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Under GST normal registered taxpayer is required to file an annual return (GSTR 9) once in a financial year on or before the 31st December following the end of such financial year. Annual Return is not for rectification of errors, but it is summarisation of all returns filed pertaining to the transaction from period 01/07/17 to 31/03/18 in a single return.

It is to be clarified that Annual GST Return (GSTR 9) is a consolidation of returns filed and is no way reconciliation with books of accounts. Broadly, an annual return in GSTR 9 is divided into 6 basic parts and the same are summarized hereunder –

I Basic Details
II Details of Outward and inward supplies declared during the financial year
III Details of ITC as declared in returns filed during the financial year
IV Details of tax paid as declared in returns filed during the financial year
V Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of filing of annual return of previous FY, whichever is earlier
VI Other Information

Part I – of Annual GST Return (GSTR 9)- Basics Details

As the name itself states under part I of form GSTR 9 following basic details are to be provided –

1. Financial Year

2. GSTIN

3. Legal Name, and

4. Trade Name (if any)

Part II – of Annual GST Return (GSTR 9)- Details of Outward and inward supplies declared during the financial year

Part II consists of the details of all outward supplies, inward supplies on which tax is to be paid on reverse charge basis & advances received. The details filled in Part II is a consolidation of all the supplies declared by the taxpayer in the returns filed during the financial year. If the details are not shown in the return then it is not required to shown here (declare in Part V).

Details of Outward supplies has been further divided into 2 parts – 1st on which tax is payable (table 4) & 2nd on which tax is not payable (table 5).

Table Form GSTR 9 Reference in GSTR 1 Instructions/Observations
4A Supplies made to un-registered persons (B2C) Table 5, Table 7 along with

respective amendments in Table 9 and Table 10

– To be declared as net of credit notes or debit notes issued

– Include details of supplies to unregistered person made through E-Commerce operators

– Composition dealer is a registered person and need not to be reflected here.

4B Supplies made to registered persons (B2B) Table 4A and

Table 4C

– Details of debit and credit notes are to be mentioned separately.

– Include details of supplies to registered person made through E-Commerce operators

– Include supplies made to UINs

– Not to include supplies on which tax is to be paid by the recipient on reverse charge basis

Example – In case of supply made by GTA to a factory, the factory is required to get registered as per section 24 of CGST Act & pay GST under reverse charge. However if the factory doesn’t get registered then it shall be treated as an unregistered person.

4C Zero rated supply (Export) on payment of tax (except supplies to SEZs) Table 6A – Details of debit and credit notes are to be mentioned separately.

– Not to include details of export of goods & services under LUT

– Only IGST is required to be charged as export of goods & services is interstate supply as per section 7(5) of IGST Act, 2017.

4D Supply to SEZs on payment of tax Table 6B – Details of debit and credit notes are to be mentioned separately.

– Not to include details of supply to SEZ under LUT

– Only IGST is required to be charged as Supply to SEZ is interstate supply as per section 7(5) of IGST Act, 2017.

4E Deemed Exports Table 6C – Details of debit and credit notes are to be mentioned separately.

– Deemed exports are not zero rated supply.

– They have status equivalent to export so CGST, SGST & IGST is leviable.

4F Advances on which tax has been paid but invoice has not been issued (not covered under (A) to (E) above) Table 11A – Not to include details of advance received & refunded during the year.

– In case of supply of goods, no tax is required to be paid on the advances w.e.f 01.11.2017. Therefore the details of advances received after the above date are not required to declare here.

4G Inward supplies on which tax is to be paid on reverse charge basis Table 3.1(d) of GSTR-3B – To be declared as net of credit notes or debit notes issued.

– Remember that section 9(4) has been deferred from 13.10.2018.

4I Credit Notes issued in respect of transactions specified in (B) to (E) above (-) Table 9B Include the details of credit notes issued in respect of

– B to B supplies (4B),

– exports (4C),

– supplies to SEZs (4D)

– deemed exports (4E)

4J Debit Notes issued in respect of transactions specified in (B) to (E) above (+) Table 9B Include the details of debit notes issued in respect of

– B to B supplies (4B),

– exports (4C),

– supplies to SEZs (4D) and

– deemed exports (4E)

4K & 4L Supplies / tax declared/reduced through Amendments Table 9A and Table 9C – Include the details of amendments made to B to B supplies (4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E), credit notes (4I) & debit notes (4J).

– Also include the details of refund vouchers.

5A Zero rated supply (Export) without payment of tax Table 6A – Include the details of export of goods & services under LUT.

– Details of debit and credit notes are to be mentioned separately.

5B Supply to SEZs without payment of tax Table 6B – Include the details of Supply to SEZ under LUT.

– Details of debit and credit notes are to be mentioned separately

5C Supplies on which tax is to be paid by the recipient on reverse charge basis Table 4B – Details of debit and credit notes are to be mentioned separately.

Eg. An Advocate providing Legal Services.

