GSTR-9 (ANNUAL RETURN)

Let us understand the GST
BY : CA - RAMANDEEP SINGH BHATIA
ANNUAL RETURNS : GSTR 9
ANNUAL RETURNS :
GSTR 9

LEGAL PROVIOSNS
 Sec 44(1) requires every registered person furnish an
annual return for every financialyear electronically
 Not Applicable for
• Input Service Distributor,
• a person paying tax under section 51 or section 52,
• a casual taxable person and
• a non-resident taxable person

APPLICABILITY OF ANNUAL RETURN –IN GLANCE
Annual Return
Registered Person:
Rule 80(1)
GSTR9
Composition Dealer
: Rule 80(1)
GSTR 9A
TCS : Rule80(2)
GSTR 9B
Audit TO > 2 crores
: : Rule 80(3)
+ GSTR9C
Excludes
ISD /TDS
CTP/NRTP

SOME CRUCIAL ASPECTS –ANNUAL RETURN
 Period Coverage : 1st July 2017 to 31st March 2018
 Time Lines : 31st Dec 2018 for FY17-18
 Late Filing Fees : Rs. 100/- per day per Act (CGST +
SGST/UTGST), subject to a maximum amount of (0.25% CGST
+ 0.25% SGST/UTGST) of the turnover in the State.
 Notice for Non filer : Sec 46 read with Rule 68, A notice in
FORM GSTR-3A shall be issued with in fifteen days,
electronically, to a registered person who fails to furnishreturn
under section 44.

SOME CRUCIAL ASPECTS –ANNUAL RETURN
 Thresh hold Limit : All Registered Tax payers even if the turnover
is NIL shallfile.
 PAN / GSTIN : This is not an Entity Level reporting, its GSTIN
based filing.
 Source of Information : Circular 26/2017 clarifies how to correct
information in returns based on the books. Presuming Returns are
corrected, information furnished in GSTR 3B to be reported, along
with information furnished in GSTR 1 may be considered for
reporting various information in sub Tables.

6 IMPORTANT PARTS of GSTR-9 (Annual
Return)

BASIC DETAILS
 Year v. Financial year for GST audit
 GSTIN validation, duplication and correction
 Legal name v. Trade name v. Brand name

PART II: DETAILS OF OUTWARD SUPPLIES
Part II
Transactions havingTax
Implications
Table 4
Transactions not having tax
implications
Table 5

PART II: DETAILS OF OUTWARD SUPPLIES

OUTWARD AND INWARD SUPPLIES
 Source of data; errors of omission-commission
 Reference to tables in GSTR 1; GIGO data
 Invoice value v. Taxable value (abatement)
 Declared ‘for’2017-18 ‘in’returns filed (belated)

Table 4A, 4C
Table 6A
Table6B
Table 6C
Table 5, 7 and 9, 10
• Outward supplies at not only sales but allcredits
• Supplies actually reported in 2018-19 ‘for’2017-18
• Supplies reported ‘as if’ relating to 2018-19stays
• ‘Date-of-doc’ relevant but not amendment orCN-DN

• Outward supplies at not only sales but allcredits
• Supplies actually reported in 2018-19 ‘for’2017-18
• Supplies reported ‘as if’ relating to 2018-19stays
• ‘Date-of-doc’ relevant but not amendment orCN-DN
• NN 40/17/CT -13/10 & NN 66/17/CT-11/11
Table 11A
Table 4B / Table 3.1(d)

• Date-of-doc’ relevant and related to 4B to4E
• ‘Doc-type’ relevant whether s.34 allows ornot
• CN-DN issued ‘in’ 2017-18 not ‘for’ 2017-18
• Consider supply invoice ‘amended through’DN-CN
• Include CN-DN under 142(2) but exclude if tax-unpaid

Table 9A and9C
Table 9A and9C
• Omission-commission (B2C) already reported(4A)
• Omission-commission (B2B) now reported (4BCDE-IJ)
• Omission-commission ‘for’ 2017-18 but ‘in’ 2018-19
• Invoice-CN-DN-Refund Voucher ‘for’ 2017-18 only

TABLE- 5 – SUPPLIES _NO TAX PAYMENT
Table 6A
Table 6B
Table 4B
• Exports (goods or services) declared as ‘nottaxable’
• Export with-IGST payment already reported(4C-D)
• Review of ‘export conditions’ not to affect reporting
• Outward supplies ‘push’ to counter-partyreported

