GST Annual return date has again been extended upto 30 Nov 2019 for the year 2017-18 due to low return filing status by the assesses and request from various organizations to extend the due date due to various complexities and lack of clarity in GST annual return and reconciliation format.

Different professionals, authors, speakers on the said subject are having different interpretation, views with respect to disclosure of various information in return and reconciliation statement.

GST 9 and GST 9C were first notified vide Notification no 39/2018 –Central Tax dated 4th September 2018 and Notification no 49/2018 respectively. The initial last date of filing of annual return and reconciliation statement for the year ended 2017-2018 was 31st Dec 2018.

The last date for filing of annual return and reconciliation statement was first extended upto 31st March 2019 vide Central Goods and Services Tax (Removal of Difficulties) Order, 2018 dated 11th Dec 2018.

The formats for annual return and reconciliation statement were also amended by the Govt vide Notification no 74/2018 –Central Tax dated 31st Dec 3018 and dates were extended upto 30th June 2019 vide Central Goods and Services Tax (Third Removal of Difficulties) Order, 2018 dated 31st Dec 2018.

The dates were again extended upto 31st August 2019 vide Central Goods and Services Tax (Sixth Removal of Difficulties) Order, 2019 dated 28th June 2019 and lately has been extended upto 30 Nov 2019 vide Central Goods and Services Tax (Seventh Removal of Difficulties) Order, 2019 dated 26th August 2019.

Two clarifications have been issued by the Govt on Annual return and Reconciliation by the means of press release dated 4th June 2019 and 3rd July 2019 respectively.

As per 2nd Press release dated 3rd July 2019 with respect to “Clarification regarding Annual Returns and Reconciliation Statement” it was clarified that: –

a) FORM GSTR-1 and FORM GSTR-3B serve different purposes. While, FORM GSTR-1 is an account of details of outward supplies, FORM GSTR-3B is where the summaries of all transactions are declared and payments are made. Ideally, information in FORM GSTR-1, FORM GSTR-3B and books of accounts should be synchronous and the values should match across different forms and the books of accounts. If the same does not match, there can be broadly two scenarios, either tax was not paid to the Government or tax was paid in excess. In the first case, the same shall be declared in the annual return and tax should be paid and in the latter all information may be declared in the annual return and refund (if eligible) may be applied through FORM GST RFD-01A .

b) As per Section 73 of the CGST Act if a taxpayer has not paid, short paid or has erroneously obtained/been granted refund or has wrongly availed or utilized input tax credit then before the service of a notice by any tax authority, the taxpayer may pay the amount of tax with interest. In such cases, no penalty shall be leviable on such tax payer. Therefore, in cases where some information has not been furnished in the statement of outward supplies in FORM GSTR-1 or in the regular returns in FORM GSTR-3B, such taxpayers may pay the tax with interest through FORM GST DRC-03 at any time. In fact, the annual return provides an additional opportunity for such taxpayers to declare the summary of supply against which payment of tax is made”

So as per above clarifications any additional supply may be declared in GST Annual return and tax may be paid through DRC -03 if the same has not altogether been declared in GST 3B in 2017-2018 or 2018-2019 for the year 2017-2018.

GST Annual Return consists of 6 parts. As per instructions given in Notification no 74/2018-Central Tax dated 31st Dec 2018 it is written that:-

a) Part II consists of the details of all outward supplies & advances received during the financial year for which the annual return is filed. It may be noted that all the supplies for which payment has been made through FORM GSTR-3B between July 2017 to March 2018 shall be declared in this part.

b) Part V consists of particulars of transactions for the previous financial year but paid in the FORM GSTR-3B of April to September (extended upto 31st March 2019) of current FY or date of filing of Annual Return for previous financial year (for example in the annual return for the FY 2017-18, the transactions declared in April to September 2018(extended upto 31st March 2019) for the FY 2017-18 shall be declared), whichever is earlier.

So the place at which transactions will be reported/disclosed in annual return is dependent on when the tax has been paid. If tax for the year 2017-2018 has been paid in GSTR 3B in 2017-18 same will be disclosed in Part II, if tax has been paid in 2018-19 for transactions pertaining to 2017-18 same will be disclosed in part V and if they are not at all declared same will be disclosed in Part II.

Many figures of annual return are being auto populated on the basis of summarized data of GSTR – 3B & GSTR – 1. Data in column 4 is being picked from GSTR 1 whereas data in column 9 is being picked from GSTR-3B. So in cases where tax payable as per column no 4 and as per column no 9 is not matching it means there is a difference between data filed as per GSTR 3B and GSTR 1 and has to be reconciled and these columns are therefore editable. Tax paid figures in column no 9(3) are freezed and cannot be changed.

The disclosure under various tables based on the period when it has been disclosed in the GSTR-1/3B may be understood from below table: –

*In such cases, where liability remains unpaid then such liability needs to be manually added in Table 9 and paid through Form DRC-03. It is important to note that, “tax payable” column in Table 9 has been left editable by the portal

An effort is hereby made by the means of various case studies in this article to address the various issues pertaining to outward supplies and probable solutions for it.

Default showing under Annual return” is the data which is autopoulated from GST Portal and can be altered.

“Paid as per column 9(3) of GST 9” is freezed and cannot be altered and hence not written again at the end after to be shown under Annual Return.

To be shown under Annual return” is the way in which it can be represented in GST 9

CASE 1 (This is an ideal situation where GSTR 3B,GSTR 1 & Books of Accounts are in consonance with each other with regard to Tax and Taxable Value)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 100 100 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
100
1000
100
TABLE 9
100
100
100
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)

CASE 2 (Where Supply of year 2017-2018 has been reported in GSTR 3B& GSTR 1 in 2018-2019 )

Particulars Books of Accounts GSTR 3B GSTR 1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 100 100 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
TABLE 9
TABLE 10
1000
100
TABLE 11
TABLE 14(Payable)
100
TABLE 14(Paid)
100

CASE3 (Supply has been under reported in GSTR 3B and GSTR 1 in 2017-2018 and reported in GSTR 3B and GSTR 1 of 2018-2019 and taxes paid)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 800 200 800 200
IGST 100 80 20 80 20
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST Payable
CGST Payable
SGST Payable
IGST Paid
CGST Paid
SGST Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
800
80
800
80
TABLE 9
80
80
TABLE 10
200
20
TABLE 11
TABLE 14 (Payable)
20
TABLE 14 (Paid)
20

CASE 4 (Supply of Year 2017-2018 has been reported in the year 2018-2019 with lesser value than as per books of accounts and not reported in GSTR 1 at all)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 800
IGST 100 80
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST Payable
CGST Payable
SGST Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
200
20
TABLE 9
20
TABLE 10
800
80
TABLE 11
TABLE 14 (Payable)
80
TABLE 14(Paid)
80
DRC3 (To be paid)
20

CASE 5 (Supply of year 2017-18 has not at all been reported in GSTR 3B or GSTR 1 of the year 2017-18 or 2018-19)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000
IGST 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST Paid
CGST Paid
SGST Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
100
TABLE 9
100
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)
DRC 3 (To be paid)
100

CASE 6 (Less amount reported in GSTR 3B though correct amount reported in GSTR 1 but tax not paid on balance amount)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 900 1000
IGST 100 90 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
100
1000
100
TABLE 9
90
90
100
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)
DRC 3 (To be paid)
10

CASE 7 (Less Amount reported in GSTR 3B though correct amount reported in GSTR 1 in 2017-18 and balance tax paid in GSTR 3B in the year 2018-2019)

Particulars Books of Accounts GSTR 3B GSTR 1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 900 100 1000
IGST 100 90 10 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
Payab
CGST
SGST
TABLE 4
1000
100
900
90
TABLE 9
90
90
90
TABLE 10
100
10
TABLE 11
TABLE 14 (Payable)
10
TABLE 14 (Paid)
10

CASE 8 (Less amount reported in GSTR 1 though correct amount reported in GSTR 3B in 2017-2018)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 0 900
IGST 100 100 0 90
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
Payable
CGST
SGST
TABLE 4
900
90
1000
100
TABLE 9
100
100
100
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14(Paid)

CASE 9(Excess Taxable Value and Tax amount recorded in GST 1 in year 2017-2018 though correct amount reported in GST 3B)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 0 1100
IGST 100 100 0 110
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1100
110
1000
100
TABLE 9
100
100
100
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)

CASE 10 (Exempt sales was wrongly recorded as taxable in GSTR 1 though correctly reported in GSTR 3B)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 0 1000
IGST 0 0 0 100
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
100
TABLE 9
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)

Note: Exempt Supply will be reported in column 5 of GSTR 9

CASE 11 (Excess taxable value of supply and tax being reported in GSTR 1 of 2017-18 and not reported in GSTR 3B at all )

Particulars Books of Accounts GSTR 3B GSTR 1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1200
IGST 200 300
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1200
300
1000
200
TABLE 9
200
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14(Paid)
DRC 3 (To be paid )
200

CASE 12 (Excess Tax paid in GSTR 3B in year 2017-2018 adjusted in 2018-19 and recorded in GSTR 1 of 2017-2018 correctly)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 200 300 (100) 200
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
200
1000
300
TABLE 9
300
300
300
TABLE 10
TABLE 11
100
TABLE 14 (Payable)
-100
TABLE 14 (Paid)
-100

CASE 13 (Taxable Value of Supply and Tax reported incorrectly in GSTR 1 and GSTR 3B of 2017-2018 resulting in overpayment of tax in 2017-18 corrected in 2018-2019)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1100 (100) 900 100
IGST 200 110 (10) 90 10
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
900
90
1100
110
TABLE 9
110
110
110
TABLE 10
TABLE 11
100
10
TABLE 14 (Payable)
-10
TABLE 14 (Paid)
-10

CASE 14 (Taxes shown wrongly in GSTR 1 though shown correctly in GSTR  3B)

Particulars Books of Accounts GSTR 3B GSTR 1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 30 30
CGST 30 30 45
SGST 30 30 45

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
45
45
1000
30
30
30
TABLE 9
30
30
30
30
30
30
30
30
30
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)

CASE 15 (Taxes shown correctly in GSTR 1 but shown incorrectly in GST3B of 2017-2018 corrected in 2018-2019)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 30 30 30
CGST 30 45 (15) 30
SGST 30 45 (15) 30

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
30
30
30
1000
0
45
45
TABLE 9
0
45
45
0
45
45
0
45
45
TABLE 10
30
TABLE 11
-15
-15
TABLE 14 (Payable)
30
-15
-15
TABLE 14 (Paid)
30
-15
-15

CASE 16 (Taxes shown correctly in GSTR 1 in 2017-18 but shown incorrectly in GSTR 3B and not corrected)

Particulars Books of Accounts GSTR 3B GSTR 1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1000 1000
IGST 30 30
CGST 30 45 30
SGST 30 45 30

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
30
30
30
1000
45
45
TABLE 9
0
45
45
0
45
45
0
45
45
TABLE 10
30
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)
DRC 3 (To be Paid)
30

Note In this case excess tax has been paid which has not been adjusted so here lies a possibility of refund of Rs 15 each in CGST and SGST as per Section 54 of CGST Act 2017.

CASE 17 (Excess Tax Paid in 3B in the year 2017-2018  and not adjusted)

Particulars Books of Accounts GST3B GST1
Year 2017-18 2017-18 2018-19 2017-18 2018-19
Taxable Value 1000 1100 1000
IGST 200 220 200
CGST
SGST

Default Showing Under Annual Return
Paid as per column 9(3) of GST 9
To be shown Under Annual return
Particulars
Taxable Value
IGST
Payable
CGST
Payable
SGST
Payable
IGST
Paid
CGST
Paid
SGST
Paid
Taxable Value
IGST
CGST
SGST
TABLE 4
1000
200
1000
200
TABLE 9
220
220
200
TABLE 10
TABLE 11
TABLE 14 (Payable)
TABLE 14 (Paid)

Note: In this case excess tax has been paid which has not been adjusted so here lies a possibility of refund  of Rs 20 in IGST as per Section 54 of CGST Act 2017.

Author Bio

Qualification: CA in Job / Business
Company: N/A
Location: BHOPAL, Madhya Pradesh, IN
Member Since: 10 Aug 2019 | Total Posts: 4
I am CA Piyush Gupta having an experience of more than 10 years in the field of Indirect Tax,Accounts,Internal Audit etc.Presently working on the post of Deputy Manager in a PSU . View Full Profile

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5 Comments

  1. L.R.Vishnuram says:

    Case Studies under GST Annual Return :
    This is a very good article on the above subject and dealt in detail in 17 Simulated Situations which are practical in nature.
    The Readers can understand the complicated subject very easily by seeing the numerical examples.
    Congratulations goes to the Author of the Article CA.Piyush.

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