What is GSTR-9?
GSTR-9 is the annual return that all registered people should file a return must be filed annually on 31 December of the financial year. Businesses are required to file this return on time. In a recent announcement, CBIC extended due dates for filing GSTR-9, GSTR-9A, and GSTR-9C up to 30th June 2019.
The GSTR-9 return is a summary of a business’s monthly or quarterly returns, i.e., the total number of transactions in a particular financial year. It includes the amount of taxes paid (CGST, SGST, IGST) during the year, as well as details of exports or imports.
The purpose of the GSTR-9 is to synthesize information previously furnished in the monthly or quarterly returns. This implies that all monthly and quarterly returns should be filed before filing the annual return. Moreover, the GSTR-9 is not a rectification return but a consolidation return, which requires that data provided in monthly and quarterly returns should match the data on the GSTR-9 exactly.
Types of forms
Filing the GSTR-9 return involves the following forms:
GSTR-9A: This form is to be filed by taxpayers registered under GST’s composition scheme. It is a summary of all quarterly returns previously filed by the composition taxpayer. (Proviso to Sub Rule (1) of Rule 80)
GSTR-9B: This form must be filed by ecommerce operators who have filed GSTR-8 during the previous financial year. Competent authority certified the annual audited, account. (Sub Rule 2 of Rule 80)
GSTR-9C: This is a reconciliation statement to be filed by taxpayers whose annual turnover exceeds INR 2 crores (for all states) during the financial year. All such taxpayers are required to have their accounts audited by a Chartered Accountant, or Cost Accountant, and file a copy of their audited annual accounts. They should also file a reconciliation statement of tax already paid and details of tax payable as per audited accounts, along with this return.
All registered, taxable persons are responsible for filing a GSTR-9 return, regardless of whether there were business operations during the year (i.e., even if all the returns during the period were NIL, a Nil Annual Return must be filed). This annual return was also required in cases where a taxpayer has cancelled their registration during the year.
However, the following persons are not required to file GSTR-9 as per Section 44(1) of the CGST Act, 2017:
- Input service distributors
- Non-resident taxable persons
- Casual taxable persons
- Persons paying tax under section 51 or 52 (i.e., persons paying TDS).
Furthermore, taxpayers opting for a composition scheme will file GSTR-9A in lieu of GSTR-9.
A registered person who has switched from regular to composition, or composition to regular, is required to file both GSTR-9 & GSTR-9A for the relevant period.
Structure of GSTR-9
GSTR-9 is divided into 6 parts :
Part I: This part asks for basic details, such as the financial year, GSTIN, legal and trade names. These details will be auto-populated in the form.
Part II: This part asks taxpayers to provide details of inward and outward and supplies declared during Financial Year (FY). This part requires furnishing the details of all outward supplies made during the year (segregated between supplies liable to tax and not liable to tax) and inward supply liable to reverse charge basis. This includes not only the original supply as reported in the periodical returns but also the amendments made therein. This part is further subdivided in the below tables:
- Table 4: All transactions on which tax liability has arisen segregated in below: o Taxable outward supplies (segregated in various categories based on nature) o Advance received in respect of which invoice has not been issued o Inward supply on which liability arises under reverse charge mechanism
- Table 5: Details of outward supplies on which tax is not payable during the financial year. This includes exempted supplies, non-GST supplies, and zero-rated supplies. Total of Table 4 and Table 5 gives the turnover of the registered person during the financial year
Part III: This is where taxpayers will give details of the Input Tax Credit (ITC) as declared in returns filed during the financial year. Part III also asks for details of the ITC reversed and ineligible ITC as declared in individual returns. This part has below tables:
- Table 6 of GSTR 9: Details of ITC availed as declared in the Return has to be given in this part of the Table. Total ITC availed is auto-populated from GSTR-3B whereas the details of the ITC segregated in the inputs, input services and capital goods have to be provided by the registered person in respect of different categories of inward supplies. This part also requires separate disclosure of the transitional credits availed by the registered person.
- Table 7 of GSTR 9: The details of ITC reversed and ineligible ITC to be declared in this part. The difference between Table 6 and Table 7 indicates total credit which is available for utilization with the registered person during the financial year.
- Table 8: This table requires certain additional information to be furnished in the Annual Return related to ITC. The information contained in this Table is mainly for the purpose of analysis of the government to identify the instances of over/under availment of credit. The main part which requires disclosure is matching the credit availed in the GSTR-3B viz a viz credit which is auto-populated in the GSTR-2A.
