GSTR-9 & 9C requirements

 

GSTR-9 & 9C requirements for FY 2021-22

 

As per Section-44(1) of the CGST Act 2017, every person who is registered under GST as a regular taxpayer has to file their GSTR-9 & GSTR-9C by the 31^st December 2022. As per the latest notification 10/2022 dated 05/07/2022 taxpayers whose having AATO above Rs. 2 crores have to mandatorily file their GSTR-9. The taxpayers who fail to file annual return and reconciliation statements till such date then a late will be liable as Rs. 200/- per day subjected as sum liability for failure. The late fee can be entitled to a highest of 0.25% of assessee turnover in the related state.

Further, we suggest every taxpayer to keep the below detail ready for timely completion of GSTR-9 for FY 2021-22

 

Ø  Details required related to Outward supply

 

1.      Detail of outward supply made during the FY 2021-22

2.     Detail of outward supply declare in GSTR-1 during the FY 2021-22

3.     Detail of outward supply pertaining to FY 2020-21 but declared in 2021-22 along with reconciliation sheet

4.     Detail of outward supply pertaining to FY 2021-22 but declared in 2022-23 along with reconciliation sheet

5.     Detail of Debit/Credit Note issued against sales invoices

6.     Detail of Unbilled revenue if any

7.     Detail of advances received during the year

8.     Summary of GSTR-1

9.     Trial balance of liability as per books

10.   Signed PDF copy of Sale invoices

11.    Summary of HSN code as declared in GSTR-1

12.   Outward reconciliation as per books vs GST return

13.   Turnover Reconciliation as declared in GST return and financials

 

Ø  Details required related to Inward supply

 

1.      Detail of inward supply on which RCM is paid in FY 2021-22

2.     Detail of inward supply on which RCM is paid in FY 2021-22 but invoices pertaining to FY 2020-21

3.     Detail of inward supply on which RCM is paid in FY 2022-23 but invoices pertaining to FY 2021-22

4.     Self-Invoice and Payment voucher issued against RCM supply

5.     Detail on Inward supply on which ITC is availed in FY 2021-22

6.     Detail on Inward supply on which ITC is availed in FY 2021-22 but pertaining to FY 2020-21

7.     Detail on Inward supply on which ITC is availed in FY 2022-23 but pertaining to FY 2021-22

8.     Bifurcation of ITC in ITC on inputs (Domestic + Import), capital goods and input services

9.     Detail of ineligible ITC availed and reversal during the year

10.   Detail of ITC reversal made during the year under Rule-42 & 43

11.    Reconciliation of ITC available as availed in GSTR-3B with ITC available in Table-8A of GSTR-9

12.   Detail of invoices on which ITC availed but payment not made within 180 days.

13.   Input invoices copy for verification of ITC as availed during the year

 

Ø  Details of SCN and any demand notice received during the year and GST refund received and rejected during the year

 

 

Notes:

·       If any unpaid liability is identified for the year 2021-22 at the time of filling of GSTR 9, then such liability can be paid through DRC – 03.

·       If any excess credit has been taken but not reversed in the return filed for the year 2021-22 and 2022-23, an amount equal to such excess credit taken is required to be deposited through DRC -03 along with interest payable (if any).

·       If any missed ITC is identified which is not claimed in the returns filed for the year 2021-22 and 2022-23, cannot be claimed through the filling of annual return GSTR 9, such credit will lapse.

·       GSTR 9 is required to file by all taxpayers with GST registration as regular taxpayers.

·       GSTR 9 once file cannot be revised.

 

Turnover-based Audit under Section 35(5) of CGST Act

 

If the annual turnover of a registered taxpayer is more than Rs.5 crore aggregate turnover in a financial year, he is required to submit a self-certified reconciliation statement for FY 2021-22. A financial year covers the 12-month period beginning from April of a calendar year to March of the next calendar year. Please refer to notification no. 14/2022, a link is given below in the article.

Aggregate turnover is calculated as follows:

Aggregate turnover = Value of all taxable (inter-state and intra-state) supplies + exempt supplies + export supplies of all goods and services

 

Items included while calculating Aggregate Turnover

·       All taxable (inter-state and intra-state) supplies other than supplies on which reverse charge is applicable

·       Supplies between separate business verticals.

·       Goods supplied to/received from the job worker on a principal-to-principal basis.

·       Value of all export/zero-rated supplies.

·       Supplies of agents/job workers on behalf of the principal.

·       All exempt supplies. For example, agricultural produce supplied along with branded ready-to-eat food.

·       All taxes other than those covered under GST. For example, entertainment tax paid on the sale of movie tickets.

Items excluded while calculating turnover

·       Inward supplies on which tax is paid under reverse charge.

·       All taxes and cess charged under Goods and service tax like CGST, SGST or IGST, compensation cess.

·       Goods supplied to or received back from a job worker.

·       Activities which are neither supply of goods nor service under schedule III of CGST Act.

 

Penalty for not submitting GST Audit report

There is no specific provision. Hence, it is subject to a general penalty of Rs.25,000.

