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ALL ABOUT GST ANNUAL RETURN
- CA HIREN PATHAK
MAJOR CHALLENGESWHILE FILING GSTR-9
 Absence of GSTR-2 & 3
 Frequent changes in GST Law
 Change in logic of Preparation of Annual return
 GSTR-3B & Books is base but GSTR-9 is prepared on the basis of GSTR-1
 First time reporting of various information – e.g. I/IS/CG + Inward HSN / RCM Registered/Unregistered
 Non availability of data in books of accounts – e.g.Taxable / Exempt / Common ITC / Composite purchase
 GSTN wise Data
 Non availability of trail for figures reported in 2018-19
 Technical issues of GSTN
CA HIREN PATHAK
CHANGES IN GSTR-9
 Notification 39/2018 – Central Tax dated 04th September 2018 – First time notified - Based on GST Returns
 Notification 74/2018 – Central Tax dated 31st December 2018 – Based on actual supplies made
 Notification 31/2019 – Central Tax dated 28th June 2019 - From Sep-18 to March-19 + Instructions
 Updated GSTR-9 from CGST Rules – Part-B Forms amended up to 18th July 2019
CA HIREN PATHAK
HEADING OF NEW GSTR-9VS OLD GSTR-9
OLD GSTR-9
NEW GSTR-9
As declared in
Returns
Supplies made
during the year
REPORTED OFVARIOUSTRANSACTIONS IN GST RETURNS
Transactions of
2017-18
Return of
2017-18
Return of
2018-19
Sales Reversal
Sales
Debit note
Credit note
ITC Reversal
ITC
OVERVIEW OF GSTR-9
GSTR-9
Part-I Part-II Part-III Part-IV Part-V Part-VI
Basic
Information
Liability
Input tax
credit
Tax payable
and Paid
Adjustment in
2018-19
Other
information
Table 1-3 Table 4 & 5 Table 9 Table 10-14 Table 15-19Table 6-8
LEGAL PROVISION OF GSTR-9
 Section 44(1) : Every Registered person shall furnish Annual Return
 Rule 80 : Required person to file GSTR-9 / GSTR-9A / GSTR-9B / GSTR-9C
 Section 35(5) : Turnover more than Rs.2 crore then needs to file GSTR-9C
WHO IS REQUIREDTO FILE GSTR-9?
Who has to File?
 Every Registered Person
 No Turnover Limit
Practical Issues
 Registered as NormalTaxpayer and
composite dealer both
 Registration cancelled in 2017-18
 Registration cancelled in 2018-19
WHO IS NOT REQUIREDTO FILE GSTR-9?
Not to file GSTR-9
 Input service distributor
 Person paying tax u/s 51 / 52
 Casual taxable person
 Non-Resident taxable person
VARIOUS ANNUAL RETURNS UNDER GST
 GSTR-9 :For RegularTaxpayer
 GSTR-9A :For CompositeTaxpayer
 GSTR-9B : For Person payingTax u/s 52 (TCS) (Not effective for FY 2017-18)
NIL GSTR-9
“NIL” GSTR-9 RETURN can be filed, if you have
 Not made any outward supply (commonly known as sale); AND
 Not received any inward supplies (commonly known as purchase) of goods/services;AND
 No liability of any kind; AND
 Not claimed any Credit during the FinancialYear; AND
 Not received any order creating demand; AND
 Not claimed any refund.
INSTRUCTION OF GSTR-9
 GSTR-9 can be filed online. It can also be prepared on Offline Tool and then uploaded on the Portal and filed.
 Annual return in form GSTR-9 is required to be filed by every taxpayer registered as normal taxpayer during the
relevant financial year.
 All applicable statements in Forms GSTR-1 and returns in Form GSTR 3B of the financial year shall have been
filed before filing GSTR-9.
 In case you are required to file GSTR-9C (Reconciliation statement and Certification); shall be enabled on the
dashboard post filing of GSTR-9.
 Annual return in Form GSTR-9 once filed cannot be revised.
 Computation of ITC based on GSTR-2A was auto-populated by the System based on GSTR-1 filed by your
corresponding suppliers upto 01/05/2019.
 Due date: 31st August 2019 for GSTR-9 and GSTR-9C both
GSTR-1 GSTR-3B
Table-5,7,9,10
Table-3.1(a)
Table – 4A/4C
Table – 6A
Table-3.1(b)
Table - 6B
Table – 6C Table-3.1(a)
Outward supply
on which Tax
payable
GSTR-1 GSTR-3B
Table-11A Table-3.1(a)
NA Table-3.1(d)
Table-9B
Table-3.1(a)
Table-9A/9C
Outward supply
on which Tax
payable
IMPORTANT POINTS OF TABLE - 4
 Zero rate supplies (Export and SEZ) both separate reporting
 Advances received – GST paid – Invoice not issued up to March-19
 Together with outward supply, inward supply under RCM is also reported
 Supplies amended through Credit note/ Debit note vs Supplies amended through Amendments
 Credit note as per Section 34
 Credit note for the period 2017-18 vis-à-vis Credit note dated 17-18
 Reported in GSTR-3B up to March-18
GSTR-1 GSTR-3B
Table-6A Table - 3.1 (b)
Table-6B Table - 3.1 (b)
Table-4B Table - 3.1 (d)
Table-8 Table - 3.1(c)
Table-9B Table – 3.1 (b) / (c)
Table-9A / 9C Table – 3.1 (b) / (c)
Outward supply on
which Tax payable
IMPORTANT POINTS OF TABLE - 5
 Outward supply covered under RCM then table 5C
 Since no tax payable,Tax amount column is not required
 Exempted, Nil rated and Non GST supply reporting - ITC Reversal made?
