CA Sudhir Halakhandi
The GSTR-9 is a very complicated return form and once I have described it as a ‘Round Square’. It is not a simple return and like most of the cases of GST procedures simplification is missing from this form also and further filing instructions attached with this Return form are also confusing. Experts have difference of Opinion about filing of this return and sometimes confused about some of the of particular columns whether data are to be taken from GSTR-3B, GSTR-1 or Books of accounts. I have learned 5 different ways to file GSTR-9 in case of complicated Returns having problems. The basic reason of this misunderstanding and confusion is robust policy of the Lawmakers not to allow the dealers to modify or rectify the GSTR-3 return and further instructions to file GSTR-9 are also contradictory.
One more point to be kept in mind here that The Lawmakers can draft, redraft and reintroduce the Format of form but the dealer has no right to rectify or revise the GSTR-9. I have listened lot of experts that GSTR-9 still has lot of bugs. So for complicated returns we have to wait for some more clarification from the lawmakers and further some more amendments in the form.
The last date of filing of Form is at present 30th June 2019 but as there is a practice in GST to extend the date hence the speed of filing of GSTR-9 from our end is not picking up. But extension of Date is not the solution because it is wasting our time so what to do?
I have made a practical formula with a practical approach to solve the problem after wasting my 6 days in trying to file complicated return and I am sharing with you and as per my calculation 1 out of 3 GSTR-9 can be filed by this approach and after getting experience we can go ahead further to take up more complicated returns.
2. THE PRUDENT APPROACH- WHAT TO DO
Now we have to file all the GSTR-9 and it is the fact all the returns cannot be filed at once. So make a prudent plan. We must have a good percentage of return where the difference in Books of Accounts, GSTR-3B and GSTR-1 is Zero or minor. First take up returns having turnover below 1.50 Crores and start by following steps:-
|1.||4||The turnover and Tax Liability is auto populated from GSTR-1.
How to cross check it from Books of Accounts:-
For easy cross check purpose you have to add the GST turnover of pre GST first 3 Months’ (April , May and June 2017 since GST was introduced in July 2017) turnover in it Plus turnover of Table 5 (Exempted, NIL rated etc. ) in it .Check this Total from reported in Income Tax. If it is OK then go ahead.
How to cross check GSTR-1 and GSTR-3B:-Check the Tax Liability in table 9 with table 4 of GSTR-9 and if it is matching or matching with minor difference then your Table 4 and Table 9 is OK.
Further check the Table 4G also and it is related to RCM paid by you.
|2.||Table 5||Check the Exempt or NIL rated turnover and do the exercise as mentioned in So No.1.
First lot of returns chosen for filing generally does not have the export /sez type of sale.
Remember at present we are filing only simple Returns.
|3.||Table 6||The details are auto populated from GSTR-3B in Table 6A and you have to bifurcate the same in “Inputs, Input services and Capital Goods”. This bifurcation is to be to be reported in Table 6B and further it should match with the figures mentioned in Table 6A Minus Table 4G (RCM).
The RCM which is auto populated from your returns in Table 4G (As mentioned in SNo.2 above) have to be bifurcated in table 6C (RCM on supplies from Unregistered Dealers) and 6D (RCM on supplies from Registered Dealers ) in Input, Input services and Capital Goods. The total of RCM as bifurcated by you should match Table 4G.
Now Your Table 6B has the figures which will be transferred to table 8B (Inward supply of Goods and Service received from Registered Dealers) to be matched with the ITC auto populated from GSTR-2A.
|4.||Table 7||ITC claimed in GSTR-3B and ineligible have to be reversed here. See in general ITC ineligible is not claimed by the dealer in GSTR-3B so cases of returns filed by me and I am talking about the columns has nothing to fill.
Check your case and if you have claimed some ineligible ITC in GSTR-3B then fill these columns and do the needful.
|5.||Table 8||Table 8 seems to be very important but Table 8A is auto populated from GSTR-2A and the Table 8B is the result of Table 6B.
It is the details of the ITC given by your suppliers through their GSTR-1 which is auto populated in GSTR-2A which is reflected in Table 8A.
Here in these two you have to do nothing because you cannot change the data of Table 8A and 8B here.
Now if you have any difference in these two i.e. the ITC claimed by you in GSTR-3B (Table 8B) and GSTR-2A (Table 8A). Here you have to verify whether the ITC you have claimed by you in GSTR-3B is the same as mentioned in GSTR-2A and If it is matching then it is OK and go ahead.
If the ITC in GSTR-2A is in excess of GSTR-3B and you have not claimed it in next year (2018-19) then you have to surrender it to be lapsed.
Rest of the columns in this table is not useful for General and small dealer.
The big question is what to do when ITC as shown in the GSTR-2A is less than the ITC Claimed in GSTR-3B. This is complicated problem so at present keep these returns pending to be filed later.
The problem has so many dimensions so please wait before taking any decision in this respect and further guidance and clarifications in this respect.
|6.||Table 9||Table 9 is auto populated from GSTR-9 and as I mentioned in S.No.1 tally it with Table 4 and go ahead.|
In simple cased as mentioned above which have turnover less than 1.50 Crores , use this formula and you will get satisfactory results. Instead of wasting time you should go ahead and file as much as returns which fall in this category.
3. MY EXPERIENCE
I have worked 6 days and started with big and complicated returns but the result was zero. So I worked this formula and found 1 out 3 returns selected randomly fitted in this formula. You can also try it so that the 1/3rd of your work will be completed on a speed of 10 to 15 returns a day and then gradually you will get more experience and further clarifications. So don’t waste your time and start working. So start checking your returns and give 5 Minutes to each client’s return and select the returns fitted in this scheme and as per my experience “one out of three” will be a good return for this scheme.
This is practical approach. Start with it and later you will get the expertise and also the clarifications and Explanations from Lawmakers for more complicated and complex Returns. We will submit you regular updates from our practical experience in this respect.