It is surprising that even as on date 2nd wekk of June 2019 (with just 18 days left) - the urgency to upload the GST Annual Return & get audit conducted well in time is not being felt across India. We understand that there are many instances where the auto populated annual return without reconciliations and verification are being uploaded!!
Maybe more than 10 lakhs liable to audit may face adverse results if not filed or not filed accurately and properly.
It is advisable to pay the penalty for late filing than to file inaccurately due to the following reasons:
- This would be the opportunity to rectify the errors and mistakes. Save interest and mandatory penalty.
- We understand that more than 10 lakhs of notices would be issued after the due date of the audit. These could be are mainly variances in the enormous data available with the tax administrators and use of Information technology linking to income tax returns, RTO, e- way bill, toll, form 9 of vendor/ customer:
- Prevent and rectify the same errors for 18-19 till date. Again save interest & penalty.
- Limit the demand to 3 years . Avoid the demands for 5 years ( upto 2024) for bona fide mistakes and errors.
- Annual return once uploaded cannot be revised. If rectified at that stage ideal. If in 9C possibility of search, investigation, revenue audit….
- Many more…
There are value addition possible also as under:
- Pass on the burden to the customer who can avail the ITC now before books are closed.
- Possibly the last opportunity to be able to utilise ITC for missed liabilities of 17-18 due to the fact that this is a self assessment. Net outgo would be less. [ portal is not disabling- does it mean tactic confirmation of this view? ]
- Avoid payment to vendors who are non compliant- early correction good for both vendor + customer.
- Mismatch between 2A and Books. Get vendor to rectify, Show the difference and keep documentation to prove receipt etc.
For professionals who do their jobs properly and take due care there are several benefits:
- Establish their value to the clients who may not be aware of the non compliances and the attendant costs. It is our belief that the cost of compliance would be much less than the cost of resolving mistakes and possible litigation which is very much possible Opportunity to be part of the nation building process by ensuring missed taxes paid. Build the credibility and not complain later on not being given respect by all stakeholders.
- Establish that the 9C reports are relied on and the credibility with tax administrators is enhanced substantially.
- By preventing disputes in future in the longer term the client trust & loyalty would be intact.
- Establish that CAs are though leaders in professional audit services.[ not only Mandatory but the internal audit/ review audits, return filing with verification]
Team Hiregange has prepared a booklet on Annual Return updated upto 11th June 2019. It contains the following:
Chapter 1: Brief introduction
Chapter 2: Column by column understanding
Chapter 3: Approach for preparation and checklist
Chapter 4: FAQs
For those who wish to use the booklet the link is provided as under.
Please find below link: