Dear Friends/Taxpayers

Recently, CBIC extended the date of filing of GSTR 9 from 30.09.2020 to 31.10.2020. Last date is approaching very fastly and still every taxpayer is facing number of challenges at the time of filing the GSTR 9 like;

a) How to report the transactions or supply pertaining to FY 2017-18 in GSTR 9 & GSTR 9C of FY 2018-19?

b) How to report the supply in GSTR 9 on which GST should be chargeable but not charged?

c) How to report the supply of FY 2018-19 in GSTR 9 & 9C of FY 2018-19?

d) How to report the supply in GSTR 9 on which GST charged but not report in GST Return of any FY?

GST word and torn paper. Taxes on the background of craft paper.

Outward Part:

1. Supply pertaining to FY 2018-19 recorded in books & GSTR 1 of FY 2018-19 but not reported in GSTR 3B of any FY.

Supply to be added in Table 4 of GSTR 9 and any difference in Table 9 of GSTR 9 will be discharged through DRC-03

No special impact in GSTR 9C

2. Supply pertaining to FY 2018-19 recorded in books of FY 2019-20 (both taxable value & tax amount) but reported in GSTR 1 & GSTR 3B of FY 2018-19.

Example: Export recognized as revenue on shipment basis in book but treated as supply on removal basis in GST.

GSTR 9: Supply to be added in Table 4 and no difference will arise in Table 9

GSTR 9C: Unreconciled Turnover in GSTR 9C will be shown as difference with reasons or may be reflected as other adjustments.

3. Supply pertaining to FY 2018-19 recorded in the book of FY 2018-19 (Taxable Value) & tax amount in FY 2019-20 & reported in GSTR 1 & GSTR 3B of FY 2019-20:

Example 1: Cross Charge Transactions/Recovery from employees; taxable value recovered netted off with expense in FY 2018-19. On findings, the document issued in FY 2019-20 and accordingly tax discharged in FY 2019-20.

Example 2: Tax short charged in FY 2018-19 and therefore, debit note issued in FY 2019-20 and accordingly tax amount recorded in book and reported in GSTR 1 & GSTR 3B of FY 2019-20

GSTR 9: Only report in Table 10 of GSTR 9 (Reasoning: Refer Part V marginal note)

GSTR 9C: Add the tax amount in tax rate wise table 9. Taxable Value will be shown under the most suitable or respective column in Table 5.

4. Supply pertaining to FY 2018-19 recorded in book of FY 2018-19 (Taxable Value) which skip from GST Levy. Accordingly, not reported in GSTR 1 & GSTR 3B of any FY:

GSTR 9: Report in Table 4 & Table 9 of GSTR 9

GSTR 9C: Add the tax amount in tax rate wise table 9. Taxable Value will be shown under most suitable or respective column in Table 5.

5. Supply pertaining to FY 2017-18 recorded in book of FY 2017-18 (Taxable Value) & tax amount in FY 2018-19 but reported in GSTR 1 & GSTR 3B of FY 2018-19:

Example 1: Cross Charge Transactions/Recovery from employees; taxable value recovered netted off with expense in FY 2017-18. On findings, document issued in FY 2018-19 and accordingly tax discharged in FY 2018-19.

Example 2: Tax short charged in FY 2017-18 and therefore, debit note issued in FY 2018-19 and accordingly tax amount recorded in book and reported in GSTR 1 & GSTR 3B of FY 2018-19

Situation 1: GSTR 9 (2017-18); Reported in Table 10 of GSTR 9

Situation 2: GSTR 9 (2017-18); Skipped to report in Table 10 of GSTR 9

Situation 1 & 2:

Alternative 1:

GSTR 9: Report in Table 4 & Table 9 accordingly.

GSTR 9C: Unreconciled turnover & tax amount may be shown as different along with the reason.

Alternative 2:

GSTR 9: It should not be reported in Table 4, only tax payable amount added in Table 9 (Reasoning: Refer Part II & Part IV marginal note)

GSTR 9C: No difference will arise in turnover but the difference will arise in table 9 which may reflect along with the reason.

