Recent Changes in GSTR form 9 & Form GSTR 9C

Audit by Tax Authorities under Section 65

The Commissioner or any officer authorised by him, by way of a general or a specific order, may now undertake audit of any registered person for part of financial year also

Revision ( Rule 109B inserted)

Where the Revisional Authority decides to pass an order in revision under section 108 which is likely to affect the person adversely, the Revisional Authority is required to serve on him a notice in FORM GST‐RVN‐01 and shall give him a reasonable opportunity of being heard and the Revisional Authority shall, along with its order under section 108(1), issue a summary of the order in FORM GST‐APL‐04 clearly indicating the final amount of demand confirmed

Details to be furnished in Statement GST‐ITC‐04- Rule 45(3)

Now details of the challans in respect of goods sent from one job worker to another during a quarter not required to be included in FORM GST ITC‐04 furnished for that period.

Rule 138E of CGST Rules inserted; Restriction on Furnishing PART‐A of Form GST‐EWB‐01 [Effective date to be notified later]

Any person (including a consignor, consignee, transporter, an e‐commerce operator or a courier agency) shall not be allowed to furnish the information in PART A of FORM GST EWB‐01 in respect of a registered person, whether as a supplier or a recipient, who,—

has not furnished the returns for two consecutive tax periods or consecutive two months as the case may be

Major Changes in Annual Return Forms GSTR‐9 and GSTR‐9A

The words “as declared in returns filed during the year” has been substituted with “made during the year” in headings wherever appearing. Accordingly, the Taxpayer is required to disclose the figures as per Accounts even though not declared in Return Forms GSTR‐3B and GSTR‐1.

The Instructions given in the Form requires that all returns viz. Form GSTR‐1 and Form GSTR‐3B or Form GSTR‐4, as applicable, for the FY 2017‐18 are filed before filing this return.

The Instructions also states that Additional Liability for the FY 2017‐18 not declared in Form GSTR‐1 and Form GSTR‐3B or Form GSTR‐4 may be declared in this return. However, taxpayers cannot claim input tax credit unclaimed during FY 2017‐18 through this return.

Major Changes in Annual Return Forms GSTR‐9 and GSTR‐9A

Taxpayers will have an option to pay any additional liability declared in this form, through FORM DRC‐03 and for the same, Taxpayers shall select “Annual Return” in the drop down provided in Form DRC‐03 and the taxpayer can pay such liability through electronic cash ledger only.

HSN wise summary of inward supplies in Form GSTR‐9 are required to be declared only for those inward supplies which in value independently account for 10 % or more of the total value of inward supplies.

Major Changes in Annual Return Forms GSTR‐9 and GSTR‐9A

Part II consists of the details of all outward supplies and advances received during the FY 2017‐18 for which payment has been made through FORM GSTR‐3B between July 2017 to March 2018 and particulars of transactions for the FY 2017‐18 but paid in the FORM GSTR‐3B of April to September 2018 or date of filing of Annual Return for previous financial year, whichever is earlier, will be reported in Part V.

Issue of Tax Invoice, Bill of Supply etc. without signature or digital signature; Rule 46, 49, 54(2) and 54(4) amended

Signature or digital signature of the supplier or his authorised representative shall not be required in the case of issuance of an electronic invoice, bill of supply, consolidated tax invoice or any other document in lieu thereof by insurer or a banking company or a financial institution, ticket by passenger transportation service provider in accordance with the provisions of the Information Technology Act, 2000

Quick capture of changes in GSTR Form 9 and 9C in the revised form vide Notification 74/2018-Central Tax, Dated: 31.12.2018

Vide notification 74/2018-Central Tax, dt. 31-12-2018, the Government had amended the Annual return of form GSTR 9 and reconciliation statement of form GSTR 9C which was originally notified vide 39/2018-Central.Tax dt 04.09.2018 and. 49/2018–Central Tax dt 13^th September 2018 respectively

By now most of the corporates or bigger assesses must have been ready with the forms duly filled in the earlier version for uploading. This article would help such persons to re-visit only to those tables which had undergone changes saving considerable time and efforts.

