1

Annual Returns under GST

T R Srinivasan FCA

COURTESY
GOODS AND SERVICES TAX| GSTR-9
ICAI
 Background – Legal Provisions 3

Annual Return under GST

Person liable for filing Annual Return: Every registered person, (other than an ISD, person liable to pay tax u/s 51 and 52, a
casual taxable person and a non-resident taxable person)

DUE Date of filing: Before the 31st day of December following the end of such financial year.

Form of Filing: Electronically in FORM GSTR-9 through the common portal

GST Annual Return|

Sep’2018
 Audit by CA / CMA [Sec. 35(5) and R.80] 3

 Every registered person whose turnover during a financial year exceeds the prescribed limit
(presently Rs.2 Crore) shall get his accounts audited by a CA or CMA
 He shall submit –
(a) Annual Return u/s 44
(b) Audited Annual Accounts along with a reconciliation statement reconciling the value of
supplies declared in return with Audited FS
(c) and such other particulars as may be prescribed.

 The Audited Annual Accounts to be submitted along with Annual Return (Form GSTR
9/9A/9B) on or before 31st December following the end of financial year in Form GSTR 9C.

 The contents of the Audit report, reconciliation statement and other particulars are to be
prescribed (Form GSTR 9C)
Audit by CA / CMA [Sec. 35(5) and R.80]
4
Goods /
Service?

Imp. of Multiple
Time Limit Units?

Issues Audit
Non Report to
compliance be
of AR submitted
State wise?

Can the
same
T/L for auditor be
Submsn appointed
for all
units?
 RELEVANCE OF ANNUAL RETURNS
Sl. Categor Section Particulars Relevant Date
No y Ref

1 AR 44(1) Every RP 31st December

2 AR 44(2) Every RP + Audit u/s 35(5) 31st December

3 ITC 16(4) Time limit for availing ITC DD u/s 39 for Sep or AR Date (Earlier)
4 CN 34(2) Time Limit for issuing Credit Note DD u/s 39 for Sep or AR Date (Earlier)

5 BoA 36 Period of retention of records 72 months from DUE date for AR

6 GSTR Prov. to Rectification of Errors and Omissions DD u/s 39 for Sept or AR Date WIE
37(3) in Outward supplies (GSTR-1)
 RELEVANCE OF ANNUAL RETURNS
Sl. Category Section Particulars Relevant Date
No Ref

7 GSTR Prov. to Rectification of Errors and Omissions in DD u/s 39 for Sept or AR Date
38(5) Inward supplies (GSTRR-2) WIE

8 GSTR Prov. to Rectification of Errors and Omissions in DD u/s 39 for Sept or AR Date
39(9) Returns (GSTR-3) WIE
9 Assmt 62(1) Assessment of non-filers of returns – Best 5 years from DD u/s 44
Judgement Assessment (BJA)
10 Assmt 63 Assessment of URP – BJA 5 years from DD u/s 44
11 Assmt 73(10) Determination of tax not paid or short 3 years from DD u/s 44
paid- No fraud cases
12 Assmt 74(10) Determination of tax not paid or short 5 years from DD u/s 44
paid- Fraud cases
 Snapshot of GSTR-9 7

Part-I Basic Details

Part-II Details of outward supplies declared in the return

Part-III Details of Input Tax Credit availed as declared in the return

Part-IV Details of Tax paid as declared in the return

Part-V Particulars of the transaction for the previous year declared in April to September return

Part-VI Other Information (Demand and Recovery, HSN Summary and etc.)

September
2018
Extract of GSTR-9 8
Part-1 Basic Details

September
2018
Part – II (Outward Supply) 9

Details for the period July’17- March’18 are to be

provided.

• Include sales made through Ecommerce Operator

• Net of DN/CN
• Refer Table5,7,9 & 10 of GSTR-1

• Include E-commerce operator.

• Exclude supply on which tax payable on RCM by
Recipient.
• DN/CN Separately
• Refer Table 4A and 4C of Form GSTR-1

• Supplier to charge only IGST on supply to SEZ, If

CGST and SGST charged then same shall be
amended.

• Deemed Export:- Advance Authorization, EPCG,

EOU etc.
• Includes RCM paid on inward supply from
Registered, Unregistered and Import of service.
• Refer table 3/1(d) of Form GSTR-3B

September
2018
Part – II (Outward Supply Contd..) 10

• CN/DN in respect of B2B supplies, supplies to SEZ, and

Deemed Export.
• Refer Table 9B – GSTR-1

• Amendments pertaining to July to March 18 done before

March 2018
• Amendment made after March 18 to be disclosed later
• Refer table 9A & 9C- GSTR-1

September
2018
Part – II (Outward Supply Contd..) 11

Table 6A and 6B of the GSTR-1 may be used.

• Outward Supplies on which tax is to be paid by

the recipient .
• Whether the tax amount has to be filled ?
• Refer Table 4B of GSTR-1

Supplies for which bill of supply has been issued

• Schedule III supplies

• Supply of goods outside the ambit of GST like
crude oil, Alcohol.
• Table 8 of the GSTR 1

September
2018
Part – II (Outward Supply Contd..) 12

DN/CN issued for supplies on which no taxes has been paid.

