Article explains Categories of person who can file an Annual Return in Form GSTR-9A, Pre-requisites for filing GSTR-9A,  Filing of NIL Annual Return, Things to be done before filing GSTR-9A,  Download system computed summary of GSTR-9A and GSTR-4, Structure of Annual Return GSTR-9A, GSTR-9A filing steps at GST portal, Payment of additional tax liability and Penalty for non-filing / late filing of FORM GSTR-9A.

Every registered taxable person under GST is required to file an annual return. After the various extension, finally, the final due date for filing of the first annual return is at present notified as 30th June, 2019. Under GST, different categories of persons are required to file different types of annual return as summarized here under –

Categories of person Types of annual return
Normal taxable person FORM GSTR-9
Composition scheme taxpayer FORM GSTR-9A
E-commerce operator required to collect TDS FORM GSTR-9B
Reconciliation statement required to be filed by a normal taxable person having an aggregate turnover of more than INR 2 Crore FORM GSTR-9C

Under the present article we would try to understand every nook and corner of an annual return filing in form GSTR-9A which is required to be filed by a composition scheme taxpayer.

1. Categories of person who can file an Annual Return in Form GSTR-9A

As per section 44 (1) of the Central Goods and Service Tax Act, 2017, every registered person is required to furnish an annual return for every financial year, electronically. As per the said section, categories of persons who are exempted from filing of an annual return is listed herein below –

  • Input service distributor;
  • A person paying tax under section 51;
  • A person paying tax under section 52;
  • A casual taxable person and
  • A non-resident taxable person.

Other than above listed categories of persons, all the normal taxable persons are required to file an annual return.

Proviso to rule 80 (1) of the Central Goods and Service Tax Rules, 2017 states that the person who is paying tax u/s 10 shall furnish the annual return in FORM GSTR-9A. In nut-shell, the composition scheme taxpayer is required to furnish the annual return in FORM GSTR-9A.

It is important to be noted here that the registered taxpayer is required to file an annual return for each registration i.e. if the taxpayer has obtained multiple registrations, under the same PAN, he is required to file an annual return in FORM GSTR-9A for each such registration, separately, where the taxpayer was under composition scheme for some time during the financial year or for the whole of the financial year.

The due date for filing of an annual return by the composition scheme taxpayer in FORM GSTR-9A is on or before 31st December, however, the due date for filing of a first annual return for the Financial Year 2017-2018 in FORM GSTR-9A has been extended till 30th June, 2019.

2. Pre-requisites for filing GSTR-9A

Pre-requisites for filing of an annual return in FORM GSTR-9A are being summarized hereunder –

  • The taxpayer should have been registered under GST in the relevant financial year and the taxpayer should have opted for the composition scheme for at least a day in the relevant financial year.
  • It is mandatory for the composition scheme taxpayer to file all the quarterly return, for the prescribed period, in FORM GSTR-4, before the filing of an annual return in FORM GSTR-9A.

3. Filing of NIL Annual Return

NIL annual return can be filed only and only if all the circumstances mentioned hereunder are satisfied –

  • There is no outward supplies / sales.
  • Any goods / services i.e. purchase is not received.
  • There is no liability reported.
  • There is no credit and no refund claimed.
  • There is no receipt of any order creating demand.
  • There is no late fee payable / paid.

In order to file NIL return, one needs to follow below mentioned steps –

1. Visit site https://www.gst.gov.in/;

2. Click on ‘Login’ icon and provide appropriate username and password;

3. Navigate the path Services > Returns > Annual Return.

4. Select appropriate Financial Year from the drop-down list and click on SEARCH.

5. ‘Annual return for composition taxpayer GSTR-9A’ would be displayed and ‘PREPARE ONLINE’ or ‘PREPARE OFFLINE’ option would also be displayed.

6. Select ‘PREPARE ONLINE’. On selecting the same, a questionnaire would be displayed asking ‘Do you want to file NIL return’?

7. Select the option ‘Yes’ and click on ‘NEXT’ button.

8. Provide figure of ‘Aggregate turnover of the previous Financial Year’ and click on ‘Compute liabilities’ and proceed to file.

9. File NIL GSTR-9A using DSC / EVC.

4. Things to be done before filing GSTR-9A

  • Reconciliation of data with the books of accounts and the financial statement for the financial year 2017-2018.
  • Verification of any error / omission while filing of FORM GSTR-4 which has not been rectified subsequently.
  • Reconciliation of tax liability as per books of accounts as against returns filed.

