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Solution to GSTR 9 Queries (GST Annual Return)

• Annual Return Form?
Form GSTR 9

• Filing by whom?
Every Registered Person

• Turnover Criteria for GSTR 9?
To be filed irrespective of Turnover in FY 2017-18

• Form to be filed PAN or GSTN wise?
GSTN wise i.e. separately for each GSTN

• Applicable for Registered persons registered on or before?
For FY 2017-18, registered on or before 31.03.2018

• GSTN Cancelled?
Also required to file GSTR 9, even if GSTN cancelled during FY 2017-18

• Not to be filed by whom?
- Composition Dealer,
- Input Service Distributor,
- Tax Deductor,
- Tax Collector,
- Casual taxable person,
- Non-resident taxable person

• Composition Dealer?
To file GSTR 9A (Not GSTR 9)

• Opted out or in Composition Dealer during the year?
To file GSTR 9 and GSTR 9A for the relevant periods during the year

• Filing of NIL Return?
Mandatory

• Meaning of NIL Return?
- Nil return can be filed for the Financial year, if you have: -
- NOT made any outward supply (commonly known as sale); AND
- NOT received any goods/services (commonly known as purchase); AND
- NO other liability to report; AND
- NOT claimed any credit; AND
- NOT claimed any refund; AND
- NOT received any order creating demand

• Turnover above 2 Crores during FY 2017-18?
File GSTR 9C after filing GSTR 9

• Filing Mode?
Electronically on GST Portal www.gst.gov.in

• Due Date?
For FY 2017-18, Extended Due Date is 30.06.2019

• Not filed GSTR 3B & GSTR 1, even then filing of GSTR 9 Possible?
GSTR 9 can’t be filed unless GSTR 3B & GSTR 1 filed

• Revision of GSTR 9 Possible?
No

• Implication of incorrect information in GSTR 9 filed?
Incorrect information can attract tax demands, interest and penalties on the same, and the long-term litigations that follow years later.

• Additional Liability can be paid?
Liability identified during filing Annual Return can be deposited with Government using DRC-03 Form (i.e. Liability not earlier paid through GSTR 3B)

• Additional Liability will be auto-calculated in the Form?
No, Tax Liability needs to be self-calculated & self-deposited (Except Late Filing Fees of GSTR 9)

• Additional Liability not deposited?
Can attract tax demands, interest and penalties

• Additional ITC?
ITC not claimed in GSTR 3B can’t be claimed in GSTR 9. The same need to claimed in GSTR 3B upto the extended timeline for claiming input credit.

• Late Fees for GSTR 9?
Rs. 200 per day (Maximum 0.50% of Turnover)

• Where to file the return in GST Portal?
Login to www.gst.gov.in > Services > Returns > Annual Return > FY 2017-18 > Prepare Online > Select NIL Return Yes or No

• Basic Format of GSTR 9?

Part I: Basic Details (Table 1-3B)
Part II: Details of Outward & inward supplies made during the financial year (Table 4-5)
Part III: Details of ITC for the financial year (Table 6-8)
Part IV: Details of tax paid as declared in returns filed during the financial year (Table 9)
Part V: Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of filing of annual return of previous FY whichever is earlier (Table 10-14)
Part VI: Other Information (Table 15-19)

• How to prepare GSTR-9?
• Download System Computed Summary of GSTR 9:
Services > Returns > Annual Return > FY 2017-18 > Prepare Online > Select NIL Return Yes or No > Download GSTR 9 System Computed Summary

• Download Comparison of Liability declared & ITC claimed Report for FY 2017-18 : . Services > Returns > Returns Dashboard > FY 2017-18 : March > Comparison of Liability declared & ITC claimed > View > Click on Refresh Button

• Download Credit & Liability Statement along with 4 Reports available i.e.
1. Liability other than Export/Reverse Charge
2. Liability Due to Export and SEZ Supplies
3. Liability due to Reverse Charge
4. ITC Credit Claimed & Due

• Download GSTR 2A
Services > Returns > Returns Dashboard > FY 2017-18 : March > Auto Draft Details GSTR 2A

• Analyze the Differences (if any) on the above reports & compare the same with Books of Account

• Have Final figures on Record:

1. Sales : IGST- CGST- SGST
2. NIL Rated Sales, Exempt Sales
3. RCM Liability : IGST- CGST- SGST
4. Input Claimed : IGST- CGST- SGST
5. Input Reversed : IGST- CGST- SGST
6. Input as per GSTR 2A : IGST- CGST- SGST
7. Bifurcate Input Claimed into Inputs, Input Services & Capital Goods

• Differences/Mismatch may arise due to following

1. Differential reporting in GSTR 3B & GSTR 1 - Pay additional Liability through DRC -03
2. Under/Over reporting of Outward Supplies in GST Returns - Show only Correct Amounts in GSTR 9 - Refer Point 3 to 5 below
3. Amendments done during the same Financial Year - Show in Table 4 - Point K & L
4. Amendments done during the subsequent Financial Year - Show in Amendments Table 10 & 11.
5. Non-reporting of Sales Invoices altogether - Add in Table 4 & Table 5 & Pay Tax on Differential amount with Interest
6. Non-availment of ITC - ITC not availed upto prescribed deadline will lapse
7. Delayed availment of ITC in Next FY - Show in Table 8 - Point C
8. Excess availment of ITC - Bifurcate only Correct ITC in Table 6 & pay interest on excess availment

• Fill the required details in Form GSTR 9

• Verify all the Details & Submit the return by Computing Liabilities & File with OTP/DSC

• Pay the Additional Liability through DRC-03(If any)

Please refer all the relevant section, rules, notifications and amendments as applicable. The Author is not responsible for any losses incurred. Content is merely for sharing knowledge.

The author can also be reached at casagargambhir@gmail.com for any queries, issues & recommendations

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