GSTR-9 Audit 2022-23

Respected Sir/Madam,

We are preparing GSTR-9 audit return for F.Y. 2022-23 and downloaded the System Computed Summary of GSTR-9 and reconciled it with our audited sales data, after checking found out that our sales data is not matching with the data of GSTR-9 Table 4 - Details of advances, inward and outward supplies made during the financial year on which tax is payable.

After checking all the GSTR-1 returns of F.Y. 2022-23 filed by us, we found that the GSTR-1 of March 2023 that we had filed, in which uploaded 3 documents of credit notes in 9B-Credit/Debit Notes (Registered) - CDNR tile, but there was no impact of GST value of Credit note in Total Liability of GSTR-1, because of this, could not availed GST value of Credit note in GSTR-3B while filling return and we had paid the tax as per GSTR-3B on Outward taxable supplies, because while uploading the documents of credit notes, mistakenly Supply attract reverse charge checkbox was ticked.

The impact of taxable value of credit notes i.e. 3046060.50 is being shown in Table 5 - Details of Outward supplies made during the financial year on which tax is not payable in GSTR-9 and the impact of GST value i.e. IGST - 21262.53, CGST - 65520.25 & SGST - 65520.25 of credit note is not being shown anywhere in GSTR-9.

As we have just came to know that there was mistake while uploading the credit notes in GSTR-1 return of March 2023, now we are trying to amend the credit notes in GSTR-1 return of November 2023 but the portal is giving error as document details related to previous financial year cannot be added/amended, as amendment date has gone.

So we want to know that the process, how and where can we report our audited sales data in GSTR-9 and 9C and how to avail GST value of credit notes which was not utilized in GSTR-3B?

Requesting to you please look into this matter and guide us so that we can report proper data in GSTR-9 & 9C.

Best Regards
Ramesh Bohra

Hi Ramesh,

Thanks for sharing the detailed issue. Here's how to approach the problem with GSTR-9 audit for FY 2022-23 and credit note amendments:

Issue Summary:

Credit notes for March 2023 were wrongly uploaded with Reverse Charge checkbox ticked in GSTR-1.
Due to this, credit note values did not reduce the total liability in GSTR-1 and GSTR-3B.
You paid GST on the original outward supplies (without adjusting credit notes).
Now, the portal disallows amendment of those credit notes since the amendment period for FY 2022-23 is closed.
You want to know how to correctly report these credit notes in GSTR-9 and 9C and get GST credit for those amounts.

What Can Be Done:

1. Amendment Restrictions:

GST portal does not allow amendments to GSTR-1 for a financial year after the filing window closes(usually till September following the FY).
Since March 2023 credit notes belong to FY 2022-23, you cannot amend them now.

2. Adjusting Credit Notes in GSTR-9:

In Table 9 (Adjustments to tax paid) of GSTR-9, you can report differences between returns filed and audited figures, including credit notes not accounted earlier.
You can disclose the credit notes in Table 9 as adjustments, stating that the credit notes were not reflected correctly in earlier returns.
This will provide transparency in reconciliation and audit report.

3. Input Tax Credit (ITC) Utilization & Tax Liability:

Since you have already paid GST on the outward supplies without adjusting credit notes, the credit notes effectively mean you paid excess tax.
You cannot claim ITC now on these credit notes as input credit since they relate to your outward supplies.
Instead, you can consider this excess tax payment as advance tax or excess GST paid.

4. Claiming Refund or Adjustments:

If excess tax was paid due to this error, you can explore filing a refund claim for excess tax paid under Section 54 of CGST Act.
Alternatively, you may adjust this excess tax payment against future GST liabilities in subsequent returns (subject to proper disclosures).

5. Reporting in GSTR-9C (Audit Report):

Disclose the mismatch and non-amendment of credit notes explicitly in the audit report.
Auditor should qualify the report mentioning the effect on turnover and tax liability due to unamended credit notes.
This maintains audit transparency and helps avoid adverse remarks.

Summary / Action Points:

Step	Descripttion
Amendments not possible	Portal disallows amendment for closed FY.
Adjust in GSTR-9 Table 9	Report credit notes as reconciliation adjustment.
No ITC claim possible	Credit notes relate to outward supply; no ITC claim possible.
Excess tax paid	Treat as advance/excess tax payment. Claim refund or adjust.
Audit report (GSTR-9C)	Disclose issue & adjustment in audit notes.