 Table 5N (including Table 10+11) will be matched with GSTR-9CTurnover
 Reported in GSTR-3B up to March-18
Remarks
Total ITC availed as per GSTR-3B
Table-(4)(A) (Reversal not consider)
Table – 4(A)(5) of GSTR-3B (All other
ITC)
• Not always 9(4)
• Only Unregistered persons
• Table – 4(A)(3)
• Not always 9(3)
• Only Registered persons
• Table – 4(A)(3)
ITC Availment
Remarks
• Table-(4)(A)(1)
• ICEGATE cross verification
• Table – 4(A)(2)
• Table – 4(A)(2)
• Table – 4(A)
This Row should be Zero
ITC of TRAN-1 / to Match with Credit
ledger
ITC of TRAN-2 / to Match with Credit
ledger
IMPORTANT POINTS OF TABLE - 6
 Break up of ITC into Input, Input service and Capital Goods – Not there in GSTR-3B
 Break up of ITC inTable 6B to Table 6H as reported in GSTR-3B
 Table 6J should be Zero
 Reverse charge break up – Not there in GSTR-3B
 Import of service – separate reporting, Not included in RCM
 Transitional ITC - Can be Matched with Credit Ledger
ITC Reversal
Remarks
Non Payment within 180 days
Credit reversal by ISD
• Taxable and Exempt supply
• ITC on Input /Input service
• Taxable and Exempt supply
• ITC on Capital Goods
Ineligible ITC – only if Added earlier
TRAN-1 Reversal - CL
TRAN-2 Reversal - CL
Any other Reversal not specified
This amount will be transferred to 9C
IMPORTANT POINTS OF TABLE - 7
 Reversal of ITC under different rules
 What if not Reversed under GSTR-3B?
 Reversal u/s 17(5) - Not as per GSTR-3B
 Net ITC as per Table-7J –Transfer to GSTR-9C
Remarks
Only “filed” case ITC as on 28/02/2019
ITC as per GSTR-3B
• ITC of 2017-18 claimed in 2018-19
• Up to Sep-18 or March-19?
Difference can be + or -
Voluntarily ITC not claimed
Ineligible ITC hence not claimed
IGST paid on Import Table- 4(A)(1)
Not Affect Credit Ledger, Deemed Lapse
GSTR-2A Reco
HOW GSTR-2A FIGURES ARE CALCULATED? (TABLE-8A OF GSTR-9)
 Why figures as per Downloaded GSTR-2A and Figures as per GSTR-2A inTable-8A doesn’t Match?
 Out of filed/ saved / submitted Form GSTR-1 only FILED GSTR-1 figures are auto populated
 GSTR-1 filed up to 01st May 2019 only to be considered
 Updated value (After amendments if any) only will be reflected in Table-8A
 POS other than receiver’s state will not be updated
 RCM figures will not be updated
 Supplier has filed GSTR-1 in 2018-19, GSTR-2A of 2017-18 will have impact?
 https://www.gst.gov.in/newsandupdates/read/288
CA HIREN PATHAK
IMPORTANT POINTS OF TABLE - 8
 Informative and not calculative
 No Impact on Credit Ledger
 Ready tool forTax authority
 Figures as per GSTR-2A keeps fluctuating
 “Submitted” GSTR-1, not to be reflected in GSTR-2A
 ITC of 2017-18, claimed in 2018-19 up March-19
 IGST on Import claimed in 2018-19,Where to mention?
 ITC Lapse figure only if amount reported inTable-8E andTable-8F
Details as per GSTR-3B
including RCM
Remarks
Supply / Tax
Supply / Tax
ITC
ITC
This Turnover and Tax will be
Matched with GSTR-9C
IMPORTANT POINTS OF TABLE – 10,11,12,13
 Most discussedTables in entire GSTR-9
 Removal of difficulty Order No.2 dated 31st December 2018
 Differential tax liability only on account of changes in supply
 Amendment only or New reporting also cover?
 What if difference in GSTR-3B and GSTR-1?
 Table 10 & 11 turnover will be added in table-5N. NetTurnover will be transferred to GSTR-9C
 Log of changes must be documented
Supplies of 2017-18 reported in
2018-19 and tax payable thereon Table consider 10 & 11 only
REPORTING IN GSTR-9
Correct figure as per Books of
Account = 100
Type of Error
Return July-17 to
March-18
April-18 to
March-19
Reporting in GSTR-9
Part-II Part-V DRC-03
Perfect Reporting GSTR-1 100 0 100 0 0
GSTR-3B 100 0
Short Reporting in GSTR-3B GSTR-1 100 0 90 10 0
GSTR-3B 90 10
Short Reporting in GSTR-3B GSTR-1 100 0 90 0 10
GSTR-3B 90 0
Correct figure as per Books
of Account = 100
Type of Error
Return July-17 to
March-18
April-18 to
March-19
Reporting in GSTR-9
Part-II Part-V DRC-
03
Short Reporting in GSTR-1 GSTR-1 90 10 100 0 0
GSTR-3B 100 0
Short Reporting in GSTR-1 GSTR-1 90 0 100 0 0
GSTR-3B 100 0
Excess Reporting in GSTR-3B GSTR-1 100 0 110 -10 0
GSTR-3B 110 -10
Excess Reporting in GSTR-1 GSTR-1 110 -10 100 0 0
GSTR-3B 100 0
Error Return July-17 to
March-18
April-18 to
March-19
Reporting in GSTR-9
Part-II Part-
V
DRC-
03
Non Reporting in GSTR-3B & 1
both
GSTR-1 90 0 90 0 10
GSTR-3B 90 0
Transaction
Pertains to
2017-18
Transaction
Pertains to
2017-18
Reported in
GSTR-3B of
2018-19
Reported in
GSTR-3B of
2018-19
Part-VPart-V
Any OtherAny Other
Part-IIPart-II
New discovered
liability – DRC-
03
New discovered
liability – DRC-
03
CA HIREN PATHAK
Order confirming
Demand
As on
31/03/2018
GSTR-9 :TABLEWISE POINTSTO BE CONSIDER
 Table-15
 Refund – Export with Payment of Tax / without payment of Tax
 Intermediary service provider
CA HIREN PATHAK
16(A)
• From Books of Account
• 3B Figure (Table-5) inclusive of Exempt and Nil rated supplies
16(B)
• Sec 143 – Min period is 1 year so not applicable for 2017-18
16(C)
• Not returned within 6 Month
• Figures Informative and not calculative
• Must be routed through GSTR-3B and 1
It may be noted that this summary details are required to be declared only for those inward supplies which in value
independently account for 10 % or more of the total value of inward supplies
ADDITIONAL LIABILITY AND PAYMENT
 DRC-03 for payment of Additional Liability (Only in Cash?)
 ITC to Recipient for such additional liability paid
 Late fee – 100 per day / 0.25% of turnover in a state (similar provision in SGST)
ISSUES IN REVIEWING BOOKS OF ACCOUNTS
 Sales Return credit note booked as Expense
 Discount credit note booked as Expense
 Single GST Ledger – DN / CN against Sale or Purchase?
