An article on annual return under Goods & Services Tax

1. ANNUAL RETURN UNDER GST
1
CACA N.RAMASWAMY, F.C.A.N.RAMASWAMY, F.C.A.
CHENNAI- 600024CHENNAI- 600024
PH- 04424732130PH- 04424732130
MOBILE: 9840446412MOBILE: 9840446412
CA.N.RAMASWAMY

2. Introduction
l: What is GSTR 9 annual return?
GSTR 9 form is an annual return to be filed once in a year by the
registered taxpayers under GST. It consists of details regarding the
supplies made and received during the year under different tax
heads i.e. CGST, SGST and IGST. It consolidates the information
furnished in the monthly or quarterly returns during the year.
2. Who should file GSTR 9 annual return?
All the registered taxable persons under GST must file GSTR 9
form. But the following persons are not required to file GSTR 9
Taxpayers opting Composition scheme as they must file GSTR-9A
Casual Taxable Person Input service distributors
Non-resident taxable persons Persons paying TDS under section 51
of GST Act
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3. Type of annual returns under GST
There are 4 types of annual returns :
GSTR 9: GSTR 9 should be filed by the regular taxpayers
filing GSTR 1, and GSTR 3B.
GSTR 9A: GSTR 9A should be filed by the persons registered
under composition scheme under GST.
GSTR 9B: GSTR 9B should be filed by the e-commerce
operators who have filed GSTR 8 during the financial year.
GSTR 9C: GSTR 9C should be filed by the taxpayers whose
annual turnover exceeds Rs 2 crores during the financial year.
All such taxpayers are also required to get their accounts
audited and file a copy of audited annual accounts and
reconciliation statement of tax already paid and tax payable as
per audited accounts along with GSTR 9C.
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4. Due date of GSTR- 9
 GSTR-9 due date is on or before 31st December of the subsequent
Year
 Latest Update as on 22nd December 2018: 31st GST
Council meeting held on 22nd December 2018
recommended further extension for filing GSTR-9,GSTR-
9A and GSTR-9C upto 30th June 2019. Also, certain
changes were called for in the form GSTR-9 and GSTR-9C.
The Last date is therefore is 30-06-2019.
 Penalty for the late filing of GSTR-9 form? Late fees for not
filing the GSTR 9 within the due date is Rs. 100 per day per act
up to a maximum of an amount calculated at a quarter percent
of the taxpayer turnover in the state or union territory. Thus it
is Rs 100 under CGST & 100 under SGST, the total penalty is Rs
200 per day of default. There is no late fee on IGST.
4CA.N.RAMASWAMY

5. Simplification of Form GSTR-9 & GSTR-9C
HSN code may be declared only for those inward supplies
whose value independently accounts for 10% or more of the
total value of inward supplies.
If any additional payments are to be made they can be done
through the FORM GST DRC-03 in cash.
ITC cannot be availed through FORM GSTR-9 and FORM
GSTR-9C.
Verification by a taxpayer who is uploading the reconciliation
statement would also be included in FORM GSTR-9C
All monthly/quarterly GST Returns must be filed before
filing Annual returns
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6. Simplification of Form GSTR-9- contd,.
Outward or Inward supplies to be declared in the Annual
returns to be ‘supplies made during the financial year’ and
not ‘supplies, as declared in GST returns filed’
Value of ‘No Supply’ can be declared under Exempt supplies
section at Table 5D, 5E or 5F of GSTR-9
In GSTR-9, Table 8A-ITC as per GSTR-2A – auto-populates
all invoices related to FY 2017-18 irrespective of the month of
filing GSTR-1 by suppliers
The due date for filing of GST Annual Return (GSTR-9)
and Reconciliation statement ( GSTR-9C) after GST
Audit is e extended till 30th June 2019.
Annual return once filed can not be revised.Annual return once filed can not be revised.
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7. The details required in the GSTR-9 form
Sr No Parts of the GSTR-9 Parts of the GSTR-9
1 PART – I Basic details of the taxpayer. This detail will be
auto-populated.
2
PART - II
Details of Outward and Inward supplies
declared during the financial year(FY). This
detail must be picked up by consolidating
summary from all GST returns filed in
previous FY.
3
PART III
Details of ITC declared in returns filed during
the FY. This will be summarised values picked
up from all the GST returns filed in previous
FY.
4
PART IV
Details of tax paid as declared in returns filed
during the FY.
7CA.N.RAMASWAMY

