GSTR-9 & GSTR-9C Practical Approach: Form-Level Discussion, Audit, and Reporting

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This practical guide provides a detailed discussion on GSTR-9 and GSTR-9C, covering form-level details, GST audit, reporting of turnover data, and addressing common issues like over-reporting, under-reporting, and mis-reporting. Learn about liability, ITC, taxes paid, adjustments, and more. Discover how to correct errors and ensure accurate compliance with GST regulations.

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GSTR 9 & 9C- A Practical Approach CA Vikash Kumar Banka Association Of Corporate Advisers & Executives -EIRC 11.11.2019

Contents GSTR 9- Form Level Discussion GST Audit-Legal Provisions Practical approach to GST Audit GSTR 9C-Form Level Discussion 2

Annual Return Applicable to Not Applicable to ISD/TDS/TCS Regd. Persons Composition Taxpayers ECO if TCS u/s 52 If Aggregate Turnover>2 Cr. CTP/NRTP OIDAR GSTR9 GSTR 9A GSTR 9B CG/SG Dept/LA- CAG Audit, LA audit GST Audit 9C

GSTR-9 Part I Part II Part III Part IV Part V Part VI Basic Details Liability ITC Taxes Paid Circular 26/2017 Adjustments Other Info Table 1-3 Table 4-5 Table 6-8 Table 9 Table 10-14 Table 15-19 5

Reporting of Turnover Data in GSTR 9 Source: GSTR 1-Different Tables (As downloaded from GST Portal) 6

Issues in GSTR 9 Over-reporting, Under-reporting, Mis-reporting in GSTR- 1 but correct reporting in GSTR 3B. What to do? Over-reporting, Under-reporting, Mis-reporting in GSTR- 3B but correct reporting in GSTR 1. What to do? 7

Issues in GSTR 9 Over-reporting, Under-reporting, Mis-reporting both in GSTR-1 & 3B. What to do? B2B supply reported as B2C in GSTR 1. Can we correct it in GSTR-9? If yes, will it be reflected in GSTR 2A of the recipient? 8

Issues in GSTR 9 Export reported in outward taxable supplies row 3.1(a) in GSTR 3B. Can we correct it now in GSTR-9? Outward supply for FY 17-18 reported in 18-19. Where to report this in GSTR-9? 9

Issues in GSTR 9 ITC for FY 17-18 reported in 18-19. Where to report this in GSTR-9? RCM for FY 17-18 paid in 18-19. Where to report this in GSTR-9? 10

Issues in GSTR 9 Outward supply not reported till now. Can it be reported now and tax paid thereon? Reverse Charge supply not reported till now. Can it be reported now and tax paid thereon? If yes, can ITC be claimed on it now? 11

Issues in GSTR 9 Ineligible ITC not reversed till now. Can it be reversed now and tax paid thereon? If yes, where to report? Whether 6B to 6H figures are to be reported as per books of accounts or it should be a bifurcation of Table 6A? 12

Issues in GSTR 9 Supply not reflecting in GSTR 2A but claimed in 3B resulting in (-) balance in 8D. What to do? Supply reported in GSTR 2A but not in 3B resulting in (+) balance in 8D. What to do? 13

Issues in GSTR 9 If supply is not reflected in GSTR 2A, can the recipient claim input tax credit? Supplier made a supply on 30th March, 2018. Buyer received it on 2ndApril, 2018. Supplier shown the supply in GSTR 1 of March 18. This supply is reflected in GSTR 2A of buyer in March 18. Buyer claimed ITC on it in April 18. Where to show this ITC in Table 8? 14

Issues in GSTR 9 If interest not paid, whether needs to be calculated and reported in Table 9? If GSTR 9 filed and not reported, whether auditor needs to report it in Table 9L, 11 and part V of GSTR 9C? Whether status of refund as on date to be reported in Table 15 or as on 31.03.2018? 15

Issues in GSTR 9 In Table 16A, Supplies from composite taxpayers was auto populated. However, I have not received any such supplies. What to do? 16

