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Parts of GSTR 9C:

  • Part A - Reconciliation Statement ( This contains 5 Parts-From I to V)
  • Part B - Certificate

Part A - Reconciliation Statement

Part I- Basic Details (SI No: 1 to 4)

  • Financial Year(FY),GSTIN, Legal Name, Trade Name, Liability to audit under any Acts
  • FY means from 01.07.2017 to 31.03.2018. Turnover for this period shall be taken for threshold limit of 2 crores.

Part II- Reconciliation of Turnover in Financial Statements with GSTR 9 (SI No: 5 to 8)

SI No.5: Reconciliation of Gross Turnover

GSTR 9C form filing with easy-to-understand notes

SI No

Action

Description

5A


Turnover(including Exports) as per Financial Statements (here after referred as 'FS')

  • Where multiple GSTIN exist on same PAN, GSTIN wise FS are required

5B

+

Unbilled revenue at the beginning of the FY

  • Means revenue recognized in FS of earlier year, but GST is paid in current year.

5C

+

Unadjusted advances at the end of the Financial Year

  • Advance received for supply of goods before 15.11.17 & for supply of services till 31.3.18 shall be taken, if the supply is not completed as on 31.3.18.
  • Don't include for reconciliation;
  1. Advance received for supply of exempt goods or services
  2. Advance received for supply of goods on or after 15.11.17
  • Cross verify GSTR-1(including amendments in next year) with books of accounts

5D

+

Deemed Supply under Schedule I

  • Fixed assets sold/taken by proprietor/Partner where ITC was availed. Higher of tax on transaction value or unexpired ITC(Asset life: 5 years) shall be paid
  • Gift value>50,000 in a FY given to employee is considered as supply
  • Transactions between principal & agent
  • Import of service from a related person/establishment outside India

5E

-

Credit Notes issued after the end of the financial year but reflected in the annual return

  • May occur due to some error, mostly will be Nil.

5F

+

Trade Discounts accounted for in the audited FS, but are not permissible under GST

  • If the sales are shown net of discount in the FS, the discounts not allowed u/s.15(3) shall be declared here

Eg: Special discount, rebate, bonus discount.etc which are not established in terms of an agreement before the supply and not specifically linked to invoices.

5G

-

Turnover from April 2017 to June 2017

5H

-

Unbilled revenue at the end of Financial Year

5I

-

Unadjusted Advances at the beginning of the Financial Year

  • Relevant only from next year onwards

5J

+

Credit notes accounted for in the audited FS but are not permissible under GST

  • Similar to 5F

5K

-

Adjustments on account of supply of goods by SEZ units to DTA Units

  • Will be reflected in FS of SEZ unit as sales, but not considered as supply under GST(IGST levied on Bill of Entry and not reported in GSTR-1)

5L

-

Turnover for the period under composition scheme

  • See GSTR-4 & GSTR-9A

5M

+/-

Adjustments in turnover under section 15 and rules there under

  • Any tax other than GST/Compensation Cess collected in the invoices

Eg: Entertainment Tax

  • Alternate rates of tax

Eg: In case of Air travel agent, value is deemed as 5% or 18% of ticket price, but actual commission may be different.

5N

+/-

Adjustments in turnover due to foreign exchange fluctuations

  • If the forex rate used in books and GST Returns are different, the effect of the same may be disclosed here. Forex gains/losses shown as a separate line item in the P&L shall not be considered here, because the reconciliation is done with Turnover as per P&L

5O

+/-

Adjustments in turnover due to reasons not listed above

  • Eg: Turnover for period in which there was no registration

Incentive received from supplier and considered as supply under GST

Sum 5A :5O

Annual turnover after adjustments as above

  • This turnover ideally should match with GSTR-9.If there's any difference, the same should be reconciled and the reasons shall be mentioned in SI No-6

5Q


Turnover in GSTR-9

  • May be derived from SI No-5N,10 & 11 of GSTR-9

5R

5Q-5P

Un-Reconciled Turnover

  • Differences shall be shown under SI No.6(Part II) and SI No.11(Part III)

SI No.6: Reasons for un - Reconciled difference in Annual Gross Turnover

Due to non reporting in GSTR-9

SI No.7: Reconciliation of Taxable Turnover

SI No

Description

7A

Annual turnover after adjustments (from 5P above)

7B

Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover

  • Shall be reported net of Dr/Cr Notes & amendments
  • Can be derived from 5D,5E & 5F of GSTR-9