Quick capture of changes in Form and instructions.

Form 9 – in 7 tables and 11 in instructions

Form 9C- in 1 table and 3 in instructions

Form 9

Pt. II

Table 4. “Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the financial year” is replaced with “Details of advances, inward and outward supplies made during the financial year on which tax is payable”

Table 5.” Details of Outward supplies on which tax is not payable as declared in returns filed during the financial year” is replaced with “Details of Outward supplies made during the financial year on which tax is not payable”

Table 5 F “Non-GST supply (includes ‘no supply ‘)”

Pt.III – Table 6. “Details of ITC as declared in returns filed during the financial year” is replaced with “Details of ITC availed during the financial year”

Table 7 “Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year” is replaced with “Details of ITC Reversed and Ineligible ITC for the financial year”

Table 8 E” ITC available but not availed (out of D)” is replaced with “ITC available but not availed”

Table 8 F” ITC available but ineligible (out of D)” is replaced with “ITC available but ineligible”

Form-9 – Instructions

Sl. No.2 The underlined text is added

“It is mandatory to file all your FORM GSTR-1 and FORM GSTR-3B for the FY 2017- 18 before filing this return. The details for the period between July 2017 to March 2018 are to be provided in this return”

Sl no 4 – “Part II consists of the details of all outward supplies & advances received during the financial year for which the annual return is filed. 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. The instructions to fill Part II are as follows: is replaced with

‘“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. The instructions to fill Part II are as follows: in returns filed during the

In Table 5D,5E and 5F against Sl. No 4 – the underlined portion is reworded  

“Aggregate value of exempted, Nil Rated and Non-GST supplies shall be declared here. Table 8 of FORM GSTR-1 may be used for filling up these details. The value of ―”no supply” shall be declared under Non-GST supply (5F).”

In Table 6C against sl.no,5, instead of Table 4(A)(5) of FORM GSTR-3B is replaced with the underlined text

“Aggregate value of input tax credit availed on all inward supplies received from unregistered persons (other than import of services) on which tax is payable on reverse charge basis shall be declared here. It may be noted that the total ITC availed is to be classified as ITC on inputs, capital goods and input services. Table 4(A)(3) of FORM GSTR-3B may be used for filling up these details”

In Table 7A to 7H against Sl.no.5 the underlined text is included in the revised format

“Details of input tax credit reversed due to ineligibility or reversals required under rule 37, 39, 42 and 43 of the CGST Rules, 2017 shall be declared here. This column should also contain details of any input tax credit reversed under section 17(5) of the CGST Act, 2017 and details of ineligible transition credit claimed under FORM GST TRAN-I or FORM GST TRAN-II and then subsequently reversed. Table 4(B) of FORM GSTR-3B may be used for filling up these details. Any ITC reversed through FORM ITC -03 shall be declared in 7H. If the amount stated in Table 4D of FORM GSTR-3B was not included in table 4A of FORM GSTR-3B, then no entry should be made in table 7E of FORM GSTR-9. However, if amount mentioned in table 4D of FORM GSTR-3B was included in table 4A of FORM GSTR-3B, then entry will come in 7E of FORM GSTR-9.”

In Table 8A against Sl.no.5, The text “received during “is replaced with the underlined text.

“The total credit available for inwards supplies (other than imports and inwards supplies liable to reverse charge but includes services received from SEZs) pertaining to FY 2017-18 and reflected in FORM GSTR-2A (table 3 & 5 only) shall be 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 FORM GSTR-1.”