GSTR-9 at a glance Description Table No. of GSTR 9 Turnover as per Books = 4 + 5 + 10-11 Tax Paid as per Books ITC as per Books Refund Informative details Late Fee payment = = = = = 9 & 14 6-7-12+13 15 1,2,3,8,16,17,18 19 17

Supply GST Supply- Sec 7 Non-GST Supply Non-Taxable Supply-Sec 2(78) Taxable Supply- Sec 2(108) Exempt Supply- Sec 2(47) Nil Rated Supply 18

Meaning of Goods & Services Goods- Sec 2(52) Services- Sec 2(102) Services means anything other than goods, money and securities but includes activities relating to the use of money or its conversion by cash or by any other mode, from currency or denomination, to another form, currency or denomination for which a separate consideration charged; Goods kind of movable property other than money and securities but actionable claim, growing crops, grass and things attached to or forming part of the land which are agreed to be before supply or under a contract of supply means every includes one form, severed is 19

Exempt Supply- Sec 2(47) Exemptsupply means supply of any goods or services or both which attracts nil rate of tax or which may be wholly exempt from tax under section 11, or under section 6 of the IGST Act, and includes non-taxable supply;

Nil Rated Supply No such rate in N. No.01/2017-CT (Rate) dt. 28.06.17 relating to Goods Three rates in N. No.11/2017-CT (Rate) dt. 28.06.17 relating to Services: Sl. No. 24 (i) Heading 9986 Description Support services to agriculture, forestry, fishing, animal husbandry Ex- Supply of farm labour, Renting or leasing of agro machinery or vacant land, Loading, unloading, packing, storage or warehousing of agricultural produce;

Nil Rated Supply Sl. No. 16(i) Heading 9972 Description Services by CG, SG,UT or local authority to governmental government entity, by way of lease of land authority or 16(ii) 9972 Supply of land or undivided share of land by way of lease or sub lease where such supply is a part of composite supply of construction of flats, etc. specified in the entry in column (3), against serial number 3, at item (i) (ia), (ib), (ic), (id), (ie) and (if)]

Examples- Books & GSTR 1 matched but not 3B Turnover T4 T 10 Period July 17 Mar 18 Books 100 GSTR 1 GSTR 3B 100 100 100 Nil July 17 Mar 18 April 18-Mar 19 100 100 80 20 80 20 July 17 Mar 18 April 18-Mar 19 Unreported till date 100 100 80 10 10 80+10 10 23

Examples- Books & GSTR 3B matched but not GSTR 1 Turnover T4 T 10 Period July 17 Mar 18 Books 100 GSTR 1 GSTR 3B 100 100 100 Nil July 17 Mar 18 April 18-Mar 19 100 80 20 100 100 Nil July 17 Mar 18 April 18-Mar 19 Unreported till date 100 80 10 10 100 100 Nil 24

Examples- GSTR 1 & 3B do not match with Books Turnover T4 T 10 Period July 17 Mar 18 Books 100 GSTR 1 GSTR 3B 100 100 100 Nil July 17 Mar 18 April 18-Mar 19 100 80 20 80 20 80 20 July 17 Mar 18 April 18-Mar 19 Unreported till date 100 80 10 10 80 10 10 80+10 10 25

GST Audit 26

Practical approach to GST Audit? Remarks Appendix 2,Page No. 178 of TG Obtain Appointment letter Issue Acceptance letter Appendix 2,Page No. 178 of TG Obtain Management Representation (MR) Letter Appendix 4,Page No. 199 of TG Copy of Registration Certificate Copy of audited annual accounts REG 6 If multiple GSTIN: Alongwith above, obtain books of accounts for each GSTIN alongwith consolidated statement Copy of GSTR 9 27

