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    GST Audit- Concepts

    GST Audit shall apply every year for those GST registered a business (GSTIN) having turnover more than Rs 2 crores, by the sale of goods or services in the financial year.

    This article covers the following:

    1. Need for GST Audits and meaning
    2. Types of Audits under GST
    3. Turnover-based Audit under Section 35(5) of CGST Act
    4. Qualification or Eligibility of GST Auditor
    5. Conducting GST Audit & Issue of GST Audit report

    1. Need for GST Audit and meaning

    Audit under GST includes an examination of records, returns and other documents maintained by a GST registered person. It ensures the correctness of turnover declared; input tax credit availed, refund claimed, taxes paid, and assess other such compliances under GST Act to be checked by an authorized expert.

    Under GST it is a trust-based taxation regime wherein a taxpayer is required to self-assess his tax liability, pay taxes and file returns. Thus, to ensure whether the taxpayer has correctly self -assessed his tax liability a robust audit mechanism is must. Various measures were taken by the government for proper implementation of GST and audit is one amongst them.

    2. Types of GST Audit

    Types Performed By When Initiated
    Turnover based Audit Chartered Accountant or Cost Accountant appointed by the taxpayer If the Turnover exceeds 2 crores the taxpayer has to get his accounts & records audited
    Normal audit/General Audit Commissioner of CGST/SGST or any Officer authorized by him On order of Commissioner by giving 15 days prior notice
    Special audit A Chartered Accountant or Cost Accountant, nominated by Commissioner On order of Deputy/Assistant Commissioner with prior approval of Commissioner

    3. Turnover-based Audit under Section 35(5) of CGST Act

    The annual turnover of a registered taxpayer was more than Rs. 2 crores in a financial year, he was required to get his accounts audited by a Chartered Accountant or Cost Accountant every year.

    A financial year covers the twelve-month period beginning from April to March of the next year.S

    If the annual turnover of a registered taxpayer was more than Rs. 2 crores in a financial year, he was required to get his accounts audited by a Chartered Accountant or Cost Accountant every year.

    A financial year covers the 12-month period beginning from April to March of the next year.

    Aggregate turnover is calculated as follows:

    Aggregate turnover = Value of all taxable (inter-state and intra-state) supplies + exempt supplies + export supplies of all goods and services

    The total turnover calculation should be PAN-based, which means that once the turnover under the PAN will more than Rs. 2 crores all business entities registered under GST for that PAN will be liable for GST audit for a financial year.

    Items included while calculating turnover:

    1. All taxable (inter-state and intra-state) supplies other than supplies on which reverse charge is applicable
    3. Supplies between separate business verticals.
    5. Goods supplied to/received from job worker on principal to principal basis.
    7. Value of all export/zero-rated supplies.
    9. Supplies of agents/ job worker on behalf of the principal.
    11. All exempt supplies. E.g. Agricultural produce supplied along with branded ready-to-eat food.
    13. All taxes other than those covered under GST Eg: Entertainment Tax paid on the sale of movie tickets.


    Items excluded while calculating turnover:

    1. Inward supplies on which tax is paid under reverse charge
    3. All taxes and cess charged under Goods and Service Tax like CGST, SGST or IGST, Compensation Cess.
    5. Goods supplied to or received back from a Job Worker.
    7. Activities which is neither supply of goods nor service under schedule III of CGST Act.


    4. Qualification of GST Auditor & Eligibility

    Only a Chartered Accountant or a Cost Accountant can perform a GST Audit u/s 35.

    Points to Note:

    1. An internal auditor cannot parallelly be appointed as a GST Auditor.
    2. The GST Act does not allow a GST practitioner to perform the audit. The power to audit was granted only to a Chartered Accountant or Cost Accountant who was in practice or was an employee of a firm of Chartered Accountants or Cost Accountants. Therefore, a Chartered Accountant should not be registered as a GST practitioner for the purpose of issuing the Audit Report.
    3. Where an organization or an institution and corporation has multiple branches registered under GST in different states/UTs, the total aggregate turnover of all such branches was considered while calculating the threshold limit of Rs. 2 crores. If the cumulative turnover of all the branches exceeds Rs. 2 crores, then the GST audit was applicable to each of these branches, irrespective of whether the turnover of a particular branch was less than the threshold. In such cases, one may appoint either one dedicated auditor for all branches or separate auditor for each branch. Where multiple branches have different auditors, the Standards on Auditing: SA 299 — Responsibility of the Joint Auditors should apply for the purpose of reporting GST Audit observations & Reporting.


    5. Conducting GST Audit & Issue of GST Audit report


    1. Appointment of GST Auditor:

    A  Board of Directors, proprietor, partner in case of a Company should appoint a GST Auditor at the beginning of the financial year.


    2. Accounts to be reviewed by GST Auditor:

    Following are important accounts or records for review:

    1. Sales Register
    2. Stock Register
    3. Purchase Register and Expenses ledgers
    4. Input tax credit availed and utilized
    5. Output tax payable and paid
    6. E-way bills generated during the period under Audit, if in compliance with rules.
    7. Any documents that record communications from the GST department relating to the year.


    3. Documents to be furnished by the taxpayer for GST Audit:

    1. Audited financial statements (which is PAN-based)
    2. Annual return in form GSTR-9 (for every GSTIN)
    3. Certified reconciliation statement in Form GSTR-9C, reflecting reconciled values of supplies and tax amounts declared in GSTR-9 compared to audited financials in Part-A, along with the Audit report in Part-B.


    6. Forms for Annual return and GST Audit:

    Type of taxpayerForm to be filed
    Whether or not applicable to GST Audit
    A Regular taxpayer filing GSTR 1 and GSTR 3BGSTR-9
    A Taxpayer under Composition SchemeGSTR-9A
    E-commerce operatorGSTR-9B
    Applicable for GST Audit
    Taxpayers whose turnover exceeds Rs. 2 crores in FYGSTR-9C


    Review of comments by GST Auditor:

    The Auditor should report any tax liability pending for payment by the taxpayer, identified along with the reconciliation exercise and observations made on GST audit. Taxpayers can settle taxes when the recommended made the auditor in Form DRC-03.


    7. Submission of GST Audit report & Annual return:

    The finalization of GSTR-9C can be certified by the same CA who conducted the GST audit or it can also be certified by any other CA who did not conduct the GST Audit for that particular GSTIN.

    The following should be reported and certified by the GST Auditor or the certifier:

    1. Whether or not all the requisite accounts or records are maintained.
    2. Whether or not the Financial Statements are prepared as per the books of accounts maintained at the principal place of business or additional place of business of the taxpayer.
    3. Certify the accuracy of the information in GSTR-9C.
    4. To list down the audit observations or reservations or comments, if any.


    8. Due dates for submission of GST Audit report:

    GSTR-9 and GSTR-9C are due on or before 31st December of the subsequent fiscal year.

    Special Note: For FY 2017-18, the due date for filing GSTR 9 and GSTR-9C is extended to 30th June 2019, through an order.


    9. Penalty for not submitting GST Audit report:

    There is no specific provision. Hence, it is subject to a general penalty of Rs.25,000.

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