8. The details required in the GSTR-9 form
Sr No Parts of the
GSTR-9
Parts of the GSTR-9
5 PART – V Particulars of the transactions for the previous FY
declared in returns of April to September of current FY
or up to the date of filing of annual returns of previous
FY whichever is earlier. Usually, the summary of
amendment or omission entries belonging to previous
FY but reported in Current FY would be segregated and
declared here..
6
PART - VI
Other Information comprising details of:-GST
Demands and refunds, -HSN wise summary
the quantity of goods supplied and received with its
corresponding Tax details against each HSN code,-Late
fees payable and paid details and -Segregation of
inward supplies received from different categories of
taxpayers like Composition dealers, deemed supply
and goods supplied on approval basis. 8CA.N.RAMASWAMY

9. FAQs on GSTR-9
Sr No QUESTION ANSWERS
1 Is it mandatory to
file Form GSTR-9?
Yes, it’s mandatory to file Form GSTR-9 for normal
taxpayers
2 Can tax payyer
revise the GSTR-9
which has been
filed?
No. Currently, GSTR-9 does not allow for any
revision after filing
3 The tax payer got
my registration
cancelled in the
financial year say
FY 2017-18. Am I
file GSTR 9?
Yes, the annual return needs to be filed even if the
taxpayer has got his registration cancelled during the
said financial year.
9CA.N.RAMASWAMY

10. FAQs on GSTR-9
Sr No QUESTION ANSWERS
4 Whether form
GSTR-9 return
is required to
be filed at the
entity level or
GSTIN level?
Form GSTR-9 return is required to be filed at
GSTIN level i.e. for each registration. If taxpayer
has obtained multiple GST registrations, under the
same PAN, whether in the same State or different
States, he/she is required to file annual return for
each registration separately
5 Matching input
GST with 2A
before filing
GSTR9 required
Yes, you must reconcile GSTR-2A for FY 2017-18
data with the input tax credit accounted in your
books of accounts till March 2019 for FY 2017-18
data before filing GSTR-9.
6 From where can
a taxpayer file
Form GSTR-9?
Navigate to Services > Returns > Annual Return
to file Form GSTR-9.
10e CA.N.RAMASWAMY

11. FAQs on GSTR-9
Sr No QUESTION ANSWERS
7 Which tables in
Form GSTR-9
has auto-
populated data
from filed Form
GSTR-1 & GSTR-
3B?
Below tables in Form GSTR-9 has auto-populated
data, from already filed Form GSTR-1 and Form
GSTR-3B of the relevant financial year:
4. Details of advances, inward and outward supplies
made during the financial year on which tax is
payable
5. Details of Outward supplies made during the financial
year on which tax is not payable
6A Total amount of input tax credit availed through
FORM GSTR-3B (sum total of Table 4A of FORM
GSTR-3B)
6G- Input Tax credit received from ISD
6K- Transition Credit through TRAN-I (including
revisions if any)
6L- Transition Credit through TRAN-II
9. Details of tax paid as declared in returns filed
during the financial year
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12. FAQs on GSTR-9
Sr No QUESTION ANSWERS
8 Can a tax payer
file nil Form
GSTR-9?
Nil Form GSTR-9 can be filed for the Financial year, if
you have: -
NOT made any outward supply (commonly known as
sale); AND
NOT received any goods/services (commonly known
as purchase); AND
NO other liability to report; AND
NOT claimed any credit; AND
NOT claimed any refund; AND
NOT received any order creating demand; AND
There is no late fee to be paid etc.
12CA.N.RAMASWAMY

