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GST annual return filing is mandatory for all entities having GST registration, irrespective of turnover during the financial year. Hence, even businesses that have obtained GST registration and having even NIL turnover must file annual return. GST registration holder who has obtained the registration anytime before 1st April 2018 are required to file GST annual return for the financial year 2017-18 on or before 30th June 2019 in form GSTR 9. Thus all the registered entities has to file the same in the next Few Days only, after Due Date being extended for a very long span of Time.

Government in its Initial statement defined GST as Good & Simple Tax. But the same seems to be a very much complicated. Government has recently given clarification on some issues, but a lot of clarifications are still awaited.  Few of clarifications have been given in News & Updates Tab on www.gst.gov.in and others through Press Release on www.cbic.gov.in

1. What is Turnover Criteria for filing Form GSTR- 9C?

Clarification: Form GSTR-9C is to be filed by all those taxpayers whose aggregate turnover has exceeded Rs 2 crore in a financial year. Turnover of complete year i.e. from 1st April, 2017 to 31st March, 2018 has to be taken into account for calculating the turnover. For example, if a taxpayer has a turnover of Rs. 2.1 Cr for the period 1st April, 2017 to 31st March, 2018 and a turnover of Rs. 1.9 Cr for the period 1st July, 2017 to 31st March, 2018, then the taxpayer is required to file form GSTR- 9C.

Crux: Consider Full Year Turnover for GSTR 9C eligibility purpose

2. Why auto-populated data in Table 8A of GSTR-9 don’t Match with Actual GSTR 2A downloaded?

Clarification: Some taxpayers have reported that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A. Please note that this may happen due to following reasons:

a. Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-1 of the supplier taxpayer. But figures in table 8A of Form GSTR-9 are auto-populated only on the basis of filed Form GSTR-1 by the supplier taxpayer. In case, Form GSTR -1 is not filed by your supplier, then credit related to those invoices will not appear in table 8A of your Form GSTR-9.

b. Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR-1, which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April, 2019, will not get auto-populated in table 8A of Form GSTR-9.

c. In table 8A of Form GSTR-9, only latest values have been auto-populated based on filed Form GSTR-1, taking into account all the amendments made, if any. Suppose an invoice with taxable value of Rs 100/- with tax of Rs. 18/- was filed in Form GSTR-1 in the month of January, 2018 and same was amended to Rs 90 as taxable value in the month of March, 2018, then

i. the Form GSTR-2A of January, 2018 will show ITC of Rs. 18

ii. the Form GSTR-2A of March, 2018 will show ITC of Rs 16.20 &

iii. the table 8A of Form GSTR-9 will contain ITC of Rs 16.20.

d. In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in which place of supply lies in supplier’s taxpayers State, instead of State of the receiver taxpayer. These figures will be shown in Form GSTR-2A of the recipient. For example if a taxpayer of State A visits State B and stays in a hotel in State B, the tax paid by him to the hotel in State B will appear in his Form GSTR-2A, but the same will not be reflected in table 8A of Form GSTR-9.

e. The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.

Crux: Most of the Ineligible ITC Credits have already been reduced while auto-fetching data from GSTR 2A to Table 8A of GSTR 9

3. When is ‘Proceed to File’ Button enabled in GSTR 9 and what is Purpose of ‘Compute Liability’ Button?

Clarification: While filing Form GSTR 9 ‘Proceed to File’ button will be enabled only if ‘Compute Liability’ is clicked. This button is meant for computation of late fees only. Please note Form GSTR 9 once filed cannot be revised.

Crux: ‘Proceed to File’ button gets enabled after ‘Compute Liability’ Button is clicked for computing Late Fees of GSTR 9.

4. GSTR 2A as on which date gets auto-populated in Table 8A of GSTR 9?

Clarification: Information contained in FORM GSTR-2A as on 01.05.2019 shall be auto-populated in Table 8A of FORM GSTR-9

Crux : GSTR 2A as on 01.05.2019 auto populates in Table 8A of GSTR  9

5. ITC not reported in GSTR 3B in FY 2017-18, but reported in GSTR 3B of FY 2018-19. How to show the same in GSTR 9?

Clarification: Input tax credit on inward supplies shall be declared from April 2018 to March 2019 in Table 8C of FORM GSTR-9.

