During filling & filing of GSTR 9C it was found that there is an error file generated by GSTN when Digitally Signed GSTR 9C is up-loaded and error is reflecting at PT III (9) at row Q & P – by saying “The amount paid by you mentioned at “Q” is not matching with amount reported by you in GSTR 9. Similar error reflected at “R” also.

After a long R & D it was found that amount of Tax paid as filled by assesse/CAs under Part III (9) – Q – Total amount paid as declared in Annual Return (GSTR 9) – is actually comparing by utility of GSTR 9C with the value filled in GSTR 9 – in Part IV Sr. No. 9 A, B & C and any adjustment in Part V Sr. No.10 & 11. (Please do not consider row 13 it is without RCM).

But what is important here when you fill PART III(9) of GSTR 9C then it asked to fill Interest, Late Fee,  Penalty at L, M & N respectively but when it compares from GSTR 9 in Part IV it does not include Interest, Penalty etc. therefore an error arises while submitting 9C at portal.

Therefore, at the time of giving figures in GSTR 9C paid amount fill only IGST + CSGT + SGST + Cess if any and do not include late fee/penalty etc. so that your figure will be matched and form GSTR 9C will be processed.

Now, what will happen when you fill figures without Late fee etc. in Q a difference will arrive at R – as Un-reconciled payment (Q-P) equal to Penalty etc. this will be suitable answered in Part III (10) by Auditors –

Suggestive Language of Note: “The difference arises due to Interest, Late Fee, Penalty shown at Part III -9 l, M & N where Late Fee etc. is paid by client but in GSTR 9 Part IV Sr. No.9 A, B & C it is not included. The late fee has already been paid therefore no difference of Tax is payable.”

I hope this will help you. For any confusion you can revert to me.

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Qualification: CA in Practice
Company: RAJIV NIGAM & ASSOCIATES
Location: NEW DELHI AND NOIDA, New Delhi, IN
Member Since: 17 Jul 2017 | Total Posts: 26
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3 Comments

  1. sumaiya daruwala says:

    Sir as explained above partIII(9) of 9C column Q take the payable value of 9pt IV of gstr 9,then it does not reflect the difference ( payable).whether it requires auditor comment?suppose i have 100000 rs net sales and2500,2500 as my sgsgt and cgst same has alredy shown in 3b and gstr1.but reverse charge is not shown in 3B say 20000 @5% 1000,sgst and cgst1000 .Now i will have to change my payable from 2500 to 3500 in gstr9 column 9.if in audit then same 3500 will appear in column p of part III(9),then how and where to show difference as Pand Q become similar.
    Thanks alot in advance for resolving my issue

  2. RAJIV NIGAM says:

    One more thing is very important to note that the amount is matched in GSTR 9C with 9 in case of amount paid as GST with Amount Payable – given at Part IV No. 9 “Details of Tax Paid as declared in returns filed during the financial Year” at “Tax Payable” column not at “Paid” column.

    The idea behind it if anything is payable and if you have not paid in returns then at the time of filing GSTR 3B it will not accept or any liability will be paid by DRC 03. (Also in those cases where Audit is not required).

    Further, GSTR 9 is only a summary of GSTR 1 & 3B filed during the year 2017-18. It has nothing to do with liability as per books.

    Now question arises why I am explaining all these because if you adjusted your findings of Books at GSTR 9 level at “Payable Side” (increase or decrease) then at Part IV 9 it will be created a difference with payment and no option at GSTR 9 level for payment on “arises difference” treatment is given.

    So at suo moto you can deposit your liability if, Audit is not required, and then at later department enquiry you can explain them that liability has already been deposited.

    If audit is required then this difference must be reported at Part III (9) at sub total P and report difference here and then deposit the same in PT III (11) as “Additional Amount Payable but not paid”.

    I hope this will help to resolve further problems faced by clients/CAs etc.

  3. RAJIV NIGAM says:

    One more thing is very important to note that the amount is matched in GSTR 9C with 9 in case of amount paid as GST with Amount Payable – given at Part IV No. 9 “Details of Tax Paid as declared in returns filed during the financial Year” at “Tax Payable” column not at “Paid” column.
    The idea behind it if anything is payable and if you have not paid in returns then at the time of filing GSTR 3B it will not accept or any liability will be paid by DRC 03. (Also in those cases where Audit is not required).
    Further, GSTR 9 is only a summary of GSTR 1 & 3B filed during the year 2017-18. It has nothing to do with liability as per books.
    Now question arises why I am explaining all these because if you adjusted your findings of Books at GSTR 9 level at “Payable Side” (increase or decrease) then at Part IV 9 it will be created a difference with payment and no option at GSTR 9 level for payment on “arises difference” treatment is given. So at suo moto you can deposit your liability if, Audit is not required.
    If audit is required then this difference must be reported at Part III (9) at sub total P and report difference here and then deposit the same in PT III (11) as “Additional Amount Payable but not paid”.

    I hope this will help to resolve further problems faced by clients/CAs etc.

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