Refer Table 9B of GSTR-1

Details to be provided for the Amendment done in the return

during July’17-March’18

4N – Taxable Supplies and advances on which tax has to be

paid
5M – Exempted/ No supply Turnover
4G – Inward supplies on which tax has to be paid under
RCM

September
2018
13
 14
Situation
 (a) Intra-State supply to Registered Persons in July 2017 as reported in GSTR 1: Rs.10,00,000
 (b) Inter-State supply to consumer in October 2017 as reported in GSTR 1: 25,00,000
 (c) Intra-State supply incorrectly shown as supply to a consumer in October 2017 and rectified as
B2B supply in March 2018: 10,00,000
 (d) Inter-State supply to Registered Persons incorrectly shown with value of Rs. 5,00,000 in
November 2017 and rectified with value of Rs. 7,00,000 in May 2018
 (e) Credit note issued in March 2018 of Rs. 2,00,000 in respect of intra-State supplies made to
Registered Persons in December 2017 for Rs. 5,00,000
 (f) Credit note issued in April 2018 of Rs. 1,00,000 in respect of inter-State supplies made to
Registered Persons in January 2018 for Rs. 3,00,000
 (g) Outward supplies taxable under reverse charge basis in February 2018 as reported in GSTR 1:
Rs. 5,00,000
Part – III (Input Tax Credit)
15
Reconciliation with 3B

Table 4A of GSTR-3B contains ITC availed on Imports of Goods and Services,

Reverse charge and All other ITC

Bifurcation of Inward supplies into to Input, IS and CG. No similar requirement

in 3B.

Bifurcation of reverse charge credit on account of supplies received from

registered and unregistered person.

Inward supplies from SEZ included in Point 6B above.

Credit reclaimed on account of reversal due to non payment of consideration

within 180 days.

Ideally difference should be Zero.

TRAN-1: Credit of closing stock evidenced by invoices

TRAN-2: Credit of closing stock by registered person not posses invoices

ITC-01.- credit on Opt out of the Composition Scheme

ITC_02- Credit on Sale, Merger, amalgamation, lease and transfer.

Ideally be equal to total of credit’s in Electronic Ledger till March 18.

September
2018
Part – III (Input Tax Credit Contd..)
16

Reversal of ITC on account of non payment of consideration to supplier

within 180 days

Reversal of ITC on the basis of ISD credit note

Proportionate reversal of ITC with respect to

• Taxable and Exempt Supply
• Partly used for Business and other purpose

• 17(5) does not prescribe any reversal of credit.

• GSTR-3B Requires disclosure of ineligible credit u/s 17(5)
• Will it part of Total ITC Reversed as per Row I?

• Reversal of inadmissible credit taken (like Cess and irregular credit

under existing law)
• Reversal in 3B – Current Circular

• Credit Reversal through ITC-03 (Opting in for Composition Scheme)

September
2018
Part – III (Input Tax Credit Contd..)
12
Reconciliation with GSTR-2A

• Total credit available for inward supplies other than imports and inward
supplies liable to RCM but includes supplies from SEZ.
• Reflected in GSTR-2A table 3 & 5 is be auto populated

• This column may be negative if the vendor has not uploaded the return. In
that case whether company will have the negative balance?

• Maybe ineligible or not availed.

• Provides clarification that company can not claim credit after the due date

September
2018
Part – IV (Payment Details)
18

September
2018
Part – V (Details of Amendment of previous year return
through April to September return) 19

Amendment during April-September’18 for outward supply made

during the Period July’17-March’18

Details of credit appearing in GSTR-2A till march but taken in April to

September’2018

September
2018
Part – VI (Other Information's (Like Refund, HSN
Summary) 20

Details of Refund claims, provisional sanctioned, rejected

shall be provided

Should exclude provisional refund received

Details of Demand of taxes, tax paid on such demand and

demand pending under GST

September
2018
Part – VI (Other Information's (Like Refund, HSN
Summary Contd..) 21
Deemed supply-
Goods sent for job work not received within a period of 1 / 3 years.

Goods sent on approval basis- time limit of issuance of invoice 6 Months

from date of removal

HSN Summary:-
Upto 1.5 Cr - Optional
1.5- 5 Cr - 2 digit
5Cr and above - 4 digit

HSN wise inward summary to be provided, the same was the not disclosed
in any previous return.

Late fee payable on filing Annual return after due date

September
2018
 22
Specific Queries
 Can I avail ITC in the Annual Returns directly?
 Whether the supplier must mention the ITC in GSTR 2A to be claimed by
Recipient?
 Whether the credit can be availed by Recipient even if the Supplier has included in
B2C instead of B2B?
 Time limit for availing ITC?
 Eligibility of KKC and EC / SHEC?
 Concept of Financial Credit Notes
 Inter State Vs Intra State Misclassification
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Thank You
T R Srinivasan FCA
Ph: 97899 76079
trs.connects@gmail.com