Crux : Use Table 8C for ITC Reported in FY 2018-19

Note : Also show in Table 13

6. For the Purpose of reporting in either Pt. II or Pt. V of GSTR 9, what data will prevail as reported in GSTR 3B or as reported in GSTR 1?

Clarification:  It may be noted that irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a supply in Pt. II or Pt. V is essentially driven by when was tax paid through FORM GSTR-3B in respect of such supplies. If the tax on such supply was paid through FORM GSTR-3B between July 2017 to March 2018 then such supply shall be declared in Pt. II and if the tax was paid through FORM GSTR3B between April 2018 to March 2019 then such supply shall be declared in Pt. V of FORM GSTR-9.

Crux : GSTR 3B will prevail over GSTR 1.

7. Sales Reported/amended in FY 2018-19 in GSTR 1 to be shown in Pt. V or Pt. II of GSTR 9 (if the same was not reported in GSTR 3B till date) ?

Clarification: Particulars of the transactions for FY 2017-18 declared in returns between April 2018 to March 2019 shall be declared in Pt. V of FORM GSTR-9. Such particulars may contain details of amendments furnished in Table 10 and Table 11 of FORM GSTR-1.

Crux : Use Table V of GSTR 9 for Sales Reported/amended in FY 2018-19 in GSTR 1 (if the same was not reported in GSTR 3B till date)

Note : Also Pay tax through DRC 03

8. How Reporting to be done if the sales was neither shown in GSTR 3B nor in GSTR 1 upto 31.03.2019?

Clarification: Any additional outward supply which was not declared by the registered person in FORM GSTR-1 and FORM GSTR-3B shall be declared in Pt.II of the FORM GSTR-9. Such additional liability shall be computed in Pt.IV and the gap between the “tax payable” and “Paid through cash” column of FORM GSTR-9 shall be paid through FORM DRC-03.

Crux : Show in Pt. II & Pt. IV and pay tax through DRC 03 through Cash Ledger

9. Auto populated data in Table 4 can be changed if different from Books of Accounts & Returns filed?

Clarification:  Many taxpayers have reported a mismatch between auto-populated data and the actual entry in their books of accounts or returns. One common challenge reported by taxpayer is in Table 4 of FORM GSTR-9 where details may have been missed in FORM GSTR-1 but tax was already paid in FORM GSTR-3B and therefore taxpayers see a mismatch between auto-populated data and data in FORM GSTR-3B. It may be noted that auto-population is a functionality provided to taxpayers for facilitation purposes, taxpayers shall report the data as per their books of account or returns filed during the financial year.

Crux : Books of accounts & returns filed will prevail over auto-populated data in Table 4.

10. IGST on imports availed in GSTR 3B for FY 2018-19 to be shown in which Table?

Clarification: Many taxpayers have represented that Table 8 has no row to fill in credit of IGST paid at the time of import of goods but availed in the return of April 2018 to March 2019. Due to this, there are apprehensions that credit which was availed between April 2018 to March 2019 but not reported in the annual return may lapse. For this particular entry, taxpayers are advised to fill in their entire credit availed on import of goods from July 2017 to March 2019 in Table 6(E) of FORM GSTR-9 itself.

Crux : To be shown in Table 6(E)

11. Payments to be made through DRC 03 should be shown as paid or payable while filing GSTR 9?

Clarification:  Payments made through FORM DRC-03 for any supplies relating to period between July 2017 to March 2018 will not be accounted for in FORM GSTR-9 but shall be reported during reconciliation in FORM GSTR-9C.

Crux : DRC 03 payment effect will be considered as paid in GSTR 9C & not in GSTR 9.

12. Why getting error message while using Excel version in GSTR 9C?

Clarification: You are also advised to use Microsoft excel version higher than 2007 while preparing Form GSTR 9C.

