Now that dead line for submission of GSTR 9 and 9C for FY2017-18 are extended by three months , there is huge sign of relief amongst assessees as well as auditors. Of course, there may be some dismay also, because some hopeful Associations and clients may rue that submission of GST annual returns for FY 2017-18 are only deferred and not cancelled at all. Some certifying professionals may also regret that they can not bill the clients for the hard work done over almost last six months and they need to do this exercise for three more months . And clients have started relaxing and nothing can be done to force them.
Now how should to spend these three months usefully?
Prepare GST annual returns for FY 2018-19. Why ?
1. In FY 2018-19, compliance is much better , despite addition of Eway bill and also GST TDS for certain type of clients.
The reasons for better compliance are
a. almost one year experience in implementation of GST, technical issues in submission of Monthly GST returns are mostly sorted out;
b. GSTR1 was submitted first then GSTR3B in FY 2018-19 , so more accurate reporting in 3B ;
c. Complication of 9(4) of CGST act was not there for the full FY 2018-19.
So preparation of GST annual returns for FY 2018-19 may take much lesser time.
2. Preparing FY 2018_19 draft Annual returns may give some idea about the omissions done in FY 2017_18 and an opportunity may be available to discharge tax liability of FY 2017-18 due to such omissions with interest, to avoid penalty.
3. Concentrating on finalising Input Tax credit for FY18_19 during September may be a good idea , particularly for clients having presence in many states because of the following reasons:
A. Reconciliation of 2A with Purchase register needs to be done before 30th September 2019 as per present deadlines;
B. If such reconciliation of 2A with Purchase register throws records of such Vendors being present only in Purchase register in both FY17-18 and FY18-19, then such Vendors are continuing to treat supplies to assessee as B to C instead of B to B. Or such Vendors may not be filing GST returns at all.
C. If such reconciliation of 2A with Purchase register throws records of such Vendors being present only in 2A in both FY17-18 and FY18-19 may mean some expenditure of the assessee is not being accounted properly in the books of accounts or some third party service is not reported properly in GST returns by the assessee.
So it may be advisable to complete GSTR9 and 9C of FY 2018-19 during September and October 2019 and be ready for filing these returns for both Financial years in November 2019 !