• All kinds of ‘un-taxed’ supplies to be actuallyreported
• All ‘no supply’ transactions to be reported
• Report credits in expenditure-asset-liabilityaccounts
• **Report omissions up to Oct 31, 2018, no taxeffect
• Ensure ‘complete’ transparency of transactions
Table 8

• Ensure no overlap with 4IJKL
• Supplies ‘with-tax’ in 4IJKL and ‘without-tax’ in5HIJK
• ‘Date-of-doc’ relevant whether S.34 allows ornot
• Amendment or first-time reporting to be considered
Table 9B

• Total turnover very important for reconciliation in 9C
• Taxable PLUS non-taxable turnover ‘for’ 2017-18
• Turnover in 5N may not match with turnover inbooks
• All ‘errors’ remain, time to rectify ends Oct 31,2018
Table 5Q in
GSTR 9C

PART-III ITC DECLARED IN RETURN FILED
Input Tax
Credits
Table 6
ITC Declared as
per 3B
Table 7
ITC Reversed as
per 3B
Table 8
Reconciliation with
2A

TABLE-4 (ITC SECTION) –GSTR-3B
4 (A) ITC Available (whether in
full or part)
(1) Import of Goods
(2) Import of Services
(3)Inward supplies liable to reverse
charge (other than 1 & 2 above)
(4) Inward supplies from ISD
(5) All other ITC
4 (B) ITC Reversed
(1) As per rules 42 & 43 of CGST Rules
(2) Others
4 (C) Net ITC Available (A) –
(B) 4 (D) Ineligible ITC
(1) As per section 17(5)
(2) Others

TABLE-6 ITC AT GLANCE
Classification of Credits GSTR 9
Input Tax Credit Goods Services
Domestic Inward Supplies 6B* 6B
Imports 6E* 6F
Inward Supplies from SEZ
- Bill of Entry filed by Recipient 6E* 6B
- Bill of Entry filed by SEZ 6B* NA
Paid under RCM – Registered Supplier 6D* 6D
Paid under RCM – Unregistered Supplier 6C* 6C
Composition Dealer Not Applicable Not Applicable
Input Service Distributor Not Applicable 6G
* Tobe bifurcated into Capital Goods and Inputs

TABLE-6 ITC
Table 4A
Table 4A(5)
• Credit flows from GSTR 3B (as claimedactually)
• Credit ‘for’ 2017-18 is not based on ‘date’ of invoice
• GSTR 3B is ‘consolidated’ amount not ‘invoice-wise’
• Credit ‘for’ 2017-18 is based on ‘month’ of GSTR3B

TABLE-6 ITC
Table
4A(3)
Table
4A(1)
Table
4A(2)
• RCM-credits ‘for’ 2017-18 claimed in GSTR3B
• RCM transactions taxed as FWC not reported here
• Errors in GSTR 3B rectified in 2018-19 notcounted

TABLE-6 ITC
• Again FWC credits reported; 6H also FWCcredit
• Difference cannot be ‘negative’ value (I – A, not A – I)
• Difference is ‘positive’ indicates ‘excess’ claim in 3B
• Difference must be ‘nil’ (ideally)
• Repeat above credit details forCGST-SGST-IGST-Cess
Table 4A(4)
Rule -37 & Refund Rejected Re
Credited

TABLE-6 ITC
• Special case of credit flow only to CGST or onlySGST:
– TRAN1-2 credit flow into ECL after revision (up/down)
– Stock-on-hand credit when newly taxable (Rule 40) ITC 01
– Transfer of credit with PAN change (Rule 41) ITC-02
Actual balance as reflected
in Electronic Credit
Ledger
Rule 40 stock-on-hand and
Rule 41 transfer of credit

TABLE-7 DETAILS OF REVERSED AND INELIGIBLE
Table Description Reference
7A
As per Rule 37 Section 16(2) – payment to supplier not made –
180 days
7B
As per Rule 39 ISD – apportioned is in negative because of CR Noteby
the ISD
7C
As per Rule 42
Proportionate reversal of credit on common input
tax and other than business purpose input tax
(D1+D2)
7D
As per Rule 43 Proportionate reversal of credit on common
Capital Goods
7E As per section 17(5)
Blocked Credits
7G
Reversal of TRAN-I credit
Ineligible credits reversed
7H Reversal of TRAN-II credit
Ineligible credits reversed