Crux: Use MS Excel version higher than 2007 for GSTR 9C Purpose

13. Membership Number by Auditor to be mentioned with or without prefixing Zero?

Clarification: While filing Part B of Form GSTR-9C, Auditors are advised to give their membership number without prefixing ‘0’ in their membership number. If membership number is ‘016’, then auditor should enter ‘16’ on the aforesaid part in the membership number field & not ‘016’.

Crux: Don’t Prefix ‘Zero’ in Membership Number

14. What is the due date for GSTR 9 & GSTR 9C for FY 2017-18?

Clarification: All the taxpayers are requested to file their Annual Return (FORM GSTR-9) at the earliest to avoid last minute rush.

Crux : 30.06.2019

15. Whether due date for Annual Return will be extended?

Clarification: All the taxpayers are requested to file their Annual Return (FORM GSTR-9) at the earliest to avoid last minute rush.

Crux : No such notification/announcement yet

References :-

CBIC Clarifications on filing of Annual Return (FORM GSTR-9) dated 4th June 2019

GSTN Clarification on Issues reported in filing Form GSTR 9C by the taxpayers : Steps to be taken

Please refer all the relevant section, rules, notifications, press release and amendments as applicable. The Author is not responsible for any losses incurred. Content is merely for sharing knowledge & Educational Purpose only. Author can be reached at casagargambhir@gmail.com for any queries, issues & recommendations.

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121 Comments

  1. ANEE SHAH PM says:

    Hai Sir,
    I had filed gst returns for the FY 2017-18 but there is mismatch in itc and there is no sales for our firm so turnover is less than 2 crore is it necessary to file gstr 9. kindly pls reply me

  2. KANIKA says:

    Dear sir,
    Please resolve my Query:
    If in case sales in GST3B is less than books but in GSTR-1 it reconcile with books, then how to adjust this in annual return GSTR-9 as this form is taking all values from GSTR-1 . We have paid the tax payable on that sale but how to Reconcile?

  3. DEVENDRA SHARDA says:

    as per press release of dated 3rd july, 2019 ,after reading Point No. I of this press release we can easily conclude that “turnover for eligibility of filing form 9C should be reckoned for the period July 2017 to march 2018. ( and Not April 2017 To March 2018)

  4. SMB says:

    Sir,
    Assessee is registered under GST as his rental income (commercial) is Rs.30 Lakhs, he also has interest income of Rs.1.80 crores, is he liable to file 9 and 9C?.
    From what i know is that Interest income shall not be considered as part of aggregate turnover for registration purposes. i want to know the position for filing 9 & 9C.

  5. shruthi says:

    Sir,
    2017-18 I had ITC but I wasn’t used,
    2018-2019 by mistake etc cGST 1lakh and sgst One lakh credited in the month of March and I used for ITc but after my payment still 5 lakh is in ITC.
    2019-20 can I adjust that 2 lakh this year? I have purchase as well sale how can I take out that 2 lakh?

  6. Anuj verma says:

    SIR,
    WHEN I MAKE DEBIT NOTES FOR PURCHASE RETURN. I REDUCE MY ITC CLAIMED IN BOOKS AND GSTR 3B 2017-18. BUT COUNTER PARTY NOT MAKE CREDIT NOTE IN 2017-18 BUT ISSUED IN 2018-19IN RESPONSE TO MY DEBIT NOTES.SO ITC REDUCE ONLINE GSTR 2A 2018-19.THIS CAUSE EXCESS AMOUNT SHOW IN GSTR 9 IN TABLE 8 GST AVAIL 2017-18 And REDUCE IN 2A ITC 2018-19 HOW I COMPUTE MY TAX LIABILITY IN GSTR 9. PLZ SUGGEST

  7. SUMIT AGARWAL says:

    Dear Sir,
    I have downloaded all my GSTR 2A for the fy 17-18 and crossed checked it, in which i found that the total itc as per gstr 2a is 8.52 where as what i have claimed in 3b is 8.49, but the major concern is that while filing gstr 9 in table 8 (A) which is auto populated is showing is 8.36. as you have told the possible reasons already in your article above kindly suggest me what is to be done in this case as in table 8 it is showing me a negative value..
    in this year at the year end there is itc balance in my credit ledger account firstly, secondly during this year i have paid gst in cash as well and also have received trans 1 input..
    kindly suggest how should i move and file my return..
    secondly my CA is saying that if the turnover fron july 17 to march 18 is more that 2 cr only then gst audit and gstr 9c will be filled.. vat turnover will not be counted for 9c.. what to do???

