Analysis

of
GST
Annual Return
(Form GSTR-9)
By,
CA. Naresh Nahar
 2
 Basic provisions
 Parts of GSTR-9
 Tables
 Constituents

 Treatment for transactions:

Scope  Recorded in Jul.17 – Mar.18 GSTRs
 Recorded in Apr.18 – Sep.18 GSTRs
 Recorded in Oct.18 – Mar.19 GSTRs
 Not recorded in GSTRs till date
 Points to ponder!
 Annual Return – Basics 3

Consequences
Who should file? By When? Form:
of non-filing:
All regd. persons except: • 30th Jun. • All regd. • Notice with
• ISD; 2019 (for persons – 15 days' time
• Person required to deduct tax 9M, FY18) GSTR-9; to file;
at source; • 31st Dec. of • Composition • Late fee:
• Person required to collect tax succeeding Dealer – Rs.200/day
at source; FY; (max. 0.5%
GSTR-9A
of State
• Casual Taxable Person; Turnover)
• E-com operator
• NR Taxable Person
reqd. to collect
• Entities holding UIN,
tax at source –
including UN agencies /
Embassies GSTR-9B
Filing of Nil GSTR- Dealer with cancelled Dealer who opted in / out of
9 compulsory? registration? composition scheme during the FY?
 GSTR-9 Format – Overview 4

Part I: Basic Details

Part II: Details of outward & inward supplies made during the FY

Part III: Details of ITC for the FY

Part Details of tax paid as declared in returns filed during the FY

IV:
Particulars of transactions for the previous FY declared in returns of
Part Apr. to Sep. of current FY or upto date of filing of annual return
V: of previous FY, whichever is earlier
Part VI: Other Information
 Part – II: Outward & Inward supplies made 5
during the FY
Part – II comprises: Should be filled with: Source for
filling:

Transactions Outward supplies:

Table – 4: Advances, From GSTR-1 (or)
inward recorded in
from GL, if missed to
& outward supplies – made GSTR of Jul.17 be recorded in GSTR-1
during the FY – on which – Mar.18 till date
GST is payable
Transactions
Inward supplies:
Table – 5: Outward supplies (pertaining to From GSTR-3B (or)
– made during the FY – 9M, FY18) from GL, if missed to
on which GST is not missed to be be recorded in GSTR-
payable recorded in 3B till date
GSTR till date
 Table-4: Inward & outward supplies 6
made
during the FY on which GST
Table 4 Constituents:
is payable
4A 4B 4C 4D 4E 4F 4G 4I / 4J 4K / 4L

SEZ Deeme Unadju Inward Credit Amend

B2C B2B Export
supplie d sted supplie / Debit ments
supplie supplie s Export advanc s– (+ / -)
s# s WPA s Notes
WPA s es** RCM # ** #
Y Y

Fields marked # – Refer next slide for details of

aggregation

Fields marked ** – Avoid double-count!

 Table-4: B2C, Cr./Dr. Notes & Amendments 7
–
Source of Information
Cred
it / Cr./Dr. Notes (Regd.) – B2B,
B2C (Others) Debi SEZ WPAY, DE
t
Amended B2C (Others) Note
B2C supplies (4A):

s Cr./Dr. Notes (Unregd.) –

B2C (Large) Invoices (4I / Exports WPAY
4J)
Amended B2B Invoices - B2B / SEZ
Amended B2C (Large) Invoices WPAY /

Amendments (+ / -)
** (4K / 4L):
DE
Credit / Debit Notes (Unregd.) – B2CL Amended Export Invoices -
WPAY
Amended Cr./Dr. Notes (Unregd.) – Amended Cr./Dr. Notes (Regd.) – B2B,
B2CL SEZ WPAY, DE
Amended Cr./Dr. Notes (Unregd.) –
Exports WPAY
 Table-5: Outward supplies made during 8
the
FY onExports
which GST is not payable
WOPAY SEZ
Outward supplies – RCM
WOPAY Fields marked ** –
Exempt Avoid double-count!