TABLE-7 DETAILS OF REVERSED AND INELIGIBLE
Table 4(B)
ITC 03
• Ensure reversal true-up after year-endreview
• Ensure 7E is ‘nil’ to avoid ‘double counting’ or tothe extent included in reversal
• TRAN1-2 reversal, ensure only admittedreversal

TABLE-8 OTHER ITC RELATED INFORMATION
• Tax ‘admitted’ by counter-party flows to GSTR 2A
• Credit from invoices-on-hand claimed in 6B
• If there’s mismatch, consider:
– 2A > 6B, see if all credits are availed (directly reported)
– 2A < 6B, expect inquiry keep alternative confirmation ready
– 2A > 6B, credit availed in 2018-19 (choice of year)

TABLE-8 OTHER ITC RELATED INFORMATION
Table 4(A)(5)
• Credit ‘to be’ lapsed not automatic, ensure it is‘nil’ , - 8D can trigger inquiry; maintain
detailedinformation , - Bill of Entry filed by Registered Person

PART- IV TABLE-9 – TAX PAID _GSTR3B RETURN
Table 6.1
• Details of tax paid as declared in returns filedduring the financial year i.e Actual ‘tax paid’ data from3B

PART- V PREVIOUS TRANSACTION (APRIL-SEPTEMBER 18)
• ‘Date-of-doc’ relevant even if reportedbelatedly
• ‘Return-for-month’ relevant even if filed belatedly
• ‘Date-of-filing’ by Oct 31, 2018 (GSTR 1)
• Included ‘as if’ belongs to2018-19:
– Not to be considered in 10 to 13 of GSTR 9
– But considered in GSTR 9C as unreconciled difference

Table 9A, 9B and
9C
Table 4(B)
Table 4(A)
• Follow ‘date-of-doc’ and report ‘new’ / ‘amendment’ declared ‘in’ 2018-19 (avoid
double-counting)
• Credit cannot ‘belong’ to both years (choice ofyear):
– Check conditions of s.16(2)
– Compared with Table 8C
– Exclude ‘accrued but not due’ during/in 2017-18

14 Differential tax paid on account of declaration in 10 & 11above
Description Payable Paid
1 2 3
Integrated Tax
Central Tax
State/UT Tax
Cess
Interest
• Calculate ‘admitted’ tax-payable on 10 and 11
• Report ‘if’ tax-paid within Apr-Sept
• Ensure no double-counting of liability andpayment
• Tax ‘unpaid’ can also be reported here

PART- VI T-15 OTHER INFORMATION
Refunds
Claimed
Table 15A
Sanctioned
Table 15B
Rejected
Table 15C
Pending
Table 15D

Table 5
• Provide factual data and if details not available, stateit
• Tracker for goods sent to job-worker (not transition 141)
• Section 31(7) – 6 Months – Goods Sent on Approval
• Information only; no tax to be paid

• HSN summary of ‘outward’ supplies required
• Match with 5N + 10 + 11
• Prepare such summary for non-monetary/sch I supplies
• Identify limitations in data collection
Table 12

• GSTR 9 attracts late fee; Rs.100+Rs.100,cap 0.25%+0.25%
• Single GSTR 9 for CGST-SGST, IGST and Cess
• GSTR 9 can be filed with ‘unpaid’ late feealso

VERIFICATION
• No ‘text’ space allowed for ‘limitations’disclosure

It may be noted that nothing contained in this publication should be regarded
as our opinion and facts of each case will need to be analysed to ascertain
applicability or otherwise of the topics covered in this publication. Appropriate
professional advice should be sought for applicability of legal provisions based
on specific facts. We are not responsible for any liability arising from any
statements or errors contained in this publication.
CA RAMANDEEP SINGH BHATIA
National Empanelled Faculty for GST IDTC New Delhi
Faculty National Academy of Customs & Indirect Tax & Narcotics (NACIN)
FCA, DISA, B.COM , CS. (EXE), CERT. IFRS, CERT. IDT, CERT. CBA
caramandeep.bhatia@gmail.com
facebook.com/ca.ramandeepbhatia
Twitter.com/@caramandeep

GSTR-9 (ANNUAL RETURN)

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