Practical approach to GST Audit? Remarks Copy of GSTR 1 (alongwith working sheet) % wise outward supply details % wise outward supply, tax on which to be paid by recipient under reverse charge Invoice wise outward supply statement ITC Details Copy of GSTR 3B (alongwith working sheet) Copy of GSTR 2A Expenses head wise ITC details containing value, ITC and eligible ITC Copies of: E. Cash Ledger; E-Credit Ledger and E-Liability Ledger Alongwith Monthly Summary sheet of discharge of liability Audit Checklist Appendix-10, Page No. 491 of TG 28

GSTR 9C- Form Level Overview GSTR 9C Part A- Reconciliation Statement Part B- Certificate 29

Part A- Reconciliation Statement Part I Part II Part III Part IV Part V Basic Details Reco of Turnover Reco of Tax paid Reco of ITC Auditor s recommendation on additional liability due to non-reconciliation Sl. No. 1-4 Sl. No. 5-8 Sl. No. 9-11 Sl. No. 12-16 REG 6 Audited accounts, GSTR 1, GSTR 3B, GSTR 9 3B, 2A, working sheet, Exp head wise ITC details % wise O/s details (also of RCM),E-cash, E-credit, E-Liability Ledger, Monthly Summary sheet of discharge of liability 30

Data Flow-GSTR-9 to 9C Table No. of 9C Description Table No. of GSTR 9 5Q Turnover as declared in Annual Return (GSTR-9) Taxable turnover as per liability declared in Annual Return (GSTR-9) Total amount paid as declared in Annual Return (GSTR 9) ITC claimed in Annual Return (GSTR 9) ITC claimed in Annual Return (GSTR 9) = 5N +10-11 7F = 4N-4G+10-11 9Q = 9+14 12E 14S = = 7J 7J 31

Issues Sl. No. Issues Form 9C-T9Q Solutions Give reconciled T10. Amount payable as per T9 + Diff. tax as per T14 of GSTR9 is auto populated here. However, auto population is of taxes only and not of Int, Late Fee & penalty in T9 & Int in T14 resulting in differences of 9Q with 9P. This results in un-reconciled figure in T9R. reason for un- in amount

Some Suggestions Don t copy figures in 9 & 9C. This will result in error while uploading. However, written text can be copied using F2 There should not be single paisa difference in five figures of GSTR 9 which are reported in 9C File which is to be uploaded should not be saved in network server. Keep it in local PC. While GSTR 9C offline utility is downloaded and extracted, it contains one file wsweb . Keep this file in the same folder in which excel file is saved. Do not override other client s figures. Always use fresh form. DSC must be plugged in before proceeding to generate Json file.

Some Suggestions Don t put zero before membership No. in Part V and in B(i) or B(ii) in GSTR 9C. PAN No. of Auditor in Part V of GSTR 9C must be same as in DSC. To get HSN code of 4 digit, type 3 digit. If you type 4 digits, it will show 8 digits. In B(i) or B(ii), Cash Flow Statement is a mandatory field. Where it is not applicable, put date there and give observation in Para 5. Para 5-Observation/Qualification: Even if there is no observation/ Qualification, enter at least Nil.

Some Tech issues Sl. No. 1 Steps Before signing 9C, close all other emsigners. Download emsigner from GST portal and run as administrator. 2 Java Version 8 update 101 and above 3 Excel 2007 and above 4 If web socket for emsigner is not opening, then type https:\\127.0.0.1:1585 in address bar. Then click proceed to safety and follow instructions.

Steps for signing GSTR-9C using Offline Utility V1.2: Sl. No. 1 Steps Please ensure Internet Explorer 11 is installed. 2 Open the Offline Utility excel file and make sure all data is correctly filled up. 3 4 5 Click on generate JSON file. This will open Internet Explorer. Click on the Internet Explorer (e) icon in the taskbar. Press F12 to open Developer Tools.

Steps for signing GSTR-9C using Offline Utility V1.2: Sl. No. 6 Steps On the right side of Developer Tools, there should be a button with "5" written on it. Click on it and change it to Edge. 7 Then click on the x button on the right to close Developer Tools. 8 Continue signing as per instructions given in the web page.