GSTR 9C Audit Checklist - Points to be verified while conducting an audit

CA Kushwanth AVSR | Last updated: 03 October 2020

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Quick Summary

The GSTR 9C audit form is an annual requirement for specific taxpayers, needing digital signature by a qualified accountant. Key verification steps include reconciling various GST returns (GSTR 3B, 1, 9) and company books, checking for timely interest payments on delayed filings, and ensuring ineligible input tax credit (ITC) isn't claimed. Auditors must also verify adherence to rules for common input, reversal of ITC on exempted supplies, and correct payment of reverse charges, including specific provisions for FY 2017-18.

GSTR 9C is an audit form that has to be filed by specified taxpayers annually in GST. This form has to be digitally signed by either a Chartered Accountant or a Cost Accountant. While doing the GSTR 9C audit, the following points have to be verified:

GSTR 9C Audit Checklist: Key Verification Points

Reconciling GSTR 3B vs. GSTR 1 vs. GSTR 9 vs. Books
Reconciling GSTR 3B vs. GSTR 2A vs. GSTR 9 vs. Books
Is there any delay in filing GSTR 3B.? If yes, whether interest paid or not.?
Whether the taxpayer claimed any ineligible credit.?
In the case of common input, whether Rule 42 and 43 are followed or not.?
In case the taxpayer is supplying exempted goods, then whether ITC on purchase of goods or services for such supply was reversed or not
In the case of FY 2017-18, whether the reverse charge was paid till 13-10-2017 under section 9(4) or not
Is there any reverse charge invoice in GSTR 2A(besides this, books also to be verified to know whether any supply was there on which GST has to be paid under reverse charge) and whether the taxpayer had paid the same or not
In case of any mistake in GST returns, whether the same are rectified by amendment or not.? If rectified, then in which month and scope of interest on the same
Is there any other income in income tax return other than those specified in GST returns.? If yes, then taxability of such income in GST
Is there any demand raised against the taxpayer.? If yes, then whether the same was solved or still pending and the effect of such order on GST returns
Is there any consideration received for the disposal of business assets.? If yes, then the taxability of such supply else then the applicability of schedule I.
Whether any advances received? If yes and if the intended supply is service, then taxability of such advance. In case, GST was paid in the month of service provided then interest in delay between the months of advance received and GST paid.
Verifying the valuation rules wherever applicable

These are a few points that are to be verified while doing an audit in GST.

FAQ :

GSTR 9C is an annual audit form that must be filed by specified taxpayers under the GST regime, requiring digital signature by a Chartered Accountant or Cost Accountant.

The audit involves reconciling GSTR 3B, GSTR 1, GSTR 9, and company books, as well as GSTR 3B, GSTR 2A, GSTR 9, and company books.

Auditors must verify if any ineligible credit has been claimed and ensure that ITC on purchases for exempted goods or services has been reversed. For common input, adherence to Rules 42 and 43 is also checked.

The audit checks if reverse charges were paid correctly, including specific requirements for FY 2017-18 (payment by 13-10-2017 under section 9(4)) and verifying reverse charge invoices in GSTR 2A against company books.

The audit examines other income declared in income tax returns for GST taxability, the resolution status of any tax demands raised against the taxpayer, and the taxability of consideration received from the disposal of business assets.

The audit verifies the taxability of advances received, particularly for services, and checks for any interest payable if GST was paid in the month of service provision rather than the month the advance was received.