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Applicability of GSTR-9 Annual Return

CA Umesh Sharma , Last updated: 27 May 2019  
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Arjuna (Fictional Character): Krishna, After the end of Financial Year, everywhere there is discussion in relation to annual return of F.Y 2017-18. What is it?

Krishna (Fictional Character): Arjuna, GSTR 9 is an annual return which needs to be filed by the registered persons once in a year. It consists of details regarding the supplies made and received during the year i.e it is a consolidation of the information furnished in the monthly or quarterly returns during the year.

Arjuna: Krishna, Who is required to file GSTR-9? Is it compulsory to file annual return?

Krishna: Arjuna, Yes, every registered person should file GSTR-9.

Arjuna: Krishna, Are there any exceptions to it?

Krishna: Arjuna, every registered person shall be required to file GSTR-9. However, the following persons are not required to file GSTR 9:

  • an Input Service Distributor,  
  • a casual taxable person and 
  • a non-resident taxable person.
  • a person paying tax under section 51 (TDS) or section 52 (TCS), 
  • Person paying tax under section 52 (TCS) is required to file GSTR-9B but since, provision of section 52 is applicable from 01st October 2018 only, they are not required to file GSTR-9B for the year 2017-18.
  • Also it must be noted that taxpayers opting Composition scheme as they must file GSTR-9A

Arjuna: Krishna, What are the details required in the GSTR-9 form?

Krishna : Arjuna, GSTR-9 is divided into 6 parts and 19 tables:

Part I: This part asks for basic details, such as the financial year, GSTIN, legal and trade names. Details will be auto-populated in the form.

Part II: This is part where taxpayer is to provide details of outward and inward supplies declared during Financial Year (FY).  The details can be picked up by consolidating summary from all GST returns filed in previous FY.

Part III:  In this part taxpayers will provide details of the Input Tax Credit (ITC) as declared in returns filed during the financial year. Also in this details of the ITC reversed and ineligible ITC as declared in individual returns.

Part IV: Here, taxpayers will provide details of taxes paid as declared in returns filed previously during the fiscal year.

Part V: The summary of amendment or omission entries belonging to previous FY but reported in Current FY would be segregated and declared in this part.

Part VI: Taxpayers will here report other information like Demand and refund details, Supplies received from composition taxpayers, deemed supply goods sent on approval basis; HSN-wise summary of outward and inward supplies; Late fees payable as well as those paid.

Arjuna: Krishna, Whether a Taxpayer shall be required to file GSTR-9 even though his registration has been cancelled before 31st March 2018?

Krishna: Arjuna, Yes, the annual return needs to be filed even if the taxpayer has got his registration cancelled during the said financial year.

Arjuna: Krishna, What is the due date to file GSTR-9?

Krishna: Arjuna, the due date for filing GSTR 9 is 30th June 2019.

Arjuna: Krishna, What if taxpayer do not file of GSTR-9?

Krishna: Arjuna, Late fees need to be paid for non-filing of GSTR 9 within the due date. This amount shall be maximum of the following:

  1. 2.5% of the taxpayer turnover in the state or union territory or,
  2. Rs 100 for CGST and SGST per day.

 Arjuna: Krishna, What one should learn from this?

Krishna: Arjuna, This annual return shall be the first annual return since the implementation of GST. Being the first time taxpayers should take care. Annual return is mere summation of all the returns already filed in which ITC amount claimed cannot be changed. But if additional liability arises it needs to be paid before filing return.

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CA Umesh Sharma
(Partner)
Category GST   Report

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