Gujarat Sales Tax Bar Association has made a Representation on Extension of Due Date For Filing of Annual Return In Form GSTR-9, 9A, 9B And Audit Report In Form GSTR-9C to Smt. Nirmala Sitharaman, Union Minister of Finance and Corporate Affairs and others. Text of the Representation is as follows:-


There is sufficient cause and need for the extension of filing of Annual Forms GSTR-9, 9A, 9B and 9C for a reasonable period of time to give justice to the correctness of returns considering the need for reconciliations state-wise. The reasons for the request are as out lined Below:

We have written to your good selves many times populating issues and possible solutions. Herein, we are presenting before your good selves the difficulties and hardship faced by the trade, industries and consultants at large due to delay in enabling GST Annual & Audit related returns, requirement to file state-wise Audit and GST reconciliations for all tax payers.

  • GST has been a bold and epic reform of the Government, introduction of which had taken a decade to reach a logical implication and naturally this introduction had its fair share of issues on trade and companies due to capacity constraints of GSTN IT infrastructure and various other issues, which required incessant changes of forms, dilution etc. Since, it was unable to introduce in lucid form, it has tumultuous impact on reconciliation of accounts for corporate and other bodies. This has continuously percolated and intruded in to time required for GST as well as other compliances and has continued a chain reaction of effect.
  • Income Tax returns filing due date for individuals, corporate were regularly extended due to aforesaid and other factors. The frequent changes in e-schema ,due date for filing income tax returns and introduction of mandatory late fees along the normal interest not helping the cause either. Moreover, the due date of filing GSTR Annual Return and Audit Report will also clash with due date of filing various Income Tax Forms and Returns. (ITR, TDS & Others Statutory Compliance)
  • GST Annual Returns and audit are expected to be completed before 30th June, 2019 and March 31st 2019 being the legitimate extended date for claim in go flost/unclaimed Input Tax Credit and inconsistencies along with the follow-ups thereto had been engaging considerable time and effort of the stakeholders.
  • To make matters worse, the GSTR Annual forms mentioned above have a consider able delay in being enabled for filing. Further, since the forms are being filed pan India, dealers may have to face considerable difficulties to achieve this herculean task within the next four weeks or so.
  • Clarification by Govt. for GSTR-9 is too late… First week of June…. That too…. Only some clarifications are received. Still there are many issues like Trans-1 Pending due to technical glitch, interest liability on net or gross, Non –Availed ITC etc etc. GSTN has not come up with solutions. Better these solutions first be given, then annual filing need to be started.
  • Department has started GSTR-9 online March 19 And offline utility in April-19… So time given is too short, Only 3 Month. Therefore, the tax payers needs and require enough  time to learn and file true and correct annual returns and audit report. In fear of late fees, the tax payer may file wrong annual returns and audit  reports. The task which has been assigned to tax payers is not only raising their anxiety levels but also becoming haunting under the pressure of heavy penalties for non-compliance. Therefore to avoid the situation date may please be extended.
  • Also, unless proper reconciliation is effected, it could be a matter for extended litigation later-on to the un reconciled returns and/or qualified Audit Reports by auditors if proceeded as it were. The reconciliation element possibly arises partly due to the niggling issues in GST and loose ends therein pursuant to delayed corrections / submissions from suppliers of goods and services for genuine reasons, onslaught of financial difficulties having cumulative bearing on compliances.
  • Without proper reconciliation and audit reports, even Revenue would face its fair share of difficulties to rely up on the inputs thrown from audit and it may lead to prolonged litigation, which could be mitigated by an appropriate extension
  • Unscheduled and frequent power cuts lasting hours left the tax payers across the country fuming. Unannounced power cuts have been plaguing the work of industry and causing losses. Power cut off is a serious issue for trade and industry and electricity is one of the important and essential requirements that serves as the backbone of every industrialized society and economy. Due to power cut the tax payers and professionals are facing lots of challenges and difficulties in making timely compliance of various statutory requirements.
  • The 2019 Indian General Election was held in seven phases from 11 April to 19 April, 2019. Since the trade and industries and professionals across the country were somewhere occupied in the process of the election, normal business and routine was badly affected.
  • The formats prescribed for GST Annual Returns and GST Audits are not only voluminous but confusing as well. The confusion all the more rises when GST Portal itself malfunction giving two information’s from one source of data.
  • The ground realities mentioned above emerge from the communications received by the professionals from the entities, companies, managements and other stakeholders and the same being sought herein for redressal through your august office.

Madam / Sirs, the problem is not that tax professionals and tax payers do not want to comply statutory requirements and file / submit annual returns and audit reports the issues lies in road map towards the annual return, which a part from being blurry is also covered under the dense fog of mental pressure anxiety and humanistic. Amidst all this forget about the simplifying the GST annual returns, officials are busy signaling that there shall be no extension of last date of filing of annual return and audit report. This is clear case of harassment, mental torture and highest level of anarchy.

We hereby appeal your good selves to consider the issues faced by the trade and industries and consultants and provide a reasonable extension for filing of annual forms GSTR-9 to 9C i.e. up to 31st December, 2019.

We would be highly thankful if you could extend the due date well in advance, which would be very useful in planning the filings for the trade and industries and practitioners meaningfully.

