GSTR-9 and 9C- Aspects that need clarification

As we all now the due date for filing GST Annual Return and GSTR-9C is 30.09.2020. But still there is no clarification regarding the manner of presenting details in the respecitve returns

1. SALES

As far as sales are concerned there can be two views

As per BOA:

If we present sales as per BOA in Table 4 of GSTR-9, then we may end up in either of the two different scenarios

1. If we state the adjustments made during the next financial year in Table No :- 10 and 11 respectively then it may end up creating unreconciled turnover in GSTR-9C since it compares audited Turnover with the turnover stated in GSTR-9 including the adjustments stated in Table 10 and 11

2. If we don't state the adjustments made during the next financial year in table no 10 and 11 then it may result in misrepresentation of information in GSTR-9. However the said approach may result in reconciled turnover in GSTR-9C

As per 3B: 

If we present the turnover details as per 3B in Table 4 of GSTR-9, then there is a possibility that it may include the figures of adjustments of F.Y. 17-18 made in F.Y. 18-19 and since there is no separate space till date where we can remove the effect of the said adjustments we may end up getting unreconciled turnover in GSTR-9C

Prudent Approach: 

The most prudent approach in such a case would be to state the turnover as per 3B EXCLUDING THE ADJUSTMENTS OF F.Y. 17-18,IF ANY MADE IN RETURNS OF F.Y. 18-19 in order to get the turnover reconciled at all places 

Also if we present the details in above stated manner and state the tax payable in table no 9 of gstr-9 as stated above the difference in tax payable and paid will automatically reflect the adjustments of F.Y.17-18 made in F.Y. 18-19 and it can serve as a basis for the same. 

2. ITC

As far as ITC is concerned there can be two views

As per BOA:

If we present ITC as per BOA in Table 6 of GSTR-9 ,then we may end up in either of the two different scenarios

1. If we state the adjustments made during the next financial year in Table No :- 12 and 13 respectively then it may end up creating unreconciled ITC in GSTR-9C since it compares ITC as per audited BOA with the ITC stated in GSTR-9 including the adjustments stated in Table 12 and 13

2. If we don't state the adjustments made during the next financial year in table no 12 and 13 then it may result in misrepresentation of information in GSTR-9. However, the said approach may result in reconciled ITC in GSTR-9C

As per 3B: 

If we present the turnover details as per 3B in Table 4 of GSTR-9, then there is a possibility that it may include the figures of adjustments of F.Y. 17-18 made in F.Y. 18-19 and since there is no separate space till date where we can remove the effect of the said adjustments we may end up getting stating more or less ITC in GSTR-9 if any sort of previous year adjustment was made. But since GSTR-9C provides separate space where we can provide details regarding previous year adjustments, we may end up getting reconciled ITC in GSTR-9C.

Hence the prudent approach would be to state the details as per 3B