13. FAQs on GSTR-9
Sr No QUESTION ANSWERS
9 Does a PERSON
need to provide
details in all the
tables
You are required to provide/ update details only in
those tables which are relevant to your business.
10 Is there any
Offline Tool for
filing Form
GSTR-9?
Currently, Form GSTR-9 return can be filed through
online mode only. However, offline tool for Form
GSTR-9 will be released shortly. In fact Off line tool is
available on the portal.
11 Which table in
GSTR-9 has auto-
populated data
from Form
GSTR-2A?
Form GSTR-9 has auto-populated data, from Form
GSTR-2A of the relevant financial year:
Table no. 8A: ITC as per GSTR-2A (Table 3 & 5
thereof)
13CA.N.RAMASWAMY

14. FAQs on GSTR-9
Sr No QUESTION ANSWERS
12 Can Tax payer
edit auto-
populated data
from filedGSTR-1
& GSTR-3B in
Form GSTR-9?
Yes, you can edit auto-populated data from filed
Form GSTR-1 and GSTR-3B in Form GSTR-9, except
data in below mentioned tables:
Table no. 6A: Total amount of input tax credit
availed through FORM GSTR-3B (sum total of Table
4A of FORM GSTR-3B)
Table no. 8A: ITC as per GSTR-2A (Table 3 & 5
thereof)
Table no. 9: Details of tax paid as declared in returns
filed for the financial year (Except tax payable
column)
13 Is there any late
fee for late filing
of Form GSTR-9?
Yes, there is a late fee for filing of Form GSTR-9 beyond
the due date.
14
CA.N.RAMASWAMY

15. FAQs on GSTR-9
Sr No QUESTION ANSWERS
14 When "Late fee
payable and paid"
tile in Form
GSTR-9 gets
enabled?
Once the status of Form GSTR-9 is Ready to File and
liabilities are calculated, Late fee payable and paid
tile gets enabled for filing of Form GSTR-9 by the
taxpayer.
15 when filed late,
can GSTR-9 be
filed without
paying late fee ?
No. Tax payer cannot file Form GSTR-9 without payment of
late fee for Form GSTR-9, if same is filed after the due date.
16 Is there any
option to make
payment other
than late fee in
Form GSTR-9?
After filing return in Form GSTR-9, tax payer will get a link
to navigate to Form GST DRC-03 to pay tax, if any. Any
additional payment can be made using Form GST DRC-3
functionality only through utilization from Electronic Cash
Ledger.
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16. FAQs on GSTR-9
Sr No QUESTION ANSWERS
16 Can additional
liability not
reported earlier in
GSTR 3B be
declared in form
GSTR-9,
Yes, additional liability not reported earlier at the
time of filing Form GSTR-3B can be declared in Form
GSTR-9. The additional liability so declared are
required to be paid through Form GST DRC-03.
17 Can a tax payer
claim any
unclaimed ITC
through Annual
Return?
No. A tax payer cannot claim ITC through Form GSTR-9.
18 Whether GSTR-9
return be
revised
No, Tax payer cannot revise Form GSTR-9 return after filing
16CA.N.RAMASWAMY

17. An attempt has been made to bring out essential aspects relating
to filing of annual return under GST taking clues from different
sources.
Being first return lots of care need to be taken especially when
revision of annual return once filed , can not be made.
As this is a summary return of all the returns filed during the
financial year , it is necessary to cross check the amount declared
with reference to financials to take a call regarding the omissions
& commissions.
Most of the tax payers would have completed these process and
would be ready to file these returns hopefully before the due dates
to avoid penal provisions.
The presentation is suggestive and can not be considered as law.
17CA.N.RAMASWAMY

18. THANKING YOU.
CACA N.RAMASWAMY, F.C.A.N.RAMASWAMY, F.C.A.
CHENNAI- 600024CHENNAI- 600024
PH- 04424732130PH- 04424732130
MOBILE: 9840446412MOBILE: 9840446412
18CA.N.RAMASWAMY