5D5E

& 5F

Exempted, Nil Rated, Non-GST supply Table 8 – Include the details of ‘No supply’ as specified in schedule III.

– Ratio of exempt supply to taxable supply may be taken from here for reversal of the credit attributable to the exempt supply as per Rule 42 of the CGST rules, 2017.

– Details of debit and credit notes are to be mentioned separately as exempt supply may be taxable supply.

5H Credit Notes issued in respect of transactions specified in A to F above (-) Table 9B Include the details of credit notes issued in respect of supplies declared in 5A,5B,5C, 5D, 5E and 5F
5I Debit Notes issued in respect of transactions specified in A to F above (+) Table 9B Include the details of debit notes issued in respect of supplies declared in 5A,5B,5C, 5D, 5E and 5F
5J & 5K Supplies declared/reduced through Amendments Table 9A and Table 9C Include the details of amendments made to zero rated supply under LUT
5N Total Turnover (including advances) (4N + 5M – 4G above) – This is not the turnover as per books of accounts. It is the turnover as per the valuation rules of GST. It may include the value of expenses like packing charges, transportation charges etc. if they are charged in the invoice [section 15(2) of CGST Act, 2017]

– It may include the value of supply without consideration.

– Not to include the aggregate value of inward supplies on which tax is on reverse charge basis.

Part III – Details of all input tax credit availed and reversed in the financial year

If the details of the input tax credit are not shown in the GSTR 3B filled during the previous year then it is required to shown in table no. 8C.

Table Form GSTR 9 Reference in GSTR 3B Instructions
6A Total amount of input tax credit availed through FORM GSTR-3B Table 4A Total input tax credit availed in GSTR-3B would be auto-populated here.
6B Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs)

– Inputs

– Capital Goods

– Input Services

Table 4(A)(5) – Total ITC availed is to be classified as ITC on inputs, capital goods and input services.

– Not to include details of inward supplies on which tax is payable on reverse charge basis, inward supply of goods from SEZ & import of goods & services

– Not to include ITC which was availed, reversed and then reclaimed. It shall be shown in Table 6H.

6C Inward supplies received from unregistered persons liable to reverse charge (other than B above) on which tax is paid & ITC availed Table 4(A)(3) – Not to include details of import of services

– Total ITC availed is to be classified as ITC on inputs, capital goods and input services.

– It Pertains to RCM u/s 9(4)

6D Inward supplies received from registered persons liable to reverse charge (other than B above) on which tax is paid and ITC availed Table 4(A)(3) – Total ITC availed is to be classified as ITC on inputs, capital goods and input services.

– It Pertains to RCM u/s 9(3)

6E Import of goods (including supplies from SEZs) Table 4(A)(1) – Include supply of goods received from SEZs

– Total ITC availed is to be classified as ITC on inputs and capital goods.

6F Import of services (excluding inward supplies from SEZs) Table 4(A)(2) Services from SEZs are not import of services.
6G Input Tax credit received from ISD Table 4(A)(4)
6H Amount of ITC reclaimed (other than B above) under the provisions of the Act Include ITC which was availed, reversed and then reclaimed under the Provisions of the Act.
6J Difference Ideally, this amount should be zero if the details are correct.
6K Transition Credit through TRAN-I (including revisions if any) Include details of transition credit received in the electronic credit ledger on filing of GST TRAN-I including revision of TRAN-I
6L Transition Credit through TRAN-II Include details of transition credit received in the electronic credit ledger on filing of GST TRAN-II
6M Any other ITC availed but not specified above Details of ITC availed through ITC01 and ITC-02 in the financial year shall be declared here.

ITC01 • Unregistered person got registered

• Composition dealer opting out of the composition scheme

• Exempted goods become taxable goods

ITC02 In case of transfer of business by way of sale of business / merger / demerger
7A, 7B,

7C, 7D,

7E, 7F,

7G and

7H

ITC Reversed & Inelligible as per Rule 37,39,42,43, Sec 17(5), Reversal of Trans I & II Credit etc. Table 4(B) – Any ITC reversed through FORM ITC -03 shall be declared in 7H (Composition to Normal).

Rule/Section Particulars
Rule 37 Non-payment of consideration
Rule 39 Distribution of input tax credit to Input Service Distributor
Rule 42 & 43 Being partly used for the purposes of business and partly for other purposes, or partly used for effecting taxable supplies including zero rated supplies and partly for effecting exempt supplies
section 17(5) Block Credit
8A ITC as per GSTR-2A Table 3 & 5 of GSTR-2A – Auto-populated in this table

– This would be the aggregate of all the input tax credit that has been declared by the corresponding suppliers in their GSTR-I.

– This would not include the input tax credit on imports and inwards supplies liable to reverse charge.

– GSTR 2A is the reflection of ITC on inward supplies made but it doesn’t determine the eligibility of the credit.