Part IV: taxpayers will input details of taxes paid as declared in returns filed previously during the financial year. (Table 9)
Part V: This asks for transaction particulars of the previous financial year, declared in returns from April to September of the current financial year, or up to the date annual returns of the previous financial year were filed, whichever is earlier. Additional or omitted entries belonging to the previous financial year, but reported in the current financial year, would be declared here as well. (Table 10 to 14)
Part VI: Taxpayers will report other information here. This could include demand and refund details; supplies received from composition taxpayers deemed supply goods sent on approval basis; HSN-wise summary of outward and inward supplies; or late fees payable as well as those paid. Following details to be provided table wise:
- Table 15: Particulars of demand and refunds
- Table 16: Information on supplies received from composition taxpayers, deemed supply under section 143 (job work) and goods sent on approval basis
- Table 17: HSN wise summary of outward supplies
- Table 18: HSN wise summary of inward supplies
- Table 19: Late fees payable and paid for delay in filing of Annual Return
Last part of the Annual Return requires verification to be made by the registered person filing the Annual Return. Such a person has to declare that information contained in the Annual Return is true and the benefit of any reduction in output tax liability has been passed or will be passed on to the recipient of the supply.
A Checklist of important points to be kept in mind before filing your GST annual return
- The Financial year (FY) for the purpose of this first annual return in GST will comprise only nine months, i.e., July 17 to March 18.
- Taxpayers will need to take nine months’ worth of data from their total turnover. Before heading to file GSTR 9, it is essential to ensure that monthly or quarterly returns are synchronized and matched with books of accounts.
- Keep a list of all tax invoices in proper format with GSTIN details in respect of period July 17 to March 18. Since form GSTR-9C requires state-wise data, also keep a list of state-wise figures of turnover ready and reconciled.
- Make a list of all debit and credit notes issued during the period mentioned above.
- The government issued a notification of a change in the treatment of advances 66/2017. Pursuant to the notification, taxpayers must reconcile advances received with the amount of GST paid for goods and services from July 1 to 15 November 2017. This requirement also applies to advances received for services and GST paid from 15 November 2017 to 31 March 2018. Exemptions are available only in cases of the supply of goods, and not for the supply of services.
- In case of multiple storage branches, stock transfers amongst branches must also be reconciled. The stock held as per books of accounts and the GST annual return must be identical.
- Annual returns call for consolidation of data reported, such as between e-way bill data and tax invoices, over the entire the entire fiscal year. This is to ensure the accuracy of the declarations made on annual returns and will also help avoid duplications.
- The annual return requires splitting of total amount of input tax credit (ITC) into three categories: inputs, input services, and capital goods. This was not required in forms GSTR-3B or GSTR-1, however businesses will need to compile this data before filling out GSTR-9.
- Every bill in which a taxpayer has claimed an input credit should be reflect this information in form GSTR-2A. These input tax credits should be paid within 180 days, otherwise the ITC on these invoices will need to be reversed. Furthermore, take special care while reporting the ITC claim because any unutilised ITC cannot be claimed later or reversed, even in the annual return. GSTR-9 also calls for expense head wise bifurcation of ITC availed.
- Part VI in the annual return calls for all taxpayers to provide a summary of outward and inward supplies according to HSN. In previous forms GSTR-3B and GSTR-1, only taxpayers with an annual turnover of Rs 1.5 crore or more were required to classify their supplies in this way.
- Identify the adjustments required for unbilled revenue.
- While reconciling the GST paid by electronic cash or credit ledger, taxpayers should also account for any GST paid by way of a reverse charge mechanism on applicable expenses.
- If filing a refund application for the said period, details regarding the refund must be reported separately in Part VI of the annual return.
GST audits are different from traditional VAT, excise, service tax, or other, similar audits. Since Auditor is required to certify GSTR-9C returns as true and correct instead of true and fair hence a much higher responsibility is cast upon the auditor.
Technology is important for reconciling the data between books of accounts with what is reported on GST forms in order to ensure the correct application of GST provisions.
Automated GST compliance software with MaxBusiness will help taxpayers handle voluminous amounts of data from multiple sources and formats and provide businesses the means to verify whether the figures in their books of accounts and those reported in their GST annual returns are reconciled.