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The Chamber of Tax Consultants has made a representation to Smt. Nirmala Sitharaman Union Minister of Finance, Government of India & Chairperson – GST Council requesting  extension of due date for filing of GST Annual Return & Reconciliation Statement (form GSTR -9, 9A and 9C) for F.Y. 2017-18.

Chamber of Tax Consultants

17th August 2019

Smt. Nirmala Sitharaman
Union Minister of Finance, Government of India &
Chairperson – GST Council
134, North Block, New Delhi – 110 001

The Office of GST Council Secretariat,
5th Floor, Tower II, Jeevan Bharat Building, Janpath Road,
Connaught Place, New Delhi – 110 001
Tel: 011-23762656

Sub: Request for extension of due date for filing of GST Annual Return & Reconciliation Statement (form GSTR -9, 9A and 9C) for F.Y. 2017-18

Dear Madam/Sir,

The Chamber of Tax Consultants (CTC), Mumbai was established in 1926. CTC is one of the oldest voluntary non-profit making organizations in Mumbai – in its 93rd year – formed with the object of educating and updating its members on Tax and other Laws. It has robust membership strength of about 4000 professionals, comprising Advocates, Chartered Accountants and Tax Practitioners. The Chamber also has created a niche with the government and other regulatory agencies. It is the one of the leading institution for making effective representation with respect to Income Tax and Allied laws. It acts as catalyst for bring out necessary change both from the perspective of Government as well as Tax payers.

The Chamber sincerely believes that GST is in the best interest of the nation and the tax paying community at large. However, online technological infrastructure required for smooth implementation of GST is lagging behind and is resulting into hardship to the taxpayers in complying with the provisions of law.

The GST Council had extended the due date of filing GST Annual Return and Reconciliation statement, namely GSTR-9, 9A and 9C for the period 1st July 2017 to 31st March 2018, from 30th June 2019 to 31st August 2019 vide Order No. 6/2019-Central Tax dated 28 June 2019.

Your good office will appreciate that till date very few taxpayers have been able to file their GST Annual Returns (Form GSTR 9, 9A) and GST Reconciliation Statement (Form GSTR 9C) for FY 2017-18. This itself indicates that tax payers are facing bonafide issues and hardships in filing the said forms.

In this context, we would like to appraise your good office with the following points which necessitate the extension of due date for filing of GST Annual Returns for F.Y. 2017-18 :


1.1. We would like to highlight that the GST portal technical issues, due to which the extension was granted earlier are still persistent. Some of the instances are as follows:

a. In many instances, the Json file required for offline preparation of GSTR – 9 is taking
more than 1 hour for generation, though site states that it would take 20 minutes.

b. There are lots of issues faced by a taxpayer while downloading Json file from the GST portal and then uploading the same in offline utility tool. Many errors such as ‘Download in process. Please check after 20 mins’, ‘File generation is in progress, please try again after some time’ are being faced.

c. The Json file of error report generated post uploading of GSTR – 9C does not provide any error details. Since the system is unable to provide the details of the error, the taxpayer is not able to identify the exact reason as to why the Json file is not getting processed successfully.

d. The digital signature of auditor who is certifying the reconciliation in GSTR – 9C is not getting signed. It was observed that one of the solutions for error was that of downloading Note pad++ and thereafter making manual change in utility folder of GSTR-9C. We request you to kindly address the issue by way of either updating the utility or publicizing technical options in case of difficulties in digitally signing the file.


2.1. We would like to highlight that there have been significant clarifications in the form of press releases, GSTN advisory notes which have been issued in recent past which clarify certain positions qua filing of GSTR 9 & GSTR 9C. Few examples are narrated below:

– Clarification regarding Annual Returns and Reconciliation Statement Posted On: 03 JUL 2019 5:03PM by PIB Delhi

– Advisory note on filing of GSTR-9 by GSTN in June 2019

– Advisory note on filing of GSTR-9C by GSTN in June 2019

2.2. Thus, in such an event of constant clarifications, the auditors and tax payers would require some additional time to arrive at a conclusion with respect to correct reporting in GSTR 9 & GSTR 9C. Having made available latest clarification on 3rd July, industry at large is of the opinion that a conclusive GST audit cannot be accomplished till 31st August 2019.


3.1. It was expected that the data to be filled in Annual Returns would flow from monthly returns filed by taxpayer i.e. GSTR-3B and GSTR-1. Given below is a list of details which the taxpayers had not compiled while filing monthly returns but are required to compile at the time of filing Annual Returns:

a. Details of ITC availed as declared in returns filed during the financial year (GSTR 9, Para 6)

While filing monthly GST 3B returns, taxpayer was required to provide details of ITC availed in para 4 with following break up:

(A) ITC Available

(1) Import of Goods

(2) Import of Services

(3) Inward supplies liable to reverse charge

(4) Inward supplies from ISD

(5) All other ITC

In GSTR-9, the ITC availed as per returns to be given with following break up:

6B. Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs)

6C. Inward supplies received from unregistered persons liable to reverse charge (other than B above) on which tax is paid & ITC availed

6D. Inward supplies received from registered persons liable to reverse charge (other than B above) on which tax is paid and ITC availed

6E. Import of goods (including supplies from SEZ)

6F. Import of services (excluding inward supplies from SEZs)

6G. Input Tax credit received from ISD

6H. Amount of ITC reclaimed (other than B above) under the provisions of the Act

The above detail needs to be provided with further sub – categorization into Inputs, Input Services and Capital Goods.

Taxpayers were not required to give such details while filing monthly returns. Compilation of above referred details is time consuming.

b. Other ITC related information (reconciliation between ITC availed as per GSTR-3B and GSTR-2A (GSTR – 9 Para 8)

The form auto populates figures reflected in GSTR-2A and compares with ITC availed through monthly GST returns by taxpayer.

It was clarified by CBIC that the figures from GSTR-2A which is auto populated in GSTR-9 does not include ITC of those invoices wherein supplier has filed monthly returns after 30 April 2019.

It may be noted that GSTR-2A downloaded from GST portal is updated till the date of download. Taxpayers cannot download GSTR-2A which provides details for as on 30 April 2019. Thus, taxpayers are not in position to do reconciliation and understand as to for which invoices the differences are arising.

We request you to either enable taxpayers to downloaded line wise details of figures arrived from GSTR-2A or to remove respective Para from the form.

c. HSN wise summary of Inward Supplies (GSTR – 9, Para 18)

Since HSN wise details of inward supplies was not required for filing of monthly GST returns, many taxpayers have not maintained it. F.Y. 2017-18 being 1st year of implementation of GST, we request to remove this requirement from the form as compiling of said details is time consuming.

d. Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account (GSTR – 9C, Para IV, Table 14)

Taxpayers do not maintain expense head wise ITC accounts. Form-GSTR 9C requires – expense wise eligible and ineligible ITC details. You will appreciate that compilation of these details almost requires re-writing of ITC accounts. This is indeed cumbersome and time consuming for taxpayers.

F.Y. 2017-18 being 1st year of implementation of GST, we request to remove this requirement from the form or grant sufficient extension.


4.1. You are aware about heavy rains and flood like situation in various parts of India (Kerala, Karnataka, Western Maharashtra, Gujarat, Uttarakhand etc.). It has brought the life of affected people at standstill. The tax payers located in such areas would not be in position to file Annual Returns on or before due date. It will expose them to penalties for delay in filing Annual Returns.

5.0. It should also be noted that the due date for filing of Income Tax Returns ( non-Audit cases) is 31st August ,2019 and the due date for filing of Tax Audit Reports is 30th September,2019.

6.0. We would like to emphasise on the fact that extending the due dates for filing of GST Annual Returns for F.Y. 2017-18 will not lead to deferment of any revenue to government as taxpayers have already discharged their GST liability on monthly basis at the time of filing of GSTR-3B. However it will assist in compiling and submitting the details to the government authorities in a better manner.

7.0. In view of the above, we request your good office:

a. To address technical problems faced by taxpayers while uploading and filing of Annual Returns.

b. To relax information called for in Annual Returns which were not required to be compiled or be kept at the time of filing of monthly returns.

c. To extend the due date for filing of GST Annual Returns and Reconciliation Statement for F.Y. 2017-18 for two months i.e upto 31st October,2019. This will ease the hardship faced by the business community and assist in compiling quality data while filing the GST Annual Returns and Reconciliation Statements.