  8. Ca Gopal PRAJAPAT says:

    Dear sir,
    In some month return is been filed nill , so in next month adjusted net figure is added or deducted in next 3b suppose I have sale of 100 and purchase of 12o, I added 20 to next 3b instead of 100 to sales and 120 to purchase, so nw in gstr9 sales figure is taken from gstr1 and purchase from 3b so automatically there is huge gap in my 3b figure , bt tax liability is been paid accurately In such case wat shud be done please guide

  9. kappil says:

    SIR,
    WHEN I MAKE DEBIT NOTES FOR PURCHASE RETURN. I REDUCE MY ITC CLAIMED IN BOOKS. BUT COUNTER PARTY NOT MAKE CREDIT NOTE IN RESPONSE TO MY DEBIT NOTES. THIS CAUSE EXCESS AMOUNT SHOW IN GSTR 9 IN TABLE 8 GST AVAIL. HOW I COMPUTE MY TAX LIABILITY IN GSTR 9. PLZ SUGGEST

  10. KAPIL says:

    SIR,
    WHEN I MAKE DEBIT NOTE FOR PURCHASE RETURN. IT REDUCE MY ITC AVAILED IN MY BOOKS. BUT COUNTER PARTY NOT MAKE ANY CREDIT NOTE AGAINST OUR DEBIT NOTE. THIS CAUSE HUGE AMOUNT REFLECT IN GSTR 9 TABLE 8. HOW I KNOW TAX COUNTABILITY IN FORM GSTR 9. PLZ SUGGEST.

  11. KAPIL says:

    SIR,
    WHEN I MAKE DEBIT NOTES FOR PURCHASE RETURN. I REDUCE MY ITC CLAIMED IN BOOKS. BUT COUNTER PARTY NOT MAKE CREDIT NOTE IN RESPONSE TO MY DEBIT NOTES. THIS CAUSE HUGE AMOUNT REFLECT IN 2A OF GSTR TABLE 8. HOW I COMPUTE MY TAX LIABILITY IN GSTR 9 RETURN. PLZ SUGGEST

  12. Mithun saha says:

    Sir. Regarding gstr-9C..I had Nill rated inward supply(100%) and nill rated outward supply (100%)…as I don’t have any ITC NOR ANY OUTWARD LIABILITY THEN DO I NEED TO AUDIT AS PER CGST ACT AND FILE GSTR 9C..OR GSTR 9 WILL BE SUFFICIENT

  13. vishal says:

    Hi Sir,
    there is input tax credit carried forward through tran 1.
    So please suggest me where i have to show to this tran 1 credit in gstr 9c.

  14. muthuams says:

    sir,
    i have igst input of 71000 in 2A and i booked 14000 in fy17-18 and remaining 57000 in fy 18-19 in the book. but i have claimed 62000 in fy 17-18 in 3b and also claimed 57000 in month of april 18 through 3b so what amount should i show in table 6(b) of gstr 9
    if i show 14000 in 6(b) then it showing -48000 in 6(j) which means should i pay the tax through drc 03

  15. muthuams says:

    sir,
    i have more itc in my book when i compared to itc shown in 3b and also i have more itc in my 2a when i compared to book what amt should i show in table 6(b) of gstr 9
    eg,
    book – 100
    3b – 90
    2a – 110
    consider my all itc in 2a is eligible
    please tell me sir

  16. Muthu says:

    sir,
    sir i have the igst itc of 71000 in 2a for fy2017-18
    I have booked igst itc of 14000 in my book in fy 17-18 and remaining 57000 of igst itc in fy18-19 but i have claimed itc of 62000 in fy17-18 instead of 14000 and also i have claimed 57000 in fy 18-19 so what amt should i show in table 6 (b) of gstr 9
    if i show book value of 14000 in 6(b) it showing -48000 in 6(j) which means should i pay the amt through drc 03 please tell me sir

  17. Muthu says:

    Sir,
    I have more itc in my book when i compare to 3b and also my 2a is more than with my book so what the value should i show in table 6 (b)
    eg,
    book- 100
    2a – 120
    3b availed -80

  18. shikha says:

    In gstr-9, Pt-IV. Details of tax paid as declared i returns filed during the financial year. in this what show in tax payble. ( ( 1) F.Y -2017-18 paid tax in gstr-3b or (2) F.Y- 2018-19 paid tax in gstr-3b ?) which i consider ??