8B ITC as per sum total of 6(B) and 6(H) above The input tax credit as declared in Table 6B and 6H shall be auto-populated here.
8C ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during 2017-18 but availed during April to September, 2018 Table 4(A)(5) of GSTR-3B Include the input tax credit on all inward supplies (except those on on imports and inwards supplies liable to reverse charge basis) received during July 2017 to March 2018 but credit on which was availed between April to September 2018.
8D Difference [A-(B+C)] – If it is –ve then do recovery from supplier as the input tax credit is not available if the tax has not been paid & GSTR 1 has not been submitted by the supplier [section16(2) of CGST Act, 2017].

– If +ve then give explanation in 8E & 8F.

8E & 8F ITC available but not availed / ineligible Aggregate value of the input tax credit which was available in GSTR2A but not availed in any of the GSTR-3B returns or ineligible credit shall be declared here.

Therefore, any input tax credit remained unavailed should be shown in Sep 2018 return or else it will lapse (section 16(4) of CGST Act, 2017).

8H IGST credit availed on import of goods The input tax credit as declared in Table 6E shall be auto-populated here.
8I Difference Ideally this should be nil.
8J ITC available but not availed on import of goods
8K Total ITC to be lapsed in current financial year The total input tax credit which shall lapse for the current financial year shall be computed in this row.

Part IV – Details of actual tax paid during the financial year

The payment of tax under Table 6.1 of FORM GSTR-3B may be used for filling up these details.

Part V – Particulars of transactions for the previous financial year but declared in the returns of April to September of current FY or date of filing of Annual Return for previous financial year, whichever is earlier.

If any transaction for the previous year is declared after filling GSTR 1of the Sep 2018 then it should not be shown here.

Table Form GSTR 9 Reference in GSTR 3B Instructions
10 & 11 Supplies/Tax declared/reduced through amendments Table 9A, Table 9B and Table 9C of GSTR-1 – Include the details of amendments to any of the supplies already declared in the returns of the previous financial year

– Also include the details of any outward supplies not declared in GSTR 1 of the previous financial year

– To be declared as net of credit notes or debit notes issued

12 Reversal of ITC availed during previous financial year Table 4(B) of GSTR-3B – The recipient is required to do the apportionment towards exempt supplies/ non-business purposes on an annual basis before the due date of filing the return of the September month of the following year.

– The differentials will be liable to be paid with interest (if the annual disallowance is higher) and will be eligible as credit (if the annual disallowance is lesser).

– The input tax credit on the basis of receipt voucher can’t be taken as the assesse has not received the goods and /or services [section 16(2) of CGSt Act, 2017]

13 ITC availed for the previous financial year Table 4(A) of GSTR-3B This should be equal to Table 8E.

– Contain the details of ITC for goods or services received in the previous financial year but ITC for the same was availed in the current financial year.

14 Differential Tax Amount Differential tax payable & paid on account of declaration in 10 & 11 above.

Part VI – Details of other information.

Table Form GSTR 9 Reference in GSTR Instructions
15A, 15B, 15C and 15D Refund Claimed/ Sanctioned/ Rejected/ Pending etc. – Include the details of aggregate value of refunds claimed, sanctioned, rejected and pending for processing shall be declared here.

– Not to include details of non-GST refund claims.

15E, 15F and 15G Demand of Tax Aggregate value of demands of taxes, taxes paid out of the total value of confirmed demand & demands pending recovery shall be declared here.
16A Supplies received from Composition taxpayers Table 5 of GSTR-3B Aggregate value of supplies received from composition taxpayers shall be declared here.
16B Deemed supply under Section 143 For 1st year, this will be nil as the time limit for return of inputs & capital goods is 1 year & 3 years of being sent respectively (section 141 of CGST Act, 2017).
16C Goods sent on approval basis but not returned If the goods are not returned to the principal supplier within one eighty days of such supply then it shall treated as deemed supply on completion of 180 days.
17 & 18 HSN Wise Summary of Outward/ Inward Supplies Table 12 of GSTR1 – Summary of supplies effected and received against a particular HSN code to be reported only in this table.

– It will be optional for taxpayers having annual turnover upto ₹ 1.50 Cr.

Number of digits of HSN code Number of digits of HSN code
Upto Rs. 1 crore fifty lakhs NIL
more than Rs. 1 crore fifty lakhs and upto Rs. 5 crores 2
more than Rs. 5 crores 4
19 Late Fees Payable & Paid Late fee will be payable if annual return is filed after the due date.

Conclusion: For the Outward Supplies, the government is relying on GSTR 1 while for the inward supplies liable to reverse charge, it is relying on GSTR 3B. It is important to note that in case of eligible ITC the reference is taken from GSTR 2A and not GSTR 3/3B. The Annual Return under GST is a starting point for GST Reconciliation Statement and GST Audit as all the reconciliation in the GST Audit is to be done between GST Annual Returns and Books of accounts. It thereby carries utmost importance.

Checkout difference between Form 16/16A here

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6 Comments

  1. Priyanka says:

    Thank You sir,
    But which return to be file if a client was under composition scheme for 3 month and the become regular?.
    please mail me the answer to my querry.

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