Thanking you,

Sincerely yours,



Vipul K. Choksi President


Mahendra Sanghvi Chairman Law & Representation


Apurva Shah Co-Chairman Committee

Download Representation for extension of due date for filing of GST Annual Return & Reconciliation Statement

List of the other recent Representation

S. No. Dated Submitted by Link
10. 19/08/2019 BCAS and 4 Others Representation on Income Tax and GST Issues faced by taxpayers
9. 19/08/2019 Professional Accountants’ &
Tax Consultants’ Association
Request for Extending Due Dates for filing Annual GST Returns
8. 17/08/2019 Chamber of Tax Consultants Extend due date for filing of GSTR -9, 9A and 9C for F.Y. 2017-18 (As Above Post)
7. 14/08/2019 Western Maharashtra Tax Practitioner’s Association Extend Due date of GST Returns in Flood affected States
6. 13/08/2019 Goods & Services Tax Practitioners Association of Maharashtra Extend GST, Income Tax and other due dates falling in Aug & Sep 2019
5. 12/08/2019 Association of Tax Lawyers, Delhi Request to Extend time limit for claim of ITC for FY 2017-2018
4. 10/08/2019 Karnataka State Chartered Accountants Association Extend Due Date for Filing of Income Tax and GST Returns
3. 18/07/2019 Tax Bar Association, Jodhpur Extend due date for filing of Income-tax returns to 30th Sept 2019
2. 11/06/2019 Goods And Services Tax Practitioners’ Association Of Maharashtra GST Annual Return & subsequent reconciliation for GST Audit- Issues
1. 05/08/2019 Gujarat Sales Tax Bar Association Request for extension of due date of Annual Return- GSTR-9

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  1. Geetha says:

    Respected Madam / Sir,
    I hereby request your Goodself to kindly update the GST software in such that , the bills will be automatically upgraded in purchaser GST portal as the GSTR1filled by the Seller.

    Kindly consider this request , as many r missing the GST ITC which is been charged by Banks due to the lakh of knowledge or due to the non availability of required input bills or data.

    We will be obliged if Due date is extended for filing of GST9, 9c,etc for the F.Y 2017-18 .

    Yours Sincerly,

  2. SUSHANTA says:

    Dear Sir,
    We Request you please Extended the Due Date of GSTR-9 Date upto 30th November 2019

    So it seems very Missmatch Shown on Report and Data not Saved
    So Kindly Further the Due date Extended
    Thanks and Regards

  3. Nirmala says:

    Dear SIr,
    please scrap the gsrtr-9 for the fy 2017-18. we have to work from july-17 to march-18 its not easy to match with audited financials results for the period of aplr-17 to march-18. kindly scrap the gstr-9 fy 2017-18

  4. rohan naik says:

    at least require 2 years to file these returns plz extend so as we can pile up the data and file………….henceforth modi must plan and execute these kind of big decisions so that people need not get harassed.

  5. CA RUBY GARG says:


  6. suryanarayanan says:

    While filing gstr9 the options given in itc table 6,7,8 are not enaugh as some mistakes like filing 3b when filed with wrong table(e.g. payment made posted in itc table instead of payment table). how to rectify in 9 which coloumn it is adjusted.

  7. Spmaheshwari says:

    Consultants are doing very hard work for compliances of direct and indirect taxation but technology is very hard to understand time consuming having more reasons viz, Internet speed, space of the server and untimely updation of government and other softwares related to the taxation and accounting,trained people of accounting and taxation and once start work time expired for filling and penalty start and mistakes happened which can not be rectified in the same performa and after can not be rectified,coustmer care are not knowing well and are not trained enough just wasting our valuable time,government should give trained staff for filling returns in time freely to the business community and can understand how much time they take to file. Even one day is not enough to file form 9 than how much time they take to file 9c.
    So many unprofessional people filed gstr1 for 2017-18 and now for reconciliation found 50% is proper and there is no time to amend, how the other people will get ITC, God knows, Govt will blame to the professionals and business community. Time had come to understand the problems and give basic time and revision of all type of returns and waive the penalty action for at least for 6 months further from 1.7.2017 and credit the taxpayers account. Govt is not getting more compare to tax collection hardly below 1%.
    It is not my opinion but from all business peoples

  8. Hiral says:

    Extension is needed. Also give edit option for all GST returns. Or else pls scrap GSTR9 for 2017 18. It is really troublesome to manage all due dates. CAs are in stress because of GSTR9, 9C.

