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Tax Bar Association, Guwahati has made a request to Hon’ble Union Finance Minister for extension of due date for filing of GST Annual Return Forms GSTR 9, 9A & 9C for  the year 2018-19. Full Text of the Representation is as follows:-

Dated: September 27, 2020


Hon’ble Finance Minister
Govt. of India
New Delhi

Respected Madam,

Sub: Request for extension of due date for filing of GST Annual Return Forms GSTR 9, 9A & 9C for  the year 2018-19.

Tax Bar Association, Guwahati is a prestigious professional association having membership strength of 450 members consisting of Chartered Accountants, Company Secretaries, Cost Accountants, Advocates and Tax Consultants.

Giving prompt relaxation from return and tax payment due to outbreak of COVID-19 by various notifications and circulars is a welcome step in the right direction. However, due to continuous pandemic situation in the country we have identified a few issues which need immediate attention/ relief.

Due Date


The relaxation due to Covid-19 includes extension of due date of filling Annual return and audit report for the year 2018-19 in GSTR-9 & GSTR-9C upto 30th Sept, 2020. The said extension was given in the month of March, 2020 with an expectation that COVID-19 pandemic situation will improve and normalcy will return by the end of June, 2020 when the Hon’ble Prime Minister had declared 21 days lockdown, but unfortunately the COVID-19 pandemic is yet to be over and most of the offices are either partially open or are not open or are working from home. People are struggling for survival. In the state of Assam also lockdown has been withdrawn from 4th Sept, 2020 only. However still we could see daily jump in affected people requiring home or institutional quarantine or hospitalisation. In the present circumstances, it is almost impossible without full operation of business office, consultants/CA office and availability of employees to file the Annual Return and audit report under the GST Act within the extended due date of 30th Sep 2020.

Thus, we request you to kindly extend the due date of filling of GST Annual return for the year 2018-19 to 31st March 2021.

B) Clarification on Filling of GSTR-9 & GSTR-9C

The present GST Annual return and Audit report form GSTR-9 & GSTR-9C which was introduced for the first time for the year 2017-18. During that time lot of confusions were there and has also created lot of hue and cry. Finally, those issues were resolved by way of various notification, clarifications, press release etc.

Similar situation is in being faced again while finalisation of Annual Return and Audit Report for the year 2018-19. The issues which need clarification are as follows:

a) Where to Report Input Tax Credit of 2017-18 claimed in GSTR-3B of 2008-19?

b) Where to Report Input Tax Credit reversal 2017-18 done in GSTR-3B of 2008-19?

c) Where too Report Out Put Tax of 2017-18 reported and paid through GSTR-3B of 2018-19?

d) Where to report RCM of 2017-18 reported in GSTR-3B of 2018-19?

e) How to report RCM of 2018-19 paid through GSTR-3B of 2019-20?

f) How to reconcile/report difference reported in 8D of 2017-18 after considering difference reported in 8D of 2018-19?

g) How and where to report ITC of invoices dated 17-18 but accounted for in books and claimed in 2018-19 on receipt of goods as per provision of Sec 16?

Thus, we request you to kindly issue suitable clarifications in respect of the points listed above so that error-free filing can be done.

For Tax Bar Association

CA. Gopal Singhania
Ph : 93650-09126; 98640-95646

CA. Bikash Agarwala
Indirect Taxes Committee Chairman
Ph : 94350-64691

Copy to :

1) Prime Minister’s Office, New Delhi

2) Hon’ble Minister of State for Finance, Govt. of India, New Delhi

3) The Revenue Secretary, Govt. of India, New Delhi

4) The Dept. of Revenue, Ministry of Finance, Govt. of India, New Delhi


6) GST Council


Download Full Text in PDF

Also Read:-

S. No. Dated Made by Link to View the Representation
1. 27/09/2020 Tax Bar Association, Guwahati Extend due date for filing GSTR 9, 9A & 9C for year 2018-19
2. 19/09/2020 Independent Tax Research Analysis Association Relax GST Annual Return & Audit dates for FY 2018-19
3. 19/09/2020 Confederation of GST Professionals and Industries Extend Implementation of E-Invoicing to April 1, 2021
4. 17/09/2020 Confederation of GST Professionals and Industries Extend due date for GSTR 9 & 9C of Financial Year 2018-19
5. 16/09/2020 Baroda Tax Bar Association Request to extend due date of GSTR 9 & 9C for F.Y. 2018-19
6. 10/09/2020 The Institute of Chartered Accountants of India Representation on difficulties in filing GSTR 9 for 2018-19
7. 10/09/2020 Institute of Chartered Accountants of India Permit availment of ITC under GST pertaining to FY 2019-20: ICAI
8. 10/09/2020 Institute of Chartered Accountants of India Request to devise mechanism to receive part payment of GST
9. 10/09/2020 The Institute of Chartered Accountants of India Extend due dates of filing GST Annual return & Audit Report
10. 27/09/2020 Karnataka State Chartered Accountants Association Extend due date for filing GSTR9 & GSTR9C for FY 2018-19
11. 24/09/2020 Bombay Chartered Accountants’ Society Extend dates for various provisions under GST: BCAS
12. 14/08/2020 C.V.O. Chartered & Cost Accountants’ Association (CVOCA) Representation on hardship under GST Laws on account of pandemic
13. 07/09/2020 C.V.O. Chartered & Cost Accountants’ Association (CVOCA) Representation on 7 GST issues & hardships faced by taxpayers
14. 10/09/2020 National Association of Tax Professional (Haryana) Extend Filing Date of Annual GST returns GSTR-9 & GSTR-9C
15. 24/08/2020 The Institute of Cost Accountants of India Request to extend due date of filing of GSTR 9 & GSTR 9C
16. 29/09/2020 Ahilya Chamber of Commerce and Industry Extend ITC availment, GSTR-9 & 9C Due dates till 31.03.2021

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  1. Rangrao Pandurang mirajkar says:

    Sir gst 3b late fee 500 rs from July 17 to August 2020 extended hui kya agr nahi hui tho extended honi chye kyunki July 2020 Maharashtra me har yera me Lockdown hua tha aur covid ke patient bad chuke ye

  2. Kumar p Nair says:

    With monthly retuns due for last 3 months due by 01-10-20 the Annual Returns for FY 2018-19 be extended on compassionate grounds. PM & FM we expect along with GST COUNCIL will adopt unanimously the steps to extend dates to helping entrepreneurs survive the existing crisis arising out of the pandemic

  3. Kumar p Nair says:

    When total lockdown has affected entrepreneurs so severely that the shutters were down for a couple of months: and following phsse by phase lift of lockdown there is a vitual threat of lockdown in COVID affected areas. Hence with human beings struggling betwren life and livelyhood-its unfortunate that Annual Returns are hanging like domicile sword. Hope our FM &PM view the request to give time to file AR for FY2018- 19

  4. Gourav Kumar Mishra says:

    We agreed with the content asked and query. It is really bad situation and employee also demotivated by salary, covid -19 pandemic, huge tension going on with employee. Really need extension at priority basis.

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