Special Remarks: Better to follow Alternative 2 by keeping in mind of marginal note of Part II

6. Supply pertaining to FY 2018-19 recorded in books of FY 2019-20/FY 2018-19 (both taxable value & tax amount) but reported after Sept in GSTR 1 & GSTR 3B of FY 2019-20.

GSTR 9: No separate table for reporting purposes. Therefore, may be reported in Table 10 or 11.

GSTR 9C: Shown as unreconciled turnover along with reason for differences or as adjustment in Table 5 of GSTR 9C.

Inward Part:

7. ITC pertaining to FY 2017-18 availed or reversed in GSTR 3B of FY 2018-19 and also recorded in books of FY 2018-19.

Situation 1: Reported in Table 12/13 of GSTR 9.

Situation 2: Not reported in Table 12/13 of GSTR 9.

GSTR 9: Report in Table 6 or Table 7

8. ITC excess or short availed in GSTR 3B over Book and not availed nor reversed in GSTR 3B of any FY.

Consider in Table 6 or 7 of GSTR 9 on lower basis.

9. ITC reversed in GSTR 3B of FY 2019-20 after Sept pertaining to FY 2018-19. (Also reversed in books of FY 2019-20)

GSTR 9: May be reported in Table 12 as there is no other separate column for reporting such supply in GSTR 9

If ITC availed in FY 2019-20 after Sept for FY 2018-19 – No impact to be considered in GSTR 9/GSTR9C as impact may consider in GSTR 9 of next FY.

10. Whether Table 12 or 13 should be filed on the basis of book or on the basis of GSTR 2A (Table 8C).

Some experts have a view to report the Table 13 should be filed as per Table 8C and some other experts have a view to report in table 12 or table 13 as per transaction recorded in books of account.

All possible cases in GSTR 9 & 9C other than as discussed above

Outward Part
Sr. No. Supply Book GSTR1 GSTR 3B
1 2018-19 2018-19 2018-19 2018-19
GSTR 9: Respective supply to be shown under Table 4/ 5 & 9

GSTR 9C: No special impact in GSTR 9C

2 2018-19 2018-19 2018-19 2019-20
Example: Supply skip to report in GSTR 3B

GSTR 9: To be reported in Table 10/11

GSTR 9C: No special impact in GSTR 9C

3 2018-19 2018-19 2019-20 2018-19
Example: Supply skip to report in GSTR 1

GSTR 9: To be reported in Table 4/5 & 9

GSTR 9C: No special impact in GSTR 9C

4 2018-19 2018-19 2019-20 2019-20
Example: Supply reported in GSTR 3B & GSTR 1 of Next FY

GSTR 9: To be reported in Table 10/11

GSTR 9C: No special impact in GSTR 9C

5 2018-19 2018-19
Example: Supply (GST Collected) not reported either in GSTR 1 or GSTR 3B or both of any FY.

GSTR 9: To be reported in Table 4/5 and Table 9. Diff. amount may be paid through DRC-03

GSTR 9C: No special impact in GSTR 9C

6 2018-19 2019-20 2018-19 2018-19
Already discussed above
7 2018-19 2018-19 (Taxable) & 2019-20 (Tax) 2019-20 2019-20
Already discussed above
8 2018-19 2019-20 2019-20 2019-20
Example: Export recognized as revenue on shipment basis in book but treated as supply on removal basis in GST

GSTR 9: Export with payment to be reported in Table 10 & export without payment may also be reported in Table 10

GSTR 9C: Unreconciled Turnover in GSTR 9C will be shown as a difference with reasons or may be reflected as other adjustments.

*****

Disclaimer: This the personal view of the author. The author or any associated or related person is not liable for any loss or damages to any person for taking any action by accepting this view as given above.

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16 Comments

  1. L Saha says:

    Dear Mr. Garg,
    In FY 2018-19, entry related to ‘All other ITC’ (Row No.5, has been entered erroneously in Row No.4 i.e. ‘Inward supplies from ISD’, in GSTR 3B , Table 4. Please advise how to reconcile it in GSTR 9 /9C.
    Regards

  2. Sreelakshmi says:

    Sale bill not entered in July 2018, gstr 1, but paid tax for the same in gstr3b.
    2018 – 19 annual returns already filed
    How to enter the bill details so that the customer can claim Itc, advise

    1. TARUN GARG says:

      No rectification of any omission shall be allowed after the due date of Sept month GST Return or actual date of furnishing of annual return, whichever is earlier.

