AMENDMENT OF GSTR 9

Hi Kumar Swamy,

Here’s how you can handle the issues related to the amendment of GSTR-9 for your client:

1. Wrong classification of B2B invoices as B2C in July 2017 & attempted amendment in Sept 2018

• GSTR-9 is an annual return and meant for reconciliation, not for changing original invoice details.

• The proper way to rectify invoice misclassification is:

  • Make corrections in the subsequent returns (GSTR-1 and GSTR-3B) of the current or next tax period where the error is detected.

  • Since the mistake was in July 2017, but detected in Sept 2018, you should have corrected the invoices in the returns of the period when the mistake was discovered or thereafter — NOT by adding fresh invoices in Table 4A of GSTR-9 with old dates.

• Adding invoices with old dates in Table 4A of GSTR-9 is not allowed and may cause rejection.

• In your case, since the department is not accepting the amendment, advise your client to file a rectification for the respective month’s GSTR-1/GSTR-3B (if still within allowed time period).

• If the time limit for amendment of GSTR-1/GSTR-3B for that period is over, then:

  • Rectify the mistake in the current/next return by showing the correct classification and adjustment.

  • Maintain proper documents and explanation for the tax authorities.

2. Table 6B (ITC Reconciliation) in GSTR-9 not filed and ITC claimed but not showing

• Table 6B of GSTR-9 relates to details of ITC availed but not reflecting in GSTR-2A.

• Not filling this section means reconciliation between ITC claimed in GSTR-3B and ITC declared by suppliers in GSTR-1 was incomplete.

• This causes mismatch between ITC claimed in GSTR-3B and GSTR-9.

• Department issues notices for such mismatches.

• Your explanation can be:

  • ITC was claimed as per books of accounts and returns filed (GSTR-3B).

  • Due to non-filing or mismatch in suppliers' returns (GSTR-1), ITC is not reflecting in GSTR-2A or GSTR-9.

  • The omission in Table 6B was inadvertent and now will be rectified.

• Advise to file a revised GSTR-9 with complete and correct details including Table 6B to reconcile ITC.

• If the time limit for filing revised GSTR-9 has expired, submit a detailed explanation with supporting documents to the tax authorities and cooperate for verification.

Summary: