The Annual GST Return is an important document as the facts/ figures/ data disclosed in this document carries various implications. Any incorrect information may attract serious amount of litigations and disputes with the concerned tax authorities and accordingly the assesse may face various hardships.
All big and small firms have already started gearing up for the GST Audit and filing of GST return by 30th June 2019. Hence the last date to file GST Annual return for July 2017- March 2018 is 30th June 2019.
The different types of GST returns which are applicable to various assesses are summarized as follows-
|GST Return Form||Assessee|
|GSTR 9||Every registered person, other than an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person|
|GSTR 9A||Person paying the tax under Sec 10 i.e. a composition dealer|
|GSTR 9B||Electronic commerce operators who have to pay tax at source|
|GSTR 9C||Every registered person whose aggregate turnover during a financial year exceeds two crore rupees shall get his accounts audited as specified under sub-section (5) of section 35 and he shall furnish a copy of audited annual accounts and a reconciliation statement|
Challenges being faced by Assesses while filing the Annual Return- GSTR 9
The Government while devising the format of GSTR 9 must have taken adequate care for including all the necessary details and its proper liking with the other two returns from which the information etc will be clubbed and included in the GSTR 9 format.
However there are certain grey areas which have not been addressed in the form of Annual Return. The same have been reproduced as below-
1. ITC details-Bifurcated details of ITC availed are required as Inputs and Input Services and Capital goods
2. Reporting Transactions-The reporting of the amended transactions which are relevant to FY 2017-18 filed in the 6 monthly returns pertaining to the period April-Sept of the current FY or upto the filing of the return of FY 2017-18 i.e. 31st Dec 2018 whichever is earlier.
3. HSN details-The details w.r.t. to the HSN of the inward supplies was not required while filing monthly GSTR 3B, however the HSN wise detail of the inward supplies is required in the Annual return GSTR 9.
4. Reporting of HSNs-Restriction on the reporting of the HSN wise details i.e.the summary is restricted only to those HSN codes wherein such HSN codes accounts for atleast 10% of the total summary of inward supplies.
5. Gaps in the financial information vs Annual Return-The disagreements in the annual return as per the books of accounts and GST data filed during the financial year is also a matter of concern. There is an option for the assesee that either the value of the goods can be declared as per the books or as per the returns already filed by the assesee.
6. Lack of updation of data GSTR 2A on the GST Portal appearing in Table A of GSTR 9
7. Input reversals done in GSTR 3B are shown as utilisation of Input Tax Credit in auto populated table 9. This field is also not editable
8. Table 4 of GSTR9 asks for details of advances, inward and outward supplies made during the financial year on which tax is payable. This data is auto-populated as per GSTR1 filed. However, if some sales are not reported in GSTR1 but tax is already paid through GSTR3B then where to report it is not clarified
9. Absence of any column for IGST on imports paid but goods still lying Bonded Warehouse in the table 8 of the return wherein details of ITC and other related information is to be mentioned
10. The adjustments / amendments upto Sept 2018 are to be reported, but the date has already been extended till March 2019 but there is np such amendment made in the forms.
11. Manual editing cannot be done for the following fields in GSTR 9
– Table no 6 A- Total amount of input tax credit availed through GSTR 3B
– Table no 8 A- ITC as per GSTR 2A
– Table no 9- Details of tax paid except tax payable column
Addressing these challenges
One must keep in mind the following essential steps and scrutinises all this information before filing of Annual Return
√ Reconciliation of the books of accounts and tax invoices issued since inception of GST in July 2017 till March 2018
√ The above reconciliation should match with the annual turnover declared by the businessmen in their audited financial statements.
√ Matching of the stock transfers in between the units and branches of the company with the books of accounts
√ E way bill data should be matched with the tax invoices issued since inception of GST i.e. July 2017 till March 2018.
√ Proper and correct availment of Input tax Credit should be ensured.
√ The purchase and service invoices should be accounted for properly
√ The purchase data by the suppliers should have been uploaded by the suppliers properly which will be reflected in GSTR 2A form
√ Quarterly and monthly reconciliation of all the GST Returns with the books of accounts to avoid any disparity.
√ Input Tax Credit should have been paid only on such invoices on which payment to suppliers has been made within 180 days of the invoices
√ Relevant and applicable provisions of Reverse Charge Mechanism should also be taken into account
Challenges being faced by Assesses while filing the Annual Return- GSTR 9 C
1. Having Bifurcated details of Books of Accounts for each GSTIN-this clause is applicable if the assesee is operating from multiple locations
2. Details of the Input Tax Credit, Expense head wise- All the expenses mentioned in the audit report must be listed in a statement containing basic value, Input Tax Credit, but that also for each GSTIN.
3. Preparing the statement of Outward Supply –invoice wise- the next challenge for the assesse is to have a proper reconciled detail of the outward supply as shown in the books of accounts and in the returns already filed
4. Identifying the reasons of the differences-The most difficult part of this exercise is the identification of the differences arising in the figures of the Total Turnover , Taxable Turnover & ITC and identification of the reasons thereof