 P&L having Profit/Loss on sale where as for GSTTransaction value is important
 Freight and Insurance collected – Net off in Expenses
CA HIREN PATHAK
CA HIREN PATHAK
1ST PRESS RELEASE ON ANNUAL RETURN – 04TH JUNE 2019
 FORM GSTR-2A as on 01.05.2019 shall be auto-populated
 Input tax credit on inward supplies shall be declared from April 2018 to March 2019 in Table
8C of GSTR-9
 Transactions for FY 2017-18 declared in returns between April 2018 to March 2019 shall be
declared in Pt.V of FORM GSTR-9
 Irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a
supply in Pt. II or Pt.V is essentially driven by when was tax paid through FORM GSTR-3B in
respect of such supplies.
 Declared in GSTR-3B of 2017-18 = Part-II
 Declared in GSTR-3B of 2018-19 = Part-V
 Declared in GSTR-3B of 2019-20 = ?
 Not declared in GSTR-3B till today = Part-II
1ST PRESS RELEASE ON ANNUAL RETURN – 04TH JUNE 2019
 Auto-population is a functionality provided to taxpayers for facilitation purposes, taxpayers
shall report the data as per their books of account or returns filed during the financial year.
 No Row has been provided to report IGST paid at the time of Import of Goods but credit
claimed in April-18 to March-19.Taxpayers are advised to fill in their entire credit availed on
import of goods from July 2017 to March 2019 in Table 6(E) of FORM GSTR-9 itself.
 Payments made through FORM DRC-03 for any supplies relating to period between July
2017 to March 2018 will not be accounted for in FORM GSTR-9 but shall be reported
during reconciliation in FORM GSTR-9C.
 Press release Link: http://www.cbic.gov.in/resources//htdocs-cbec/press-
release/03062019_Press_Release_on_Annual_Return.pdf;jsessionid=2974D268505BD3C9ED8BFA32BF6A7699
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Payment of unpaid Tax:
 Self-Declaration of correct tax payable. DRC-03 can be used to pay unpaid tax. – Legal Provision?
 Primary data source for declaration in annual return
 GSTR-1 vs GSTR-3B vs Books should match
 GSTR-3B and Books – data source
 No ITC can be availed or reversed by GSTR-9
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Relevance of Table- 8D (When figures in 2A is greater than ITC claimed)
 Credit available but not availed
 Not claimed in credit ledger hence there will not be any lapse.
 Therefore, taxpayers need not be concerned about the values reflected in this table.This is merely
an information that the Government needs for settlement purposes
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Relevance of Table-8J:
 As clarified IGST on
Import claimed in 18-19
shall be reported in
Table-6E.
 No ITC lapse, as already
claimed.
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Difficulty in reporting of information:
 Supplies received from Composition taxpayers
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Difficulty in reporting of information:
 HSN Summary of inward supplies
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Difficulty in reporting of information:
 It has been observed that smaller taxpayers are facing a lot of challenge in reporting
information that was not being explicitly reported in their regular statement/returns
(FORM GSTR-1 and FORM GSTR-3B).
 Therefore, taxpayers are advised to declare all such data / details (which are not part of
their regular statement/returns) to the best of their knowledge and records.
 This data is only for information purposes and reasonable/explainable variations in the
information reported in these tables will not be viewed adversely.
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Information in Table 5D (Exempted),Table 5E (Nil Rated) and Table 5F (Non-GST
Supply):
 It has been represented by various trade bodies/associations that there appears to be
some confusion over what values are to be entered in Table 5D,5E and 5F of FORM
GSTR-9.
 Since, there is some overlap between supplies that are classifiable as exempted and nil
rated and since there is no tax payable on such supplies, if there is a reasonable /
explainable overlap of information reported across these tables, such overlap will not be
viewed adversely.
 The other concern raised by taxpayers is the inclusion of no supply in the category of
Non-GST supplies in Table 5F. For the purposes of reporting, non-GST supplies includes
supply of alcoholic liquor for human consumption, motor spirit (commonly known as
petrol), high speed diesel, aviation turbine fuel, petroleum crude and natural gas and
transactions specified in Schedule III of the CGST Act
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Reverse charge in respect of FinancialYear 2017-18 paid during Financial Year 18-19:
 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).
 What is time of supply?
 Liability of which year? Role of Auditor in this case?
 What if RCM not paid at all?
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Role of CA/Cost Accountants in certifying GSTR-9C:
 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.
 Whether press release can override what's compel by Law?
 Definition of Audit
CA HIREN PATHAK
WHAT IS AUDIT AS PER GST LAW?
 “Audit means the examination of
 records, returns and other documents maintained or furnished by the registered person
 under this Act or the rules made thereunder or
 under any other law for the time being in force
 to verify the correctness of
 turnover declared,
 taxes paid,
 refund claimed and
 input tax credit availed,
 and to assess his compliance
 with the provisions of this Act or the rules made there under.”
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Turnover for eligibility of filing of reconciliation statement:
 Aggregate turnover i.e. the turnover of all the registrations having the same Permanent
Account Number is to be used for determining 2 cr. Limit
 The aggregate turnover for this purpose shall be reckoned for the period July, 2017 to
March, 2018.
 View of ICAI differ
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Treatment of Credit Notes / Debit Notes issued during FY 2018-19 for FY 2017-18:
 GST Credit note for 17-18 can only be issued till 30th Sep 2018
 Part-V of GSTR-9 = CN reported in 18-19 & provision made in books during 17-18
 Table-5O of GSTR-9C = DN reported in 18-19 & provision made in books during 17-18
CA HIREN PATHAK
2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION
STATEMENT– 03RD JULY 2019
 Reconciliation of input tax credit availed
on expenses:
 only those expenses are to be
reconciled where input tax credit has
been availed
 ITC on Salary?
 Any other expenses nature?
CA HIREN PATHAK
ISSUE RELATEDTO FILING OF GSTR-9C - GSTN CLARIFICATION
 DSC Related
 Class 2 & Class 3 DSC
 PAN Mismatch
 emSigner issue then - Stop and start with “Run as Administrator”
 Excel version higher than 2007
 Membership number :Without Prefixing ‘0’
 Compute Liability in GSTR-9: Only Late fee is counted
CA HIREN PATHAK
COMMON QUESTIONS
 Relying on Auto Generated GSTR-9
 What if Return filedWrong?
 Reverse charge paid in subsequent years
 How to calculate 10% reporting of HSN Summary of Inward supply
 6 digit HSN Required in GSTR-9
 How to derive turnover of multi-GSTN entity
 ITC eligibility on Provisional expense entry
 Personal expenses disallowed in income tax
 Whether DRC-03 can only be paid in cash?
 Turnover for GSTR-9C :Whether fromApril-17 to March-18 or July-17 to March-18?
