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GST - Impact of Clarifications Issued on GSTR-9 & 9C

CA Nikhil Jhanwar 
on 12 October 2020

LinkedIn


Ministry of Finance issued a Press Release on 9th Oct, 20 issuing certain clarifications while filing GSTR-9 & 9C for F.Y. 2018-19.

Currently, the taxpayers are facing issues in GSTR-9 in reporting transactions pertaining to F.Y. 2017-18 which was reported in GST returns of 2018-19 as there is no specific column for the same. Such values were already reported in GSTR-9 of F.Y. 2017-18 in Tables 10 to Table 14.

To address this issue, the Government has clarified as under in respect of reporting of values in Table 4,5,6& 7 of GSTR-9:

In this regard, it is clarified that the taxpayers are required to report only the values pertaining to Financial Year 2018-19 and the values pertaining to Financial Year 2017-18 which may have already been reported or adjusted are to be ignored. No adverse view would be taken in cases where there are variations in returns for taxpayers who have already filed their GSTR-9 of Financial Year 2018-19 by including the details of supplies and ITC pertaining to Financial Year 2017-18 in the Annual return for FY 2018-19.

Accordingly, the Outward liability or Input tax credit pertaining to F.Y. 2017-18 reported in GST returns of F.Y. 2018-19 would be excluded from respective Tables 4,5,6 & 7. If the transactions are reported in accordance with the Press Release, still there will be some unresolved issues which are explained in our attached Note (explained with example).

GST - Impact of Clarifications Issued on GSTR-9 and 9C

A. Outward Liability- Difference in Table 9 (Tax Payable vs. Tax paid)

Particulars

GSTR-3B

Table 4 of GSTR-9

(Taxable Outward Supplies)

Table 9

(Tax Payable)

Table 9

(Tax Paid as per GSTR-3B)

IGST for F.Y. 2018-19

1500

1500

1500

1800

IGST liability for F.Y. 2017-18 reported in GSTR-3B of F.Y. 2018-19 (also reported in Table 10 of GSTR-9 of F.Y. 2017-18)

300

Not required to be reported as per press Release

-

Total

1800

1500

1500

1800

Difference

-300

The above difference is not apparent on the fact of GSTR-9 but a crucial exercise to undertake to reconcile transactions as per books of accounts vs. GST returns. The above difference can either be positive or negative depending on the nature of adjustments done in GSTR-3B of F.Y. 2018-19 in respect of transactions of F.Y. 2017-18 i.e. either additions or reduction in output liability.

B. Input Tax Credit(Difference in Table 6J)

Particulars

Table 6A of GSTR-9

(Auto-populated)

Table 6I

(Total ITC availed)

Table 6J

(6I -6A)

ITC for F.Y. 2018-19

1000

1000

ITC for F.Y. 2017-18 reported in GSTR-3B of F.Y. 2018-19 (also reported in Table 13 of GSTR-9 of F.Y. 2017-18)

200

-

Total

1200

1000

-200

 

Ideally, there should not be any difference arising in Table 6J as per the design of GSTR-9. However, due to the spillover effects of transactions of F.Y. 2017-18 reported in GST returns of F.Y. 2018-19, there could be a difference coming in Table 6J which may need to be explained suitably to the Department.

Similarly, the ITC reversal amount to be disclosed in Table 7 of GSTR-9 will not include reversals pertaining to F.Y. 2017-18 if we go by Press Release.

C. Table 12B of GSTR-9C becoming redundant.

The above treatment of non-reporting of ITC pertaining to F.Y. 2017-18 in GSTR-9 of F.Y. 2018-19 will reduce the Net ITC available for utilization as appearing in Table 7J. The data from Table 7J will flow to Table 12E of GSTR-9C. Since Table 7J does not have any spill-over ITC of F.Y. 2017-18, then no amount is required to be reported in Table 12B of GSTR-9C- ITC booked in earlier Financial Years claimed in the current Financial Year which is added in Table 12A to reconcile with total ITC claimed in GSTR-9. In our opinion, Table 6 of GSTR-9 is appropriately designed to disclose details of ITC claimed in GSTR-3B irrespective of the period to which it pertains. The same is also in complete sync with Table 12 of GSTR-9C. However, non-reporting of ITC pertaining to F.Y. 2017-18 in GSTR-9 of F.Y. 2018-19 will make Table 12B redundant.

 

Disclaimer: The information in this document is for educational purposes only and nothing conveyed or provided should be considered as legal, accounting, or tax advice.


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