Table 5 – Nil-rated
Constituent Non-GST + Non-supplies
s Cr./Dr. Notes (Regd.) – SEZ
Credit / Debit Notes (5H / 5I) WOPAY
Cr./Dr. Notes (Unregd.) –
Exports Amended B2B Invoices – SEZ

Amendments (+ / -) ** WOPAY
(5J / 5K): Amended Export Invoices –
WOPAY
Amended Cr./Dr. Notes (Unregd.) – Exports
WOPAY Amended Cr./Dr. Notes (Regd.) –
 Part – III: Details of ITC for the FY 9

Should be filled
Part – III comprises: Source for filling:
with:

Transaction Table –
Table – 6: ITC s recorded 6: from GSTR-
Largely
availed during the in GSTR of 3B
FY Jul.17 –
Mar.18 Table – 7:
Table – 7: ITC Largely from GSTR-
& Ineligible ITC for the
reversed Transactions
3B (or) from GL,
FY (pertaining to if missed to be
9M, FY18) recorded in GSTR-
missed to be 3B till date
Table – 8: Other recorded in
ITC related GSTR till date # - ITC cannot be availed
information (FCM / RCM)
#
 Table – 6: Reconciliation of ITC availed 10

ITC availed on forward charge as per GSTR-3B

(+) ITC availed on reverse charge (dealing with unregd. persons) as per GSTR-3B

(+) ITC availed on reverse charge (dealing with regd. persons) as per GSTR-3B

(+) ITC availed on import of goods / services as per GSTR-3B

(+) ITC received from ISD / Re-claimed credit as per GSTR-3B

= Total ITC availed as per GSTR- ?? !!

3B
 Table – 7: ITC reversal / Ineligible ITC 11

Reversal as per R.37

Reversal as per R.42
– Non-payment of Reversal as per R.39
consideration within – ISD – Inputs / Input
6 months Services

Reversal as per R.43 Ineligible credit – Reversal of TRAN

– Capital Goods S.17(5) * credit

* This field should be entered only if the ITC availed figure is grossed up with ineligible credit in
GSTR-3B in the respective months.
 Table – 8: Reconciliation of 12
ITC
[GSTR-2A
ITC as per GSTR-3B (only v. 3B]
related to forward charge; claimed during Jul.17 –
Mar.18)

(+) ITC as per GSTR-3B (only related to forward charge; related to Jul.17 – Mar.18
but claimed during Apr.-Sep.18)

= ITC as per GSTR-2A (only related to forward charge)?

❑ If ITC as per GSTR-2A is higher compared to GSTR-3B, assessee should
fill: (i) ITC available but not availed; (ii) ITC available but ineligible.
❑ If ITC as per GSTR-3B is higher compared to GSTR-2A???
❑ Should the above table consider ITC availed during Oct.18 – Mar.19?
❑ The above table also captures the total ITC lapsed during the FY.
 Part – IV: Details of tax paid as 13
declared
Part – IV comprises: during the
with:FY
Should be filled Source for filling:

Transaction Payable:
Tax / Interest / s recorded From GSTR-3B (or)
Penalty / Late Fee in GSTR of from GL, if missed
Payable Jul.17 – to be recorded in
Mar.18 GSTR-3B till date
Paid through cash Tax Payable
(pertaining to Paid:
9M, FY18)
Auto-populated;
missed to be
Unable to edit the
recorded in
Paid through ITC online form
GSTR till date
 Part – V: Transactions for previous 14
FY
Should be filled
Part – V declared in Apr.-Sep.18
with:
Source for
filling
Tables 10 & 11: Supplies /
tax declared / reduced Transactions
(pertaining to Outward
through amendments (net of supplies:
debit / credit notes) 9M, FY18) From GSTR-1
recorded in
Table 12: Reversal of ITC GSTR of
availed during the previous FY Apr.- ITC related
Should outward
Sep.18 information:
Table 13: ITC availed for the supply & ITC availed From GSTR-
previous FY info (recorded in 3B
GSTR of Oct.18–
Table 14: Differential tax Mar.19) be recorded
paid here?
/ payable
 Part VI: Other Information 15

Refunds (claimed
Supplies from Deemed supply –
Demands (paid / / sanctioned / composition related to job
pending) rejected / dealer work
pending)

Goods sent on
HSN-wise HSN-wise
approval but not Late fee payable /
summary of summary of
returned within paid
180 days outward supplies inward supplies #

# – If the individual component is > 10% of total value # – Denominator to exclude value of non-supplies (e.g.,
of inward supplies salaries)!
 Payment of additional liabilities 16

Can GSTR-9 be How to pay Mode of payment of

revised? additional liabilities? additional liabilities?

No Form GST Only from e-cash

DRC-03 ledger!
Thank You
CA. NARESH NAHAR
S R K N AND ASSOCIATES
Chartered Accountants
101 Lal Ganga Business Park
Near Pachpedi Naka, Raipur
+91 99932 94999 +91 771 4900499