 

Notification 14/2022 dated 05/07/2022 – related to GSTR-9 & 9C for FY 2021-22

Point no. 12 of said notification clarifies on n the said rules, in FORM GSTR-9, under the heading Instructions, -

(a) in paragraph 4, -

(A) after the word, letters and figures ―or FY 2020-21‖, the word, letters and figures ―or FY 2021-22 shall be inserted;

(B) in the Table, in second column, -

(I) against serial numbers 5D, 5E and 5F, the following entries shall be inserted at the end, namely: –

For FY 2021-22, the registered person shall report Non-GST supply (5F) separately and shall have an option to either separately report his supplies as exempted and nil rated supply or report consolidated information for these two heads in the ―exempted‖ row only.‘;

(II) against serial numbers 5H, 5I, 5J and 5K, for the figures and word ―2019-20 and 2020-21‖, the figures and word ―2019-20, 2020-21 and 2021-22 shall respectively be substituted;

(b) in paragraph 5, in the Table, in second column, -

(A) against serial numbers 6B, 6C, 6D and 6E, for the letters and figures ―FY 2019-20 and 2020-21, the letters, figures and word ―FY 2019-20, 2020-21 and 2021-22‖ shall respectively be substituted;

(B) against serial numbers 7A, 7B, 7C, 7D, 7E, 7F, 7G and 7H, for the figures and word ―2019-20 and 2020-21‖, the figures and word ―2019-20, 2020-21 and 2021-22 shall be substituted;

(c) in paragraph 7, -

(A) after the words and figures ―April 2021 to September 2021.‖, the following shall be inserted, namely: -

―For FY 2021-22, Part V consists of particulars of transactions for the previous financial year but paid in the FORM GSTR-3B between April, 2022 to September, 2022.;

(B) in the Table, in second column, -

(I) against serial numbers 10 & 11, the following entries shall be inserted at the end, namely: -

―For FY 2021-22, details of additions or amendments to any of the supplies already declared in the returns of the previous financial year but such amendments were furnished in Table 9A, Table 9B and Table 9C of FORM GSTR-1 of April, 2022 to September, 2022 shall be declared here.‖;

(II) against serial number 12, -

(1) after the words, letters, figures and brackets ―September, 2021 shall be

declared here. Table 4(B) of FORM GSTR-3B may be used for filling up these details., the following entries shall be inserted, namely: - ―For FY 2021-22, aggregate value of reversal of ITC which was availed in the previous financial year but reversed in returns filed for the months of April 2022 to September 2022 shall be declared here. Table 4(B) of FORM GSTR-3B may be used for filling up these details.;

(2) for the figures and word ―2019-20 and 2020-21, the figures and word ―2019-20, 2020-21 and 2021-22‖ shall be substituted;

(III) against serial number 13, -

(1) after the words, letters and figures ―reclaimed in FY 2021-22, the details

of such ITC reclaimed shall be furnished in the annual return for FY 2021-22, the following entries shall be inserted, namely: ― For FY 2021-22, details of ITC for goods or services received in the previous financial year but ITC for the same was availed in returns filed for the months of April 2022 to September 2022 shall be declared here. Table 4(A) of FORM GSTR-3B may be used for filling up these details.

However, any ITC which was reversed in the FY 2021-22 as per second proviso to sub-section (2) of section 16 but was reclaimed in FY 2022-23,

the details of such ITC reclaimed shall be furnished in the annual return

for FY 2022-23.;

(2) for the figures and word ―2019-20 and 2020-21‖, the figures and word ―2019-20, 2020-21 and 2021-22‖ shall be substituted;

(d) in paragraph 8, in the Table, in second column, -

(A) against serial numbers, -

(I) 15A, 15B, 15C and 15D,

(II)15E, 15F and 15G,

for the figures and word ―2019-20 and 2020-21‖ wherever they occur, the letters, figures and word ―2019-20, 2020-21, and 2021-22‖ shall respectively, be substituted.;

(B) against serial numbers 16A, 16B, and 16C for the figures and word ―2019-20 and 2020-21 wherever they occur, the figures and word ―2019-20, 2020-21, and 2021-22 shall respectively be substituted;

(C) against serial numbers 17 and 18, -

(I) after the words, letters, and figures ―for taxpayers having annual turnover above ₹ 5.00 Cr, the words, letters, and figures ―From FY 2021-22 onwards, it shall be mandatory to report HSN code at six digits level for taxpayers having annual turnover in the preceding year above ₹ 5.00 Cr and at four digits level for all B2B supplies for taxpayers having annual turnover in the preceding year up to ₹ 5.00 Cr. shall be inserted;

(II) the following paragraph shall be inserted at the end, namely: - For FY 2021-22, the registered person shall have an option to not fill Table 18;

13. In the said rules, in FORM GSTR-9C, under the heading Instructions, -

(a) in paragraph 4, in the Table, in the second column, for the figures and word ―2019-20 and 2020-21, wherever they occur, the figures and word ―2019-20, 2020-21, and 2021-22 shall be substituted;

(b) in paragraph 6, in the Table, in the second column, against serial number 14, for the figures and word ―2019-20 and 2020-21, the figures and word ―2019-20, 2020-21, and 2021-22 shall be substituted;

 

If you have any suggestions or queries related to GSTR-9 & 9C or if you want to take any assistance in relation to the filing of GSTR-9 and reconciliation statement then please comment on our article with your contact detail or submit your query through our contact tab.