  9. Sk.pasha says:

    Sir. Every person asking for date extension..But after filing of GSTR9 with some mistakes..edit option also most important please think…Because this is new ..

  10. Sk.pasha says:

    Sir.First time return gstr9 filing in our country..Some mistakes common in Gstr9 return..So I request you to please give edit option in Gstr9..Annual return after filing…Because mistakes common and also date extension is most important…

  11. Sk.pasha says:

    Sir.First time return gstr9 filing in our country..Some mistakes common in Gstr9 return..So I request you to please give edit option in Gstr9..Annual return after filing…

  12. Ravindra More says:

    GSTR-9 is totally headache…. Actually we are filling all returns on Online Tax Return Portal, GST Officers wanted all the details should be ready on their tables without any queries. We are filling bill-wise details Returns and paying them tax on monthly basis also. But still they are asking all this details again which makes us sick. After 2 years of GST there is no option to file Revised Return ???
    First of all they need to update their Online systems.

    Pre GST period we use to file Return on Sales Tax portal very comfortably and small traders use to pay tax on Qty or Six Monthly basis. They have Revised option too. But in GST this all are missing and burden of monthly return GSTR-3B added to our monthly routine.

    Online Portal are meant to be for easiness of dealer not for troubling them. All details required in GSTR-9 is part of our GSTR-1 & GSTR-3B and if govenment allows us to file revised return from Jul-17 onwards, then we would not have too much trouble in filling GSTR-9 also. There is No requirement for Pt.V Sr. No. 10, 11, 12, 13, 14?? in GSTR-9 Isn’t it ?? And for Pt.V we have to reconcile all our data upto till date to know where we have adjusted the previous figure in which month. isn’t it time consuming & wasting too ??

  13. Rajesh Pandey says:

    I think not only Industry but the lobby of Indian Consultants are not capable to handle the sitution. The CA’s are not capable to file one single Annual return. I could not understand that how this country will survive, where a simple return is not being filed form past two years. I think, rather asking for the time form the Government, we must seek some permanent solution for this problem and that is complete wavier to save skin of legal consultants and CA’s

  14. SRINIVASAN says:

    yes sir. Definitely we need extension for filing Annual return upto Dec-2019.
    There are lot of information required to file the return. Even some auditors also not familiar in this matter.
    In offline tools even 2 paise variation also its showing error. Tax calculation variation should be like TDS software.

  15. S CHANDRAMOULI says:

    Please extend the time limit upto Feb 2020. I think by that time all will be able to understand all the form requirements and complete it in a proper way

  16. Ramesh Patil, Rossel Corporation says:

    I request you please scrap gstr 9a, 9c for 2017 -18, as it is first year of GST still settling for compliance, so many clarifications, technical problems, alreday filed 3b, gstr 1

  17. Saiprasad Panchagni says:

    Need simplified return formats
    Reconciliation of ITC with 2A need to be improvised
    Scrapping GSTR 9 for initial 2 Years is preferred

  18. R K Gupta says:

    Why should we ask government each time to extend date i think we must do our homework properly and should file our return in time. I request that no further extension is to be allowed by the government

  19. RAJENDRA SHAH says:

    Please respresent Govt, TO SCRAP GSTR 9 & 9C , for first year, as there were frequent changes in law , lack of clarity in insertion of data , in initial months of introduction of GST, etc.
    make it OPTIONAL/RECOMMENDATORY for first year.
    As per statistics available, only 10% of dealers , could upload the annual return, due to glitches in portal & lack of clarity

  20. Suryakant v khalap says:

    For first three years Govt should give some relief in filing and assessing the tax liabilities, because
    due to frequents amendments in GST Law , mistakes done in adopting the software for uploading the Returns ,Goerment should give the option of Revising thereturns For the Year 2017-18

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