 How to calculateTurnover of Rs.2 cr.?
 Whether non-reported transactions can be first time reported in GSTR-9. (+/-20%)
CA HIREN PATHAK
CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?
 Turnover on which GST has been paid = 100
GSTR-9Table Ref Reporting Amount
Table-5N Turnover as declared in 17-18 return + Additional Liability 85
Table-10 Increase in supply as reported in 18-19 20
Table-11 Reduction in supply as reported in 18-19 -5
Total (Figures to be reported in Table-5Q of GSTR-9C) (Except RCM) 100
CA HIREN PATHAK
CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?
Table 5Q of
GSTR-9C
Table 10 of
GSTR-9
Table 5N of
GSTR-9
Table 11 of
GSTR-9
GrossTurnover
Table 7F of
GSTR-9C
Table 4N of
GSTR-9
Table 4G of
GSTR-9
Table 10 of
GSTR-9
Table 11 of
GSTR-9
TaxableTurnover
CA HIREN PATHAK
CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?
 Tax Payable & paid = 100
GSTR-9Table Ref Reporting Amount
Table-9 Tax paid on supplies reported in 2017-18 85
Table-14 Tax paid on Net supplies reported in 2018-19 15
Total (Figures to be reported in Table-9Q of GSTR-9C) 100
• Tax paid through DRC-03 will not be consider in Tax paid details. Reason for
un-reconciled payment needs to be mentioned in GSTR-9C
• Tax payable needs to be amended to incorporate additional liability.
CA HIREN PATHAK
CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?
 Tax Payable & paid = 100
CA HIREN PATHAK
Table 9Q of
GSTR-9C
Table 9 of
GSTR-9
Rate wiseTax payable Tax paid as per GSTR-9
CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?
 InputTax Credit = 150
GSTR-9Table Ref Reporting Amount
Table-6 ITC availed during 2017-18 130
Table-7 ITC Reversed during 2017-18 (20)
Table-12 Reversal of ITC during 2018-19 (10)
Table-13 ITC availed during 2018-19 20
Total (Figures to be reported in Table-12E of GSTR-9C 110 (130-20)
CA HIREN PATHAK
Table 12E of
GSTR-9C
Table 7J of
GSTR-9ITC as per Financial
Net ITC as per GSTR-9
EXPORT
 With payment ofTax
 Option advisable when there is accumulation of ITC
 GSTR-3B and GSTR-1 comparison
 Merchant export @ 0.1% not permissible
 Without payment ofTax
 Option advisable when payment is required to me made in cash
 LUT required
CHANDULAL M SHAH & CO.
Select “prepare
offline” option from
Annual return GSTR-9
Tab from portal
Download Generated
JSON file from
“Download tab”
Download Offline tool
of GSTR-9
Import Generated
JSON file in offline
tool
Some of the data will
Auto populate
Fill GSTR-9 offline
tool and validate each
sheet(Even if it is
blank)
Generate JSON file
from Home page of
GSTR-9 Offline tool
Select “prepare
offline” option from
Annual return GSTR-9
Tab from portal
Select “Upload tab”
and upload the JSON
file
Status will be updated
in 15 Minutes
It may show
Error,You can
download
ERROR file
It may show
Status Proceed
Upload Error JSON file
in GSTR-9 Offline utility ,
It will show Error name.
GSTR-9 is uploaded
SuccessfullyCA HIREN PATHAK
Select prepare offline option from Annual return GSTR-9Tab from portal
Download Generated JSON file from “Download tab”
Download Offline tool of GSTR-9
Import Generated JSON file in offline tool
Fill GSTR-9 off line utility and validate each sheet(Even if it is blank)
Generate JSON file from Home page of GSTR-9 Offline utility
Select prepare offline option from Annual return GSTR-9Tab from portal
Select “Upload tab” and upload the JSON file
It may show Status Proceed
TECHNICAL ISSUES
 HSN Summary –Taxable value and Tax exact match
 Compute liability only compute late fee and not additional liability
 No Firm Name / FRN Number in GSTR-9C
 No place to mention UDIN
 Issue in uploading Financial statements
 Figure as per GSTR-9 reported in 9C
CA HIREN PATHAK
JSON ERROR SOLUTIONS
 Kindly follow below steps to understand the issue with the JSON if you are getting 'SCHEMA
VALIDATION FAILED! Download the latest version of Offline tool to generate the JSON file' or
'JSON StructureValidation'-
1. Go to https://developer.gst.gov.in/apiportal/taxpayer/returns
2. Click onView API List.
3. click on ‘GSTR9 - Save GSTR9 data’ and then version-v1.1 (On third page).
4. Click on Request Payload and then click on Download Schema
5. Go to https://www.jsonschemavalidator.net/
6. copy the schema and paste in Select schema: on https://www.jsonschemavalidator.net/ (first tab)
7. copy the JSON which is throwing error and paste in Input JSON: (second tab) and Click on the
format tab.The errors in the JSON will appear.
