR 9C) are summarized below. This will ensure qualitative filing of information by the taxpayers. 3. Primary data source for declaration in annual return: Time and again taxpayers have been requesting as to what should be the primary source of data for filing of the annual return and the reconciliation statement. There has been some confusion over using FORM GSTR-I, FORM GSTR-3B or books of accounts as the primary source of information. It is important to note that both FORM GSTR-I and FORM GSTR-3B serve different purposes. while, FORM GSTR-I is an account of details of outward supplies, FORM GSTR-3B is where the summaries of all transactions are declared and payments are made. Ideally, information in FORM GSTR-I, FORM GSTR-3B and books of accounts should be synchronous and the values should match across different forms and the books of accounts. If the same does not match, there can be broadly two scenarios, either tax was not paid ....
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.... figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A. Please note that this may happen due to following reasons: a. Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-I of the supplier taxpayer. But figures in table 8A of Form GSTR-9 are auto- populated only on the basis of filed GSTR-I by the supplier taxpayer. In case, Form GSTR -l is not filed by your supplier, then credit related to those invoices will not appear in table 8A of your Form GSTR-9. b. Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR- I, which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April, 2019, will not get auto-populated in table 8A of Form GSTR-9. c. In table 8A of Form GSTR-9, only latest values have been auto-populated based on filed Form GSTR-I, taking into account all the amendments made, if any. d. In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in which place of supply ....
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....ttlement purposes. Figures in Table 8A of FORM GSTR-9 are auto-populated only for those FORM GSTR-I which were furnished by the corresponding suppliers by the due date. Thus, ITC on supplies made during the financial year 2017-18, if reported beyond the said date by the corresponding supplier, will not get auto-populated in said Table 8A. It may also be noted that FORM GSTR-2A continues to be auto-populated on the basis of the corresponding FORM GSTR-I furnished by suppliers even after the due date. In such cases there would be a mis-match between the updated FORM GSTR-2A and the auto-populated information in Table 8A. It is important to note that Table 8A of the annual returns is auto populated from FORM GSTR-2A as on 1st May, 2019. 8. Payment of any unpaid tax: Section 73 of the CGST Act provides a unique opportunity of self- correction to all taxpayers i.e. if a taxpayer has not paid, short paid or has erroneously obtained/been granted refund or has wrongly availed or utilized input tax credit then before the service of a notice by any tax authority, the taxpayer may pay the amount of tax with interest. In such cases, no penalty shall be leviable on such tax payer. Therefore,....
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....equested for clarification on the appropriate column or table in which tax which was to be paid on reverse charge basis for the FY 2017-18 but was paid during FY 2018-19. It may be noted that since the payment was made during FY 2018-19, the input tax credit on such payment of tax would have been availed in FY 2018-19 only. Therefore, such details will not be declared in the annual return for the FY 2017-18 and will be declared in the annual return for FY 2018-19. If there are any variations in the calculation of turnover on account of this adjustment, the same may be reported with reasons in the reconciliation statement (FORM GSTR-9C). 12. Role of chartered accountant or a cost accountant in certifying reconciliation statement: There are apprehensions that the chartered accountant or cost accountant may go beyond the books of account in their recommendations under FORM GSTR-9C. The GST Act is clear in this regard. With respect to the reconciliation statement, their role is limited to reconciling the values declared in annual return (FORM GSTR-9) with the audited annual accounts of the taxpayer. 13. Turnover for eligibility of filing of reconciliation statement: It may be not....