  19. Raju says:

    Sir, I’ve not paid tax (Rs 238/-) due to reverse charge (transport company) for the month of Jan 18 till date. I know that table 4 has to be updated. Should I also update table 9 and change ‘tax payable’ and ‘interest’ fields?

  20. ROHIT MORE says:

    Sir , I am a Importer . Under FY 17-18 , Some of the Purchase Bill has been missed . How to add those inward Supply tax purchase till now under GSTR9?

    Please Help .

  21. Shree says:

    Illustration –
    ITC as per books = 100
    ITC reported in 3B = 1000

    Problem – 1
    Excess ITC reversed ( in 17-18) in Table 4B of GSTR-3B – what amount to be reported in table 6B of GSTR-9
    whether any sum to be reported in table 7H of GSTR-9

    Problem – 2
    Excess ITC reversed ( in 18-19) in Table 4B of GSTR-3B – what amount to be reported in table 6B of GSTR-9. any reporting in table 12 ?

    Problem – 3
    instead of reversal in table 4B of GSTR 3B in 18-19 we have netted off the amount in table 4A in GSTR3B of 18-19 – what amount to be reported in table 6B of GSTR-9.
    any reporting in table 12 of GSTR-9?

    Any adjustments in tax payable required in table 9 for the transactions of reversal.

  22. Mukesh says:

    Pls tell in GSTR 9C table of rate wise tax liability late fees paid are shown or not because if we shown then difference will arise so pls guide on it.AS per. total tax paid as per GSTR 9 late fees not count in total.

  23. krishnamurthy says:

    During the year 2017-18 , in gstr-1 a particular invoice was not uploaded due to gst no mistake. whereas invoice value & tax was included in gstr-3b. Now turnover and tax differ between gstr-1 and gstr-3b. Turnover & Tax was higher in GSTR-3B than that of GSTR-1. The gst mistake bill was corrected in 2018-19 and added in GSTR-1 of 2018-2019. WHERE to show these differences in GSTR-9. Please guide me

  24. Himanshu Acharekar says:

    Sir,
    i have claimed excess input in 3B and GSTR2A is showing less credit available i want to reverse excess credit and want to pay the same how to do it
    plz guide

  25. sundaram says:

    Dear Sir,
    My annual turnover of FY APR 2017 ~ MAR 2018 total is less than 5 lakh rupees.
    I already filled GSTR9 at own by online, should i need to do anything for GSTR9C ? as it showing last date 31 Aug 2019. ??
    Because GST returns make bit tension so i need clarification for that..
    Thanks in advance.

  26. VIJAY says:

    Sir,
    I have taken gst registration in dec 2017..but one of my seller had shown wrongly in gstr1 return from nov 2017 ..and gstr2a auto reflecting itc ..now when i am filing annual return what to do the itc for nov 2017 amounting to rs.480000 approx….as my returns started from dec 2017…
    Also the seller has completed annual return also for f.y.2017-18…

    Please help me…

  27. Ram says:

    Respected Sir,
    My F.Y.17-18 turnover is 10 lack but July-17 to March-18 as per GST Turnover 8 lack and 2 lack Pre GST how to consider in GSTR-9 Pre GST Amount and which column.

  28. Poonam says:

    Hello Sir
    By mistake we add sales return amount (without tax) in sales amount, then we rectify this mistake in September -2018, but we reduce twice times credit note, so our turnover also reduced, can I rectify this mistake in Gstr-9

  29. Ram says:

    Respected Sir,
    may be by mistake ITC Claimed but not Show in GSTR-2A Annual return in Reverse ITC in Table 7. first effect 7.Details of ITC Reversed and Ineligible ITC for the financial year and how to second effect on ITC reversed for Annaul return .