8. Correct the mentioned errors in the offline tool and generate the JSON again.
CA HIREN PATHAK
CA HIREN PATHAK
IMPORTANT LEGAL PROVISIONSTO CONSIDER
 Definition of Supply – Schedule-1 Transactions
 P&L credit side also to consider while verifying supply
 Blocked Credit – 17(5)
 Credit reversal as per Rule 42 & 43
 Time of supply - GST on Advances
 RCM provision – 9(3) & 9(4) – Self invoice and Payment voucher
 Valuation provision - Related party disclosure
 Job work – ITC-04
CA HIREN PATHAK
CHECKLIST - GST AUDIT PERSPECTIVE
 3Way Reconciliation – Books vs GSTR-1 vs GSTR-3B
 GSTR-3B vs GSTR-1 -Tax comparison
 GSTR-3B vs GSTR-2A - Tax comparison
 P&L having exempt supplies - Reversal of common credit
 Sales Register and GST Rate – Check material HSN rate
 GST Rate change
 Composite supply vs Mixed Supply
 Customer GSTN and Place of supply for Tax charged
 Customer ledger credit balances – GST on Advance
 Supplier GSTN and Tax charged
 Accounting Ledger Analysis – Ineligible ITC / Deemed supply / Reverse charge
 IGST paid on Import - matching with ICEGATE
 Export with payment ofTax – custom site data
 Credit ledger and Cash ledger comparison with yearend balance
GST – One Law , Different perspective
CA Hiren Pathak
E-mail : hbpathak@outlook.com
Mobile: 9033655245

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GST Annual Return (GSTR-9)

  • 1. ALL ABOUT GST ANNUAL RETURN - CA HIREN PATHAK
  • 2. MAJOR CHALLENGESWHILE FILING GSTR-9  Absence of GSTR-2 & 3  Frequent changes in GST Law  Change in logic of Preparation of Annual return  GSTR-3B & Books is base but GSTR-9 is prepared on the basis of GSTR-1  First time reporting of various information – e.g. I/IS/CG + Inward HSN / RCM Registered/Unregistered  Non availability of data in books of accounts – e.g.Taxable / Exempt / Common ITC / Composite purchase  GSTN wise Data  Non availability of trail for figures reported in 2018-19  Technical issues of GSTN CA HIREN PATHAK
  • 3. CHANGES IN GSTR-9  Notification 39/2018 – Central Tax dated 04th September 2018 – First time notified - Based on GST Returns  Notification 74/2018 – Central Tax dated 31st December 2018 – Based on actual supplies made  Notification 31/2019 – Central Tax dated 28th June 2019 - From Sep-18 to March-19 + Instructions  Updated GSTR-9 from CGST Rules – Part-B Forms amended up to 18th July 2019 CA HIREN PATHAK
  • 4. HEADING OF NEW GSTR-9VS OLD GSTR-9 OLD GSTR-9 NEW GSTR-9 As declared in Returns Supplies made during the year
  • 5. REPORTED OFVARIOUSTRANSACTIONS IN GST RETURNS Transactions of 2017-18 Return of 2017-18 Return of 2018-19 Sales Reversal Sales Debit note Credit note ITC Reversal ITC
  • 6. OVERVIEW OF GSTR-9 GSTR-9 Part-I Part-II Part-III Part-IV Part-V Part-VI Basic Information Liability Input tax credit Tax payable and Paid Adjustment in 2018-19 Other information Table 1-3 Table 4 & 5 Table 9 Table 10-14 Table 15-19Table 6-8
  • 7. LEGAL PROVISION OF GSTR-9  Section 44(1) : Every Registered person shall furnish Annual Return  Rule 80 : Required person to file GSTR-9 / GSTR-9A / GSTR-9B / GSTR-9C  Section 35(5) : Turnover more than Rs.2 crore then needs to file GSTR-9C
  • 8. WHO IS REQUIREDTO FILE GSTR-9? Who has to File?  Every Registered Person  No Turnover Limit Practical Issues  Registered as NormalTaxpayer and composite dealer both  Registration cancelled in 2017-18  Registration cancelled in 2018-19
  • 9. WHO IS NOT REQUIREDTO FILE GSTR-9? Not to file GSTR-9  Input service distributor  Person paying tax u/s 51 / 52  Casual taxable person  Non-Resident taxable person
  • 10. VARIOUS ANNUAL RETURNS UNDER GST  GSTR-9 :For RegularTaxpayer  GSTR-9A :For CompositeTaxpayer  GSTR-9B : For Person payingTax u/s 52 (TCS) (Not effective for FY 2017-18)
  • 11. NIL GSTR-9 “NIL” GSTR-9 RETURN can be filed, if you have  Not made any outward supply (commonly known as sale); AND  Not received any inward supplies (commonly known as purchase) of goods/services;AND  No liability of any kind; AND  Not claimed any Credit during the FinancialYear; AND  Not received any order creating demand; AND  Not claimed any refund.
  • 12. INSTRUCTION OF GSTR-9  GSTR-9 can be filed online. It can also be prepared on Offline Tool and then uploaded on the Portal and filed.  Annual return in form GSTR-9 is required to be filed by every taxpayer registered as normal taxpayer during the relevant financial year.  All applicable statements in Forms GSTR-1 and returns in Form GSTR 3B of the financial year shall have been filed before filing GSTR-9.  In case you are required to file GSTR-9C (Reconciliation statement and Certification); shall be enabled on the dashboard post filing of GSTR-9.  Annual return in Form GSTR-9 once filed cannot be revised.  Computation of ITC based on GSTR-2A was auto-populated by the System based on GSTR-1 filed by your corresponding suppliers upto 01/05/2019.  Due date: 31st August 2019 for GSTR-9 and GSTR-9C both
  • 13. GSTR-1 GSTR-3B Table-5,7,9,10 Table-3.1(a) Table – 4A/4C Table – 6A Table-3.1(b) Table - 6B Table – 6C Table-3.1(a) Outward supply on which Tax payable
  • 14. GSTR-1 GSTR-3B Table-11A Table-3.1(a) NA Table-3.1(d) Table-9B Table-3.1(a) Table-9A/9C Outward supply on which Tax payable
  • 15. IMPORTANT POINTS OF TABLE - 4  Zero rate supplies (Export and SEZ) both separate reporting  Advances received – GST paid – Invoice not issued up to March-19  Together with outward supply, inward supply under RCM is also reported  Supplies amended through Credit note/ Debit note vs Supplies amended through Amendments  Credit note as per Section 34  Credit note for the period 2017-18 vis-à-vis Credit note dated 17-18  Reported in GSTR-3B up to March-18
  • 16. GSTR-1 GSTR-3B Table-6A Table - 3.1 (b) Table-6B Table - 3.1 (b) Table-4B Table - 3.1 (d) Table-8 Table - 3.1(c) Table-9B Table – 3.1 (b) / (c) Table-9A / 9C Table – 3.1 (b) / (c) Outward supply on which Tax payable
  • 17. IMPORTANT POINTS OF TABLE - 5  Outward supply covered under RCM then table 5C  Since no tax payable,Tax amount column is not required  Exempted, Nil rated and Non GST supply reporting - ITC Reversal made?  Table 5N (including Table 10+11) will be matched with GSTR-9CTurnover  Reported in GSTR-3B up to March-18