5. Download system computed summary of GSTR-9A and GSTR-4

With a view to ease up the filing of the annual return, GSTN has provided a facility to download the system computed summary of GSTR-9A and also provided the facility to download system computed summary of GSTR-4. The summary is available in PDF format. By following the below mentioned steps, both the summaries can be downloaded –

  • Visit site https://www.gst.gov.in/;
  • Click on ‘Login’ icon and provide appropriate username and password;
  • Navigate the path Services > Returns > Annual Return.
  • Select appropriate Financial Year from the drop-down list and click on SEARCH.
  • Select PREPARE ONLINE under ‘Annual return for composition taxpayer GSTR-9A’.
  • Click on ‘Download GSTR 9A system computed summary’ or ‘Download GSTR-4 summary’.

6. Structure of Annual Return GSTR-9A

An Annual return in FORM GSTR-9A, to be filed by the composition scheme taxpayer, is divided into 5 parts. The said 5 parts along with its basic understanding is being summarized hereunder –

Parts Description Basic Understanding of the parts
I Basic Details Basic details like financial year, GSTN, Legal and trade name, Period of composition scheme during the year and aggregate turnover of the previous financial year.
II Details of outward and inward supplies made during the financial year Taxable and exempted outward supplies.

Inward supplies liable to reverse charge received from registered persons and received from unregistered persons.

Import of services.

III Details of tax paid as declared in returns filed during the financial year Total tax payable and total tax paid in respect of IGST, CGST, SGST, UTGST, Cess, Interest, Late fee and penalty
IV Particulars of the transactions for the previous FY declared in returns of April to September of current FY or up to date of filing of annual return of previous FY, whichever is earlier While filing of an annual return for the period FY 2017-18, the figures of transactions declared in April to September, 2018 needs to be declared.
V Other information Refund details like Refund claimed, refund sanctioned, refund rejected, refund pending.

Demand details like the demand of taxes, taxes paid, taxes pending.

ITC reversed at the time of opting in the composition scheme and ITC availed at the time of opting out of the composition scheme.

Late fee payable and paid

7. GSTR-9A filing steps at GST portal

1. Visit site https://www.gst.gov.in/;

2. Click on ‘Login’ icon and provide appropriate username and password;

3. Navigate the path Services > Returns > Annual Return.

4. Select appropriate Financial Year from the drop-down list and click on SEARCH.

5. ‘Annual return for composition taxpayer GSTR-9A’ would be displayed and as per the preference ‘PREPARE ONLINE’ or ‘PREPARE OFFLINE’ can be selected from the displayed options.

8. Payment of additional tax liability

Filing of an annual return in FORM GSTR-9A is only a summary of data’s reported while filing of the quarterly return in FORM GSTR-4. There can be a situation, wherein, the composition scheme taxpayer has intentionally / unintentionally not reported certain liability while filing of return in FORM GSTR-4.

In such a situation, additional tax liability would arise at the time of declaring the said liability while filing of an annual return in FORM GSTR-9A. Such additional tax liability can be paid voluntarily along with requisite interest through Form DRC-03.

9. Penalty for non-filing / late filing of FORM GSTR-9A

In case of non-filing / late filing of FORM GSTR-9A, penalty / late fee of INR 200 per day (i.e. CGST – INR 100 per day + SGST – INR 100 per day) would be payable. However, the maximum amount of penalty payable for non-filing / late filing of annual return in FORM GSTR-9A is restricted to 0.25% of turnover in the State / Union territory.

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3 Comments

  1. Smitha says:

    SIR,
    THANK YOU FOR THE INFORMATION.
    MY QUESTION IS , IF WE HAVE NOT DECLARED PURCHASE IN GSTR – 4 IN ANY MONTH, SHOULD WE DECLARE IT IN GSTR – 9A? IS IT MANDATORY OR CAN WE FILE WITHOUT DECLARING IT?

  2. Tarunkumar D trivedi says:

    Composition taxpayers are not required to submit details of inward supply from Registered suppliers in table 4A of GSTR 4. Now are they require to fill details of inward supply from regd supplier in table 8A of annual GSTR 9A? Sir pl reply/comment

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