To be or not to be Filing of GST audit and Annual return

Arjuna (Fictional Character): Krishna, what is the debate going on for filing of GSTR-9 and GSTR-9C GST returns?

Krishna (Fictional Character): Arjuna, As shakespeare had a question “To be or not to be” a similar question is bothering Auditors and Taxpayers after issue of notification on 14-11-2019, wherein form GSTR-9 (Annual Return) and GSTR-9C (Audit report) were simplified. As per latest tweet the new template for filing returns would be made available on 10^th December 2019. So, the question is whether to file GSTR-9 and GSTR-9C before 10^th December 2019 or not.

Arjuna: Krishna, what if the taxpayers file GSTR-9 for F.Y 17-18, before 10^th December 2019?

Krishna: Arjuna, if the taxpayers file GSTR-9 for F.Y 17-18, before 10^th December 2019 there would be no issue but following details may be provided

• The taxpayer would have to report taxable outward supplies and debit and credit notes separately.
• The amendments of taxable outward supplies are to be reported separately.
• The Exempted, Nil-rated, Non-GST are to be shown separately along with debit and credit notes.
• In Table 15 of Demand and Refund details are to be provided.
• The bifurcation of ITC as Input, Input services and capital goods is to be provided.
• Also, the bifurcation of ITC reversals is to be provided.
• The HSN-wise summary to be provided for both inward and outward supplies.
• One should note that the above requirements have been made optional via Notification issued on 14^th November 2019. One may file return before 10^th December in old utility proper note that one has opted such option of not providing above mentioned details should be enough.

Arjuna: Krishna, what if the taxpayers file GSTR-9C for F.Y 17-18 before 10^th December 2019?

Krishna: Arjuna, if the taxpayers file GSTR-9C before 10^th December 2019 there would be no issue but following details may be provided-

• Cashflow statement is to be provided
• “True and Fair” is to be reported by an auditor instead of “True and Correct” as the same cannot be edited in old utility.
• The taxpayer would have to report the details of reconciliation of gross turn-over in Table 5
• The taxpayer would have to provide data of ITC booked in earlier F.Y and claimed in current year and ITC booked in current F.Y and claimed in subsequent year.
• Expense head-wise details of ITC in Table 14 are to be provided.
• One should note that the above requirements have been made optional via Notification issued on 14^th One may file return before 10^th December in old utility. A proper disclosure that one has opted such option of not providing above mentioned details should be sufficient.

Arjuna: Krishna, what if the taxpayers file GSTR-9 and GSTR-9C for F.Y 17-18 after 10^th December 2019?

Krishna: Arjuna, the utility for filing GSTR-9 and GSTR-9C would be available till 10^th December 2019. The taxpayers would get relief from various reporting requirement, as it is made optional. But the due date for filing GSTR-9 and GSTR-9C is 31^th December 2019.

Arjuna: Krishna, When should one file Annual return and Audit report for F.Y 18-19?

Krishna: Arjuna, the utility for filing GSTR-9 and GSTR-9C is not yet made available. So, one cannot file returns as of now.

Arjuna: Krishna, what lesson one should learn from this?

Krishna: Arjuna, there are continuous changes made in GST, which is leading to confusion. One should cautiously file GSTR-9 and GSTR-9C, if one decides to file it   before 10^th December 2019. Proper notes and disclosures should be made and if one decides to wait till new utility is made available care must be taken that there is no last-minute hurry.