  • 18. Remarks Total ITC availed as per GSTR-3B Table-(4)(A) (Reversal not consider) Table – 4(A)(5) of GSTR-3B (All other ITC) • Not always 9(4) • Only Unregistered persons • Table – 4(A)(3) • Not always 9(3) • Only Registered persons • Table – 4(A)(3) ITC Availment
  • 19. Remarks • Table-(4)(A)(1) • ICEGATE cross verification • Table – 4(A)(2) • Table – 4(A)(2) • Table – 4(A) This Row should be Zero ITC of TRAN-1 / to Match with Credit ledger ITC of TRAN-2 / to Match with Credit ledger
  • 20. IMPORTANT POINTS OF TABLE - 6  Break up of ITC into Input, Input service and Capital Goods – Not there in GSTR-3B  Break up of ITC inTable 6B to Table 6H as reported in GSTR-3B  Table 6J should be Zero  Reverse charge break up – Not there in GSTR-3B  Import of service – separate reporting, Not included in RCM  Transitional ITC - Can be Matched with Credit Ledger
  • 21. ITC Reversal Remarks Non Payment within 180 days Credit reversal by ISD • Taxable and Exempt supply • ITC on Input /Input service • Taxable and Exempt supply • ITC on Capital Goods Ineligible ITC – only if Added earlier TRAN-1 Reversal - CL TRAN-2 Reversal - CL Any other Reversal not specified This amount will be transferred to 9C
  • 22. IMPORTANT POINTS OF TABLE - 7  Reversal of ITC under different rules  What if not Reversed under GSTR-3B?  Reversal u/s 17(5) - Not as per GSTR-3B  Net ITC as per Table-7J –Transfer to GSTR-9C
  • 23. Remarks Only “filed” case ITC as on 28/02/2019 ITC as per GSTR-3B • ITC of 2017-18 claimed in 2018-19 • Up to Sep-18 or March-19? Difference can be + or - Voluntarily ITC not claimed Ineligible ITC hence not claimed IGST paid on Import Table- 4(A)(1) Not Affect Credit Ledger, Deemed Lapse GSTR-2A Reco
  • 24. HOW GSTR-2A FIGURES ARE CALCULATED? (TABLE-8A OF GSTR-9)  Why figures as per Downloaded GSTR-2A and Figures as per GSTR-2A inTable-8A doesn’t Match?  Out of filed/ saved / submitted Form GSTR-1 only FILED GSTR-1 figures are auto populated  GSTR-1 filed up to 01st May 2019 only to be considered  Updated value (After amendments if any) only will be reflected in Table-8A  POS other than receiver’s state will not be updated  RCM figures will not be updated  Supplier has filed GSTR-1 in 2018-19, GSTR-2A of 2017-18 will have impact?  https://www.gst.gov.in/newsandupdates/read/288 CA HIREN PATHAK
  • 25. IMPORTANT POINTS OF TABLE - 8  Informative and not calculative  No Impact on Credit Ledger  Ready tool forTax authority  Figures as per GSTR-2A keeps fluctuating  “Submitted” GSTR-1, not to be reflected in GSTR-2A  ITC of 2017-18, claimed in 2018-19 up March-19  IGST on Import claimed in 2018-19,Where to mention?  ITC Lapse figure only if amount reported inTable-8E andTable-8F
  • 26. Details as per GSTR-3B including RCM
  • 27. Remarks Supply / Tax Supply / Tax ITC ITC This Turnover and Tax will be Matched with GSTR-9C
  • 28. IMPORTANT POINTS OF TABLE – 10,11,12,13  Most discussedTables in entire GSTR-9  Removal of difficulty Order No.2 dated 31st December 2018  Differential tax liability only on account of changes in supply  Amendment only or New reporting also cover?  What if difference in GSTR-3B and GSTR-1?  Table 10 & 11 turnover will be added in table-5N. NetTurnover will be transferred to GSTR-9C  Log of changes must be documented
  • 29. Supplies of 2017-18 reported in 2018-19 and tax payable thereon Table consider 10 & 11 only
  • 30. REPORTING IN GSTR-9 Correct figure as per Books of Account = 100 Type of Error Return July-17 to March-18 April-18 to March-19 Reporting in GSTR-9 Part-II Part-V DRC-03 Perfect Reporting GSTR-1 100 0 100 0 0 GSTR-3B 100 0 Short Reporting in GSTR-3B GSTR-1 100 0 90 10 0 GSTR-3B 90 10 Short Reporting in GSTR-3B GSTR-1 100 0 90 0 10 GSTR-3B 90 0
  • 31. Correct figure as per Books of Account = 100 Type of Error Return July-17 to March-18 April-18 to March-19 Reporting in GSTR-9 Part-II Part-V DRC- 03 Short Reporting in GSTR-1 GSTR-1 90 10 100 0 0 GSTR-3B 100 0 Short Reporting in GSTR-1 GSTR-1 90 0 100 0 0 GSTR-3B 100 0 Excess Reporting in GSTR-3B GSTR-1 100 0 110 -10 0 GSTR-3B 110 -10 Excess Reporting in GSTR-1 GSTR-1 110 -10 100 0 0 GSTR-3B 100 0
  • 32. Error Return July-17 to March-18 April-18 to March-19 Reporting in GSTR-9 Part-II Part- V DRC- 03 Non Reporting in GSTR-3B & 1 both GSTR-1 90 0 90 0 10 GSTR-3B 90 0
  • 33. Transaction Pertains to 2017-18 Transaction Pertains to 2017-18 Reported in GSTR-3B of 2018-19 Reported in GSTR-3B of 2018-19 Part-VPart-V Any OtherAny Other Part-IIPart-II New discovered liability – DRC- 03 New discovered liability – DRC- 03 CA HIREN PATHAK
  • 35. GSTR-9 :TABLEWISE POINTSTO BE CONSIDER  Table-15  Refund – Export with Payment of Tax / without payment of Tax  Intermediary service provider CA HIREN PATHAK
  • 36. 16(A) • From Books of Account • 3B Figure (Table-5) inclusive of Exempt and Nil rated supplies 16(B) • Sec 143 – Min period is 1 year so not applicable for 2017-18 16(C) • Not returned within 6 Month • Figures Informative and not calculative • Must be routed through GSTR-3B and 1
  • 37. It may be noted that this summary details are required to be declared only for those inward supplies which in value independently account for 10 % or more of the total value of inward supplies
  • 38. ADDITIONAL LIABILITY AND PAYMENT  DRC-03 for payment of Additional Liability (Only in Cash?)  ITC to Recipient for such additional liability paid  Late fee – 100 per day / 0.25% of turnover in a state (similar provision in SGST)
  • 39. ISSUES IN REVIEWING BOOKS OF ACCOUNTS  Sales Return credit note booked as Expense  Discount credit note booked as Expense  Single GST Ledger – DN / CN against Sale or Purchase?  P&L having Profit/Loss on sale where as for GSTTransaction value is important  Freight and Insurance collected – Net off in Expenses CA HIREN PATHAK
  • 41. 1ST PRESS RELEASE ON ANNUAL RETURN – 04TH JUNE 2019  FORM GSTR-2A as on 01.05.2019 shall be auto-populated  Input tax credit on inward supplies shall be declared from April 2018 to March 2019 in Table 8C of GSTR-9  Transactions for FY 2017-18 declared in returns between April 2018 to March 2019 shall be declared in Pt.V of FORM GSTR-9  Irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a supply in Pt. II or Pt.V is essentially driven by when was tax paid through FORM GSTR-3B in respect of such supplies.  Declared in GSTR-3B of 2017-18 = Part-II  Declared in GSTR-3B of 2018-19 = Part-V  Declared in GSTR-3B of 2019-20 = ?  Not declared in GSTR-3B till today = Part-II