Also consider 5H,5I (Dr/Cr Notes) and 5J & 5K(amendments) of GSTR-9

7C

Zero rated supplies without payment of tax

  • Can be derived from 5A & 5B of GSTR-9 and amendments in 5J & 5K of GSTR-9

7D

Supplies on which tax is to be paid by the recipient on reverse charge basis

7E

Taxable turnover as per adjustments above (A-B-C-D)

7F

Taxable turnover as per liability declared in Annual Return (GSTR9)

  • Refer Table(4N-4G)+(10-11) in GSTR-9

7G

Un-reconciled taxable turnover (F-E)

SI No.8: Reasons for un - Reconciled difference in taxable turnover

Reasons under SI No-6 may repeat here(non reporting in GSTR-9) or reasons such as wrong treatment of exempt supply as taxable supply may be reported

Part III- Reconciliation of tax paid (SI No: 9 to 11)

SI No.9: Reconciliation of rate wise liability and amount payable thereon

SI No

Description

9A-9O

  • Taxable turnover as per SI.No-7E shall be bifurcated according to applicable rates
  • Forward & Reverse charge to be shown separately
  • Interest, late fee, penalty also to be disclosed

9P

Total amount to be paid = Sum(9A:9O)

9Q

Total amount paid as declared in Annual Return (Refer Table 9 & 14 of GSTR 9)

9R

Un-reconciled payment of amount =9Q-9P

SI No.10: Reasons for un-reconciled payment of amount

This may occur due to;

  • Non consideration of sales in GST Returns
  • Short /Excess payment of tax

SI No.11: Additional amount payable but not paid

Due to reasons specified in SI No.6, 8 and 10

Part IV- Reconciliation of Input Tax Credit (ITC) (SI No: 12 to 16)

SI No.12: Reconciliation of Net ITC

SI No

Action

Description

12A


ITC availed as per audited FS(Net of reversals)

12B

+

ITC booked in earlier FY claimed in current FY

  • Since this is 1st year, this column would be ideally zero.
  • Next year onwards, this column would be bearing the same amount of column 12C of Previous FY

12C

-

ITC booked in current FY to be claimed in subsequent FY

  • ITC of 2017-18,claimed in GSTR-3B for 2018-19
  • Value should be equal to sum of amounts reported in clause 12&13 of GSTR-9

12D


ITC availed as per audited FS =Sum(12A:12C)

12E


ITC claimed in Annual Return (Table 7J of GSTR9)

12F


Un-reconciled ITC= 12E-12D

SI No.13: Reasons for un-reconciled difference in ITC

  • Due to excess ITC claim
  • Non reversal of ITC
  • ITC booked but not availed(lapsed)

SI No.14: Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account

  • Column 14A to 14Q requires to disclose;
    • Amount of expense
    • Total ITC
    • Amount of eligible ITC availed
  • Column 14R : Total amount of eligible ITC availed=Sum(14A:14Q)
    • 14R must be equal to 12A(Since both are as per FS/books)
  • Column 14S : ITC Claimed in Annual return= Table 7J of GSTR-9
  • Column 14T : Un-reconciled ITC= 14S-14R

SI No.15: Reasons for un-reconciled difference in ITC

May be due to;

  • Reasons specified in SI No.13
  • Ineligible ITC availed
  • ITC of 2017-18 availed in GSTR-3B of 2018-19(Column 13 of GSTR-9)
  • ITC of 2017-18 reversed in GSTR-3B of 2018-19(Column 12 of GSTR-9)

SI No.16: Tax payable on un-reconciled difference in ITC (Due to reasons in column 13 &15)

Part V- Auditor's recommendation on additional tax liability due to non-reconciliation

  • Tax may be payable due to non-reconciliation of either turnover or ITC(Columns T11 & T16)
  • Rate wise breakup required
  • For ITC there is separate column
  • This is auditor's recommendation only, not legally binding on the taxpayer
  • The department will use this as a tool for their assessment purpose

Part B - Certification

  • Maintenance/non-maintenance of books of accounts as required by Act/ rules /notifications
  • Agreement of books of accounts with balance sheet, profit and loss and cash flow statement
  • Obtained necessary information and explanation
  • Documents prescribed u/s 35(5) and Reconciliation u/s 44(2) in Form 9C have been annexed
  • Particulars given in Form No.GSTR-9C are true and correct
  • Qualifications /observations

The author can be reached at cakrishnakumarm@gmail.com


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Category GST, Other Articles by - CA Krishnakumar M 



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