Table 8D against Sl.no.5 is an insertion

“Aggregate value of the input tax credit which was available in FORM GSTR2A (table 3 & 5 only) but not availed in FORM GSTR-3B returns shall be computed based on values of 8A, 8B and 8C. However, there may be circumstances where the credit availed in FORM GSTR-3B was greater than the credit available in FORM GSTR-2A. In such cases, the value in row 8D shall be negative”

Table 8 E & 8F against Sl.no.5 “Aggregate value of the input tax credit which was available in FORM GSTR2A (table 3 & 5 only) but not availed in any of the FORM GSTR-3B returns shall be declared here. The credit shall be classified as credit which was available and not availed or the credit was not availed as the same was ineligible. The sum total of both the rows should be equal to difference in 8D.” is replaced with

Table 8E & 8F against Sl.no.5 – the earlier version “Aggregate value of the input tax credit which was available in FORM GSTR-2A (table 3 & 5 only) but not availed in any of the FORM GSTR-3B returns shall be declared here. The credit shall be classified as credit which was available and not availed or the credit was not availed as the same was ineligible. The sum total of both the rows should be equal to difference in 8D” is replaced with “The credit which was available and not availed in FORM GSTR-3B and the credit was not availed in FORM GSTR-3B as the same was ineligible shall be declared here. Ideally, if 8D is positive, the sum of 8E and 8F shall be equal to 8D”

Table 13 against Sl.no.7 -The underlined text is added in the revised form “Details of ITC for goods or services received in the previous financial year but ITC for the same was availed in returns filed for the months of April to September of the current financial year or date of filing of Annual Return for the previous financial year whichever is earlier shall be declared here. Table 4(A) of FORM GSTR-3B may be used for filling up these details. However, any ITC which was reversed in the FY 2017-18 as per second proviso to subsection (2) of section 16 but was reclaimed in FY 2018-19, the details of such ITC reclaimed shall be furnished in the annual return for FY 2018-19

Table 17 & 18 against sl.no. 8 – The underlined text is added in the revised form “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 up to ₹ 1.50 Cr. It will be mandatory to report HSN code at two digits level for taxpayers having annual turnover in the preceding year above ₹ 1.50 Cr but up to ₹ 5.00 Cr and at four digits ‘level for taxpayers having annual turnover above ₹ 5.00 Cr. UQC details to be furnished only for supply of goods. Quantity is to be reported net of returns. Table 12 of FORM GSTR1 may be used for filling up details in Table 17. It may be noted that this summary details are required to be declared only for those inward supplies which in value independently account for 10 % or more of the total value of inward supplies.”

At the end of the form, the following text is added in the new reversion

“9. Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ―Annual Return‖ in the drop down provided in FORM DRC-03. It may be noted that such liability can be paid through electronic cash ledger only.”

Form9-C

There is no change in the revised form except, at the end of form 9C the following insertion was made in the revised version

“Verification of registered person: I hereby solemnly affirm and declare that I am uploading the reconciliation statement in FORM GSTR-9C prepared and duly signed by the Auditor and nothing has been tampered or altered by me in the statement. I am also uploading other statements, as applicable, including financial statement, profit and loss account and balance sheet etc.

Signature

Place:

Date:

Name of Authorized Signatory
Designation/status”

Form 9C – Instructions

Sl.no 2, the underlined text is the insertion in the revised form “It is mandatory to file all your FORM GSTR-1, FORM GSTR-3B and FORM GSTR – 9 for the FY 2017-18 before filing this return. The details for the period between July 2017 to March 2018 are to be provided in this statement for the financial year 2017-18. The reconciliation statement is to be filed for every GSTIN separately.

Table 7F against Sl.no.4, “Taxable turnover as declared in Table (4N – 4G) + (10-11) of the Annual Return (GSTR9) shall be declared here” has replaced ““Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall be declared here.” of earlier version

Table 8 against Sl.no.4, “Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ―Reconciliation Statement‖ in the drop down provided in FORM DRC-03. It may be noted that such liability shall be paid through electronic cash ledger only.” has replaced “Towards, the end of the reconciliation statement taxpayers shall be given an option to pay their taxes as recommended by the auditor.” of earlier version