  30. G venkatesh says:

    Sir,
    What is the treatment if ITC claimed in GSTR 3B is less than the GSTR 2A and the same had not been claimed till 31.03.2019 ? Can we take that now in GSTR 9 or will it be lapsed ?

  31. Abhay Kumar Singh says:

    The amount of Our GSTR-2A & GSTR-9 8A is mismatched. we found that some supplier wrongly showing third party supply in our GST no. Some of them amended invoices but still is showing in 2A. we are unable to find out that which supplier has amended their invoices and which are not amended. Because those who are not amened is picking up in GSTR-9 Please clarify.

  32. Ram says:

    Dear Sir,
    Please help us to annual return filed in GTA Person.
    monthly sale invoice details in GSTR-3B 3.1 (C) column Other outward supplies (Nill Rated , Exempted) and GSTR-1 is B2B filling and Supply attract Reverse Charge tick and filed. please clarify in GTA person for annaul return filling.

  33. Mukesh Sharma says:

    Sir, in 3B return of march 17-18, I wrongly entered excess amount of Input GST as well as Output GST, whereas GSTR 1 is right. I have seen this error now when filing GSTR9. What can I do now, please help.

  34. Rohin Kumar Karuturi says:

    Missed an outward supply invoice in FY 2017-18 March’s GSTR 1.Can I pass a debit note in May 2019 GSTR 1 and enter such excess supply amount in GSTR 9 for the FY 17-18??

  35. Rajkumar says:

    Dear team,

    I showed my turnover 100000 in GST returns but in Income tax i showed only 50000, what is the solution to file gstr 9

  36. Darr says:

    Dear taxguru,
    My turnover for financial year 2107-18 is 0 ( no liabilities, sales or purchases), i have filed the nill annual return gstr 9,the gstr 9c option is enabled in my case, do i need to file gstr 9c.

  37. GIRI says:

    under Auto draft 2A of 2017-2018 itc received but we not used in the same year or neither in 2018-2019
    that itc where to show in GSTR9

  38. shambhoo dayal says:

    sir .In case of Petrol pumps , inward and outward supply i.e.purchase and sale of Diesel and Petrol is non GST item . However. lubricants purchased and sold by petrol pumps is under GST . For example: a petrol pump purchase and sell Diesel and petrol valued say Rs.20 crores annually and lubricants only of value 10 lakhs .In that case ,what will be turnover under GST . Whether audited GSTR-9 C is to filed in this case or a simple GSTR-9 will suffice.
    thanks.
    S.Dayal ,Mob.8795526385

  39. Vinod Kumar Banka says:

    What will be the treatment in GSTR – 9, if we have correctly shown the amount of outward supply in GSTR – 1 but shown excess amount in GSTR – 3B for the FY 2017-18 and GST paid accordingly on the excess amount. In FY 2018-19, excess amount of outward supply and Tax adjusted in GSTR-3B of 2018-19.

    As table 4 of GSTR 9 is autopopulated through GSTR 1 which is showing correct amount. Do we need to make any adjustment in Table 11?

  40. Vinod Kumar Banka says:

    What will be the treatment, if Outward supply as per GSTR-1 is correct for the FY 2017-18 but we have shown excess amount in GSTR-3B and paid excess GST accordingly. Thereafter the excess amount paid in 2017-18 was adjusted with the liability of 2018-19

  41. Omedia says:

    My turnover for fy 2017-19, including the first quarter (ie from 1-04-17 to 31-03-2018) is less than 50 lakhs. I have filed Annual Return gstr 9. I find that GSTR 9C is enabled in my case. Am I required to file GSTR 9C ? After preparing gstr 9 I found that I have an amount of Rs.7500 due. How this should be paid ?

  42. karthick nagarajan says:

    Is Turn over includes NON GST SUPPLY, ? why because we are also submitting FORM WW to VAT department for Petrol and diesel sales which is not covered in GST regime.

    Why double return for petrol and diesel products ?
    please clarify

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