  • 42. 1ST PRESS RELEASE ON ANNUAL RETURN – 04TH JUNE 2019  Auto-population is a functionality provided to taxpayers for facilitation purposes, taxpayers shall report the data as per their books of account or returns filed during the financial year.  No Row has been provided to report IGST paid at the time of Import of Goods but credit claimed in April-18 to March-19.Taxpayers are advised to fill in their entire credit availed on import of goods from July 2017 to March 2019 in Table 6(E) of FORM GSTR-9 itself.  Payments made through FORM DRC-03 for any supplies relating to period between July 2017 to March 2018 will not be accounted for in FORM GSTR-9 but shall be reported during reconciliation in FORM GSTR-9C.  Press release Link: http://www.cbic.gov.in/resources//htdocs-cbec/press- release/03062019_Press_Release_on_Annual_Return.pdf;jsessionid=2974D268505BD3C9ED8BFA32BF6A7699 CA HIREN PATHAK
  • 43. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Payment of unpaid Tax:  Self-Declaration of correct tax payable. DRC-03 can be used to pay unpaid tax. – Legal Provision?  Primary data source for declaration in annual return  GSTR-1 vs GSTR-3B vs Books should match  GSTR-3B and Books – data source  No ITC can be availed or reversed by GSTR-9 CA HIREN PATHAK
  • 44. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Relevance of Table- 8D (When figures in 2A is greater than ITC claimed)  Credit available but not availed  Not claimed in credit ledger hence there will not be any lapse.  Therefore, taxpayers need not be concerned about the values reflected in this table.This is merely an information that the Government needs for settlement purposes
  • 45. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Relevance of Table-8J:  As clarified IGST on Import claimed in 18-19 shall be reported in Table-6E.  No ITC lapse, as already claimed. CA HIREN PATHAK
  • 46. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Difficulty in reporting of information:  Supplies received from Composition taxpayers CA HIREN PATHAK
  • 47. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Difficulty in reporting of information:  HSN Summary of inward supplies CA HIREN PATHAK
  • 48. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Difficulty in reporting of information:  It has been observed that smaller taxpayers are facing a lot of challenge in reporting information that was not being explicitly reported in their regular statement/returns (FORM GSTR-1 and FORM GSTR-3B).  Therefore, taxpayers are advised to declare all such data / details (which are not part of their regular statement/returns) to the best of their knowledge and records.  This data is only for information purposes and reasonable/explainable variations in the information reported in these tables will not be viewed adversely. CA HIREN PATHAK
  • 49. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Information in Table 5D (Exempted),Table 5E (Nil Rated) and Table 5F (Non-GST Supply):  It has been represented by various trade bodies/associations that there appears to be some confusion over what values are to be entered in Table 5D,5E and 5F of FORM GSTR-9.  Since, there is some overlap between supplies that are classifiable as exempted and nil rated and since there is no tax payable on such supplies, if there is a reasonable / explainable overlap of information reported across these tables, such overlap will not be viewed adversely.  The other concern raised by taxpayers is the inclusion of no supply in the category of Non-GST supplies in Table 5F. For the purposes of reporting, non-GST supplies includes supply of alcoholic liquor for human consumption, motor spirit (commonly known as petrol), high speed diesel, aviation turbine fuel, petroleum crude and natural gas and transactions specified in Schedule III of the CGST Act
  • 50. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Reverse charge in respect of FinancialYear 2017-18 paid during Financial Year 18-19:  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).  What is time of supply?  Liability of which year? Role of Auditor in this case?  What if RCM not paid at all? CA HIREN PATHAK
  • 51. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Role of CA/Cost Accountants in certifying GSTR-9C:  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.  Whether press release can override what's compel by Law?  Definition of Audit CA HIREN PATHAK
  • 52. WHAT IS AUDIT AS PER GST LAW?  “Audit means the examination of  records, returns and other documents maintained or furnished by the registered person  under this Act or the rules made thereunder or  under any other law for the time being in force  to verify the correctness of  turnover declared,  taxes paid,  refund claimed and  input tax credit availed,  and to assess his compliance  with the provisions of this Act or the rules made there under.” CA HIREN PATHAK
  • 53. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Turnover for eligibility of filing of reconciliation statement:  Aggregate turnover i.e. the turnover of all the registrations having the same Permanent Account Number is to be used for determining 2 cr. Limit  The aggregate turnover for this purpose shall be reckoned for the period July, 2017 to March, 2018.  View of ICAI differ CA HIREN PATHAK
  • 54. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Treatment of Credit Notes / Debit Notes issued during FY 2018-19 for FY 2017-18:  GST Credit note for 17-18 can only be issued till 30th Sep 2018  Part-V of GSTR-9 = CN reported in 18-19 & provision made in books during 17-18  Table-5O of GSTR-9C = DN reported in 18-19 & provision made in books during 17-18 CA HIREN PATHAK
  • 55. 2ND PRESS RELEASE ON ANNUAL RETURN & RECONCILIATION STATEMENT– 03RD JULY 2019  Reconciliation of input tax credit availed on expenses:  only those expenses are to be reconciled where input tax credit has been availed  ITC on Salary?  Any other expenses nature? CA HIREN PATHAK
  • 56. ISSUE RELATEDTO FILING OF GSTR-9C - GSTN CLARIFICATION  DSC Related  Class 2 & Class 3 DSC  PAN Mismatch  emSigner issue then - Stop and start with “Run as Administrator”  Excel version higher than 2007  Membership number :Without Prefixing ‘0’  Compute Liability in GSTR-9: Only Late fee is counted CA HIREN PATHAK
