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 –
|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|
As the name itself states under part I of form GSTR 9 following basic details are to be provided –
1. Financial Year
3. Legal Name, and
4. Trade Name (if any)
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
|– 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.
|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.
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)
– 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.
|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).
|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.|
|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.|
The payment of tax under Table 6.1 of FORM GSTR-3B may be used for filling up these details.
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.|
|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.
|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.