GST annual return and audit clarifications

   Recently the government has issued a press release regarding clarifications on GSTR9 &9C.

1. Till what date is the table 8 auto updated?

So the GST table 8, it is auto updated as on 30^thApril. So any supplier who has filed returns before 1^st may 19, data will be updated in GST 9 table.

2. ITC claimed till what date should be reported in GSTR9?

So the major confusion is in this area, that is till what date ITC is taken into consideration. So the recent law amendments were till March2019, however the portal was giving the facility only till September 18. So the question was, which figure to take, which was clarified in the press release today. The figure till March ’19 is taken into consideration for the purpose of ITC which is taken pertaining to the section. So 31^st march 2019 is the final date.

3. If there is any output liability pertaining to FY2017-18, which has been reported from the period starting April 18 to March19, then which date should be reported in GSTR9?

So a particular liability which was belonging to FY2017-18, declared in FY2017-18, but discharged inFY2018-19, so where to disclose it?

So the press release also states this. The table 10 &11, which was pertaining to amendments, in that table you can incorporate the figures for FY2017-18 if you have discharged liability in FY2018-19. So basically the amendment table is the right place to show this figure, as before this, there was no particular place to show this figure.

E.g. suppose the liability is of Rs.100, Rs.80 belonging to 2017-18 & Rs.20 belonging to 2018-19. So that Rs.80 if you have discharged in 2017-18 itself, you can show it in part 2 i.e. table 4& that Rs.20 that you are paying in 2018-19, that you can show in table 10 & 11. So the important thing to see is the month is which discharged& according disclosure for that year. So ultimately we have to go as per GSTR3B, irrespective of whatever we have shown in GSTR1. So table 10, 11 or 4 is what you will have to take according to your payment month.

So in conclusion,whatever data you have populated in GSTR1, the principle to populate data in GSTR9 would be based on whatever we have shown in GSTR3B.

4. So for reporting in GSTR9 which figure should be taken in: as per books, as per 3B or 1?

So this is a very basic fundamental for filing GSTR9. Due to the recent clarification, it has been cleared that you will use the figure as per books that you have finalized for income tax purposes, that should be your figure in GSTR9. Further DSR03 challan which was issued right for the beginning for discharge if any liability comes across is still in use for GSTR9 liability.

Remember that the auto-population facility for GSTR9 is just for ease of filing return provided by the government, but it does not mean that that figures you have to file, as the form which appears is editable in terms of liabilities. So those figures you can edit as per your books of accounts, and since the auto population just being a facility, correct figures need to be reported. So we need to ignore the auto populated figures and put in the right figures, if it is required.

5. If there is any additional liability to be discharged due to change in some figures, then how that has to be done?

As mentioned DR03 is the appropriate form to approve such. But please remember that this challan needs to be filed after filing GSTR9 return.

6. Clarification on IGST paid for import of goods paid in FY2018-19?

So what previously happened was the form which was being released , it used to take the figure of imports that is IGST paid on imports in 2017-18 but availed in 2018-19. Those figures had no place in GSTR9. Only those figures paid in 2017-18& claimed in 2017-18itself only were supposed to be in GSTR9. So now due to this press release , it has given us the space to report this 2018-19 figure for IGST that you have paid pertaining to imports of 2017-18. So now you can report both in 2017-18 ITCbeing clubbed together.

7. Any payment made to DRC03, will that have to be reported in GSTR9?

So as we know, GSTR 9 has to be filed before this challan, and thus showing details of such is not possible in GSTR9. However you can show it as part of reconciliation in case you fall under audits, but if you don’t, then you just pay your tax, and be ready for any notices.