      As per section 16(2), for availing ITC, condition is only for payment of tax by supplier not for reporting in return. Therefore, you may give declaration to recipient that tax has been paid. However, this view is litigative. Before taking ay action, you should consult to your consultant.

  3. RAJENDER SINGH LUTHRA says:

    I LIKE YOUR ARTICLE. AND I ASK YOU THAT SALE RELATE TO 18-19 AND REPORT IN GSTR 1 AND GSTR 3B IN APRIL 19. AND PAY INTEREST ALSO. IN 18-19 ANNUAL RETURN I AM SHOWING IN COLUMN 10 AND COLUMN 14 AND SHOWING IN PAYABLE AS WELL AS PAID. IF ANY NOTICE RECEIVED THEN I WILL SHOWING RE-CONCILATION OF 19-20 IN APRIL 20. NOW IN 19-20 ANNUAL RETURN CAN I SHOW IN COLUMN 9 AND COLUMN 14 AS NEGATIVE. SALE RELATE TO 18-19 BUT FILE IN 19-20 GSTR 1 AND GSTR 3B IN APRIL 19..
    WITH THANKS
    RAJENDER SINGH

    1. TARUN GARG says:

      Thank you Sir!

      Need clarification from CBIC in the given case. In my view, GSTR 9 form should be update for reporting of such type of transaction.

  4. sreelatha skumar says:

    Sir
    We have filed GSTR 3b every month and GSTR 1 quartery durin gth eyear 2018-19 as turn over for the year 2017-18 less than 1.5 crore – during the year 2018-19turn over is morethan 2 crores – Turn over upt o december less than 1.5 crores increased to 2 crores in last quarter – we have filed gstr 1 quarterly only
    now we are not able to generate GSTR 9 please help

  5. ATUL MITTAL says:

    Dear Tarun Ji, whether we have to add the tax payable amount of column 14 of year 17-18, in tax payable amount of table 9 of 18-19 for matching the tax amount paid in 18-19, please confirm,
    and the second query: the same whether we also have to add input of col 13 of 17-18 in col. 6b or in 6M of 18-19 for matching the input tax amount claimed as per 3B of 18-19

  6. Atul Mittal says:

    and the same whether we also have to add input of col 13 of 17-18 in col. 6b or in 6M of 18-19 for matching the input tax amount claimed as per 3B of 18-19.

  7. Atul Mittal says:

    Dear Tarun Ji, whether we have to add the tax payable amount of column 14 of year 17-18, only in the tax payable amount of table 9 of 18-19 for matching the tax amount paid in 18-19, please confirm.

  8. Ramesh Sharma says:

    Sir, We returned purchase material to supplier and raised sale Bill’s, then paid GST of Rs.80000 and reported in GST-1. But supplier , instead, issued credit notes. Inadvertently, we did not enter the credit notes, as we have already debited suppliers account. This has reduced ITC available by
    Rs.80000, which is now payable in GST-9. Pl guide.
    Thanks & regards.

  9. Ajay Kumar says:

    Sir…
    I want to know… In gstr9 what amount to be filled in table 4 , in a case where gstr1 was correctly filled but in gstr 3B turnover was excess reported by Rs.10K..but corrected in next year September gstr 3B….
    Please guide how to report in gstr9 table wise… table 4, 9 11,.

  10. MAHESH KUMAR AGARWAL says:

    AS STATED IN POINT NO 5. SALES NOT REPORTED IN GSTR 1 AND 3B BUT SHOWN IN GTR 9 AND PAID ADDITIONAL TAX THROUGH DRC -03 BUT THE POINT IS HOW WILL BUYER GET THE ITC OF THE TAX PAID THROUGH DRC -03

    1. TARUN GARG says:

      As per section 16(4), recipient is not eligible for ITC after Sept’ 2019 for the invoices issued in FY 2018-19.
      Further, no rectification can be made by supplier after Sept’2019 in GSTR 1.

  11. Amit Verma says:

    Sir, you didn’t discussed about how to deal with differences between ITC as per 2A, Table-8A, and ITC claimed in GSTR-3B. Kindly share your views on this issue also. Thanks.

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