Full Text of the Representation in PDF Format is as follows

More Under Goods and Services Tax


  1. Jitendra Jain says:

    i want that date of GST audit for FY 2017-18 may extended for 31.12.2019. I request to our FM Madam N Sitaraman please extend the said date from 30.06.2019 to 31.12.2019 becuase up to september we face more presure for ITR

  2. JAGDISH CHAND says:

    Yes, due date to be extended. Up to 31.12.2019 for annual return .The Central Government should take into consideration for the G S T portal glitches it would be better to extend up to 31.12.2019 to identify the problems and solution to file true and fair annual returns

  3. mONU says:

    I have 118 gst firm.
    I not file any gst return upto govt not extend gstr date atleast for 3 month.
    Plz all CA, advocates and GST Practioners support me
    and not file any gst return.


  4. mONU says:

    I have 118 gst firm.
    I not file any gst return upto govt not extend gstr date atleast for 3 month.
    Plz all CA, advocates and GST Practioners support me
    and not file any gst return.

  5. NAMAN NAYÀK says:

    Its very sad on the part of the Government/ Finance Ministry for keeping such short date with no efforts to clarify the Annual Return i.e GSTR-9, 9A by keeping seminars or any such conferences on the part of the Govt…People are facing so much of difficulties as they have closed the portal for ITC Claim n etc as well.. Please extend each and everything which can be filed n claimed by the parties till 31st March, 2020..

  6. Deepak says:

    I appel to all C.A. , Advocate and GST practioners
    If Govt not extend gstr 9 due date.
    Than all C.A. , Advocate and GST practioners are not file any gst return upto those day govt not extned due date.
    As the result government extend gstr9 date.

    1. mehak says:

      The date for filing GSTR9 for year 2017-19 should be extended till 30 Sept 2019 and the linkage in GST2A with annual return and ITC break-up in input capital goods, services should not be asked for as the same is also not a part of GSTR3B return

  7. Sanjay kushwaha says:

    GSTR9 due date should be extend upto dec 2019 for f.y. 2107 -2018 and one time amendment should be allow for GSTR 1 & GSTR 3B for f.y. 2017-2018 so that we can file correct return .

  8. SIddharth says:

    Actually where we professionals are lacking in is in Unity. Either CA, Advocate or Cost Accountant. Remember the case of ITC 04 where no one has yet filled it, Govt. has no other options except extending due dates for it. Thus, we have to boycott the Whole Annual Return thing unless and until return amendment option is given and justified time and format is given by Govt. As far as professional opportunity is concerned i Think ample opportunity and revenue was there even before GST Implementation. So professionals it is time to stop this hyper tension, mental preassure and be UNITE AND TAKE ACTIONS AGAINST GOVT. If there is few defaulters Govt. can do anything. But if there so many they cant do anything.

  9. Vismita says:

    Due date should be extended bcz we have to focus on gst for 20 days .Nd ITR date is also coming govt have to change their decision about this Nd gate 9 is not easy to understand in few days. Any one has to do proper study on it.113

  10. shri says:

    Date should be extent till 31/12/2019 . As Auto populate data is of 31st may 19, we have to works again on same.Further new return Prototype is also going to be come by July 19, what we will do ….

  11. SIVALINGAM says:

    Date should be extended to 31.03.2020. Then only correctness and revenue to the Govt by way of GST is already more than the expected target. Annual return and scrutiny of accounts will have to be made only those turnover is more than 1 crore. Below 1 crore turnover exemption to be given for scrutiny and filing annual return.

  12. vswami says:

    By any reasoning, the plea for extension may have to be acceeded to. As opined in knowledgeable professiinal circles, the GST regime is in such an absolute state of flux, as to be justifiably stated to be – ‘WORK-IN-OROGRESS’ , Should that be so, how any half-boiled -baked) legiislation could be regarded to have come into effect; unless and until all problems faced with are resolved, for a successful implementation and faithful compliance ?

    The Rep., is on expected lines. Why only Guj., has chosen to ‘bell the cat’; does that by any chance imply that the rest of the states are fully geared , and on the move forward, to ‘beat the heat’ – against all ODDs, with no fall-out problems trailing behind ?!

  13. Raghunath Gadre says:

    The date for filing GSTR9 for year 2017-19 should be extended till 30 Sept 2019 and the linkage in GST2A with annual return and ITC break-up in input capital goods, services should not be asked for as the same is also not a part of GSTR3B return

  14. Manoj Kumar says:

    Yes Date should be extended till next March 2020 for FY 2017-2018 , 2018-2019, Every day we have received so many changes circular regarding amemdements/changes etc. So It should be extended till March 2020, so that user will be provide/submit correct data to departments through Annual Return. Earlier there is no editing/revision provision in data for correction. By doing that atleast 1-2 years annual data will be submitted correctly by users to departments.My humble request to extended the date of annual return till March 2020 for FY 2017-2018 & 2018-2019



  16. sathya says:

    The Central Government should take into consideration for the GST portal glitches it would be bettter to extend 2 months time to identify the problems and solution to file true and fair annual returns

  17. PRABHAKAR G says:

    Extending one week or one month is of no use. We can justify niethr GST nor I Tax under the cumulative pressure and work load. The new concept of GST audit needs comfortable environment to apply the mind and skill to give the best result. So if it is extended up to Dec 31st, one can work coolly during Oct,Nov and Dec and give the best performance.

  18. polinter says:

    It would be better to practice the due date terminology carry over the area jurisdictional officer according to their database of the area.So that with this terminology effect will be on the government post and public will be on the front and second side will be the officer ……

  19. VIPIN says:

    GST Department needs to change the due date pattern. Due date pattern shifted to local area jrudiction officer for completetion the gst formalities with their work one by one clearing the gst glitches then after gst will cover up the all glitches other wise its seem like a sinking titanic………

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