FAQ Annual Return Form GSTR-9A

CA Dilip Kumar Bothra

GSTR-9A: It should be filed by the persons registered under Composition scheme under GST.

1. Who needs to file Form GSTR-9A ?

• All taxpayers registered under the composition scheme under GST, for any period during the financial year, need to file Form GSTR-9A.

This will include a taxpayer

– Who have opted for composition scheme since registration and have never opted out subsequently; and

– Who have opted in for composition scheme any time during the financial year; and

– Who have opted in for composition scheme but subsequently opted out any time during the said financial year.

2. Is it mandatory to file Form GSTR-9A?

• Yes, its mandatory to file Form GSTR-9A for composition taxpayers even if there is not turnover during the said period.

3. Who does not need to file Form GSTR-9A ?

• Following persons are not required to file Form GSTR-9A

– Regular Taxpayer who have not opted in for composition scheme for any period during the financial year

– Non Resident Taxable Persons

– Input Service Distributor

– Casual Taxable Person\

– Persons required to Deduct tax at Source u/s 51

– Persons required to Collect tax at Source u/s 52

4. What are the pre-conditions for filing form GSTR-9A ?

• Taxpayer should have been registered in the relevant financial year and opted for composition scheme for even a day during the financial year.
• Taxpayer has filed all applicable returns i.e. Form GSTR-4,quaterly return of the relevant financial year, before filing the Annual Return.

5. How can I as a taxpayer file Form GSTR-9A

• Navigate to Services >Returns>Annual Return to file Form GSTR-9A.

6. Form GSTR-9A is required to be filed at entity level or GSTIN level ?

• Form GSTR-9A is required to be filed at GSTIN level i.e. for each registration.
• If taxpayer has obtained multiple registrations, under the same PAN, whether in the same state or different states, he is required to file annual return for each registrations separately, where the GSTIN was under composition scheme for some time during the financial year or for the whole of the financial year.

7. I am a regular/normal taxpayer for part period and composition taxpayer for part period during the financial year. Do I need to file Form GSTR-9A or Form GSTR-9?

• You are required to file both form GSTR-9 and Form GSTR-9A.
• The period during which the taxpayer remained as a  Composition Taxpayer, Form GSTR-9A is required to be filed.
• And, for period during which the taxpayer registered as normal taxpayer, Form GSTR-9 is required to filed.
• Both Form GSTR-9 and Form GSTR-9A for the respective tax period are required to be filed for FY 2017-18, in such cases.

8. I have not filed all my applicable returns /statements during the financial year. Still, Can I file Annual Return without filing of those applicable returns/statements ?

• No, You  cannot file return in Form GSTR-9A without filing form GSTR-4 for all applicable periods during the relevant financial year.

9. What is the due date for filing Form GSTR-9A for F.Y. 2017-18 ?

• Form GSTR-9A for F.Y. 2017-18 can be filed by 30^th June, 2019. In case of Filing after the due date, late fee will be levied.

10. I got my registration cancelled in the Financial Year. Can I file form GSTR-9A ?

• The annual return is to be filed even if taxpayer has got his registration cancelled during the said financial year.

11. Can I revise Form GSTR-9A return after filing ?

• No, You cannot revise  Form GSTR-9A Return after filing.

12. In Form GSTR-9A, can additional liability not reported earlier in Form GSTR-4 be declared ?

• Yes, additional liability not reported earlier at the time of filing form GSTR-4 can be declared in Form GSTR-9A. The additional liability so declared in Form GSTR-9A are required to be paid through Form GST DRC-03.
• If available cash balance in the Electronic cash ledger is less than the amount required to offset the liabilities, then additional cash required to be paid by taxpayer is shown in the “Additional Cash required” coloumn. You may create challan for the additional cash directly by clicking on the CREATE CHALLAN button.

13. Can I file nil Form GSTR-9A ?

• Nil Form GSTR-9A can be filed for the financial year, if you have

– Not made any Outward Supply;  AND

– Not received any goods/services;

– No other liability to report; AND

– Not Claimed any refund; AND

– Not received any order creating demand.

14. Which Table in Form GSTR-9A has auto populated data from filed Form GSTR-4?

• Table 6 : Details of Outward supplies made during the financial year.
• Table 7: Details of Inward supplies on which tax is payable on reverse charge basis (net of debit/credit notes) for the financial year.
• Table 8: Details of other inward supplies for the financial year.
• Table 9: Details of Tax Paid as declared in returns filed during financial year.

15. Can I edit auto populated details in Form GSTR-9A

• Yes, you can edit autopopulated data in form GSTR-9A except tax paid column of Table No 9.
• The Outward supplies details can be edited in order to indicate actual supplies made and not merely outward supplies indicated in the Returns.’

16. Do I need to provide information relating to all supply made during the financial year ?

• Yes, you need to provide all supplies made during the financial year and not merely the supplies reported in the return.

17. Can I download system computed values of Form GSTR-9A ?

• Yes taxpayer can download the system computed values for Form GSTR-9A in PDF format.
• This will help taxpayer to use it as reference while filing form GSTR-9A.

18. Is their any option to make payment other than late fee (if applicable) in Form GSTR-9A ?

• After filing of your return in Form GSTR-9A, you will get a link to Form GST DRC-03 to pay tax, if any.
• Any additional payment can be made using Form GST DRC-03 fuctionality only and that too by Cash.

19. Is their any Offline Tool for filing Form GSTR-9A  ?

• Currently, Form GSTR-9A return can be filed through online mode only.
• However, offline tool for Form GSTR-9A will be released shortly.

Conclusion : That’s all about from Form GSTR-9A. Do this…before you file this form :

• Reconcile your data with the books of accounts  and financial statements for 2017-18.
• Check for any Error/Omission in reporting data in GSTR-4 filed for F.Y. 2017-18, which have not been rectified in subsequent period.
• Reconcile you tax liability as reported in with Books of Accounts.
• Report your tax liability as per reconciled figure.’
• Any Additional liability can be paid through Form GST DRC-03 available at GST Portal through electronic cash ledger only.