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
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.
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 In the state of Assam also lockdown has been withdrawn from 4th Sept, 2020 only.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.
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
|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|