  • 57. COMMON QUESTIONS  Relying on Auto Generated GSTR-9  What if Return filedWrong?  Reverse charge paid in subsequent years  How to calculate 10% reporting of HSN Summary of Inward supply  6 digit HSN Required in GSTR-9  How to derive turnover of multi-GSTN entity  ITC eligibility on Provisional expense entry  Personal expenses disallowed in income tax  Whether DRC-03 can only be paid in cash?  Turnover for GSTR-9C :Whether fromApril-17 to March-18 or July-17 to March-18?  How to calculateTurnover of Rs.2 cr.?  Whether non-reported transactions can be first time reported in GSTR-9. (+/-20%) CA HIREN PATHAK
  • 58. CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?  Turnover on which GST has been paid = 100 GSTR-9Table Ref Reporting Amount Table-5N Turnover as declared in 17-18 return + Additional Liability 85 Table-10 Increase in supply as reported in 18-19 20 Table-11 Reduction in supply as reported in 18-19 -5 Total (Figures to be reported in Table-5Q of GSTR-9C) (Except RCM) 100 CA HIREN PATHAK
  • 59. CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED? Table 5Q of GSTR-9C Table 10 of GSTR-9 Table 5N of GSTR-9 Table 11 of GSTR-9 GrossTurnover Table 7F of GSTR-9C Table 4N of GSTR-9 Table 4G of GSTR-9 Table 10 of GSTR-9 Table 11 of GSTR-9 TaxableTurnover CA HIREN PATHAK
  • 60. CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?  Tax Payable & paid = 100 GSTR-9Table Ref Reporting Amount Table-9 Tax paid on supplies reported in 2017-18 85 Table-14 Tax paid on Net supplies reported in 2018-19 15 Total (Figures to be reported in Table-9Q of GSTR-9C) 100 • Tax paid through DRC-03 will not be consider in Tax paid details. Reason for un-reconciled payment needs to be mentioned in GSTR-9C • Tax payable needs to be amended to incorporate additional liability. CA HIREN PATHAK
  • 61. CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?  Tax Payable & paid = 100 CA HIREN PATHAK Table 9Q of GSTR-9C Table 9 of GSTR-9 Rate wiseTax payable Tax paid as per GSTR-9
  • 62. CROSS CHECK - HOWTO CHECK IF COMPLETE GSTR-9 IS PREPARED?  InputTax Credit = 150 GSTR-9Table Ref Reporting Amount Table-6 ITC availed during 2017-18 130 Table-7 ITC Reversed during 2017-18 (20) Table-12 Reversal of ITC during 2018-19 (10) Table-13 ITC availed during 2018-19 20 Total (Figures to be reported in Table-12E of GSTR-9C 110 (130-20) CA HIREN PATHAK Table 12E of GSTR-9C Table 7J of GSTR-9ITC as per Financial Net ITC as per GSTR-9
  • 63. EXPORT  With payment ofTax  Option advisable when there is accumulation of ITC  GSTR-3B and GSTR-1 comparison  Merchant export @ 0.1% not permissible  Without payment ofTax  Option advisable when payment is required to me made in cash  LUT required CHANDULAL M SHAH & CO.
  • 64. Select “prepare offline” option from Annual return GSTR-9 Tab from portal Download Generated JSON file from “Download tab” Download Offline tool of GSTR-9 Import Generated JSON file in offline tool Some of the data will Auto populate Fill GSTR-9 offline tool and validate each sheet(Even if it is blank) Generate JSON file from Home page of GSTR-9 Offline tool Select “prepare offline” option from Annual return GSTR-9 Tab from portal Select “Upload tab” and upload the JSON file Status will be updated in 15 Minutes It may show Error,You can download ERROR file It may show Status Proceed Upload Error JSON file in GSTR-9 Offline utility , It will show Error name. GSTR-9 is uploaded SuccessfullyCA HIREN PATHAK
  • 65. Select prepare offline option from Annual return GSTR-9Tab from portal
  • 66. Download Generated JSON file from “Download tab”
  • 68. Import Generated JSON file in offline tool
  • 69. Fill GSTR-9 off line utility and validate each sheet(Even if it is blank)
  • 70. Generate JSON file from Home page of GSTR-9 Offline utility
  • 71. Select prepare offline option from Annual return GSTR-9Tab from portal
  • 72. Select “Upload tab” and upload the JSON file
  • 73. It may show Status Proceed
  • 74. TECHNICAL ISSUES  HSN Summary –Taxable value and Tax exact match  Compute liability only compute late fee and not additional liability  No Firm Name / FRN Number in GSTR-9C  No place to mention UDIN  Issue in uploading Financial statements  Figure as per GSTR-9 reported in 9C CA HIREN PATHAK
  • 75. JSON ERROR SOLUTIONS  Kindly follow below steps to understand the issue with the JSON if you are getting 'SCHEMA VALIDATION FAILED! Download the latest version of Offline tool to generate the JSON file' or 'JSON StructureValidation'- 1. Go to https://developer.gst.gov.in/apiportal/taxpayer/returns 2. Click onView API List. 3. click on ‘GSTR9 - Save GSTR9 data’ and then version-v1.1 (On third page). 4. Click on Request Payload and then click on Download Schema 5. Go to https://www.jsonschemavalidator.net/ 6. copy the schema and paste in Select schema: on https://www.jsonschemavalidator.net/ (first tab) 7. copy the JSON which is throwing error and paste in Input JSON: (second tab) and Click on the format tab.The errors in the JSON will appear. 8. Correct the mentioned errors in the offline tool and generate the JSON again. CA HIREN PATHAK
  • 77.
  • 78. IMPORTANT LEGAL PROVISIONSTO CONSIDER  Definition of Supply – Schedule-1 Transactions  P&L credit side also to consider while verifying supply  Blocked Credit – 17(5)  Credit reversal as per Rule 42 & 43  Time of supply - GST on Advances  RCM provision – 9(3) & 9(4) – Self invoice and Payment voucher  Valuation provision - Related party disclosure  Job work – ITC-04 CA HIREN PATHAK
  • 79. CHECKLIST - GST AUDIT PERSPECTIVE  3Way Reconciliation – Books vs GSTR-1 vs GSTR-3B  GSTR-3B vs GSTR-1 -Tax comparison  GSTR-3B vs GSTR-2A - Tax comparison  P&L having exempt supplies - Reversal of common credit  Sales Register and GST Rate – Check material HSN rate  GST Rate change  Composite supply vs Mixed Supply  Customer GSTN and Place of supply for Tax charged  Customer ledger credit balances – GST on Advance  Supplier GSTN and Tax charged  Accounting Ledger Analysis – Ineligible ITC / Deemed supply / Reverse charge  IGST paid on Import - matching with ICEGATE  Export with payment ofTax – custom site data  Credit ledger and Cash ledger comparison with yearend balance
  • 80. GST – One Law , Different perspective
  • 81. CA Hiren Pathak E-mail : hbpathak@outlook.com Mobile: 9033655245