GST AUDIT: GSTR-9C -Analysis of Point No. 5A to 5O

POINT NO. 5  OF  FORM  GSTR 9C (CLAUSE WISE) – SHORT ANALYSIS

5A – Turnover (including exports) as per audited financial statements for the State / UT (For multi-GSTIN units under same PAN the turnover shall be derived from the audited Annual Financial Statement)

1. The turnover as per the audited Annual Financial Statement shall be declared here.

2. While considering the turnover from the audited financial statements, the Auditor is also required to include indirect income in the form of dividend, interest, forex fluctuation, profit on sale of asset etc.

DOCUMENTS REQUIRED —- 

1. Audited financial statements for the FY to derive the total turnover of the Registered Person;

1. GST (Viz. Form GSTR 3B and Form GSTR 1) returns filed by the Registered Person to ensure that the turnover declared in the returns match with the turnover captured in the audited financial statements.

5B – Unbilled revenue at the beginning of Financial Year

1. In simple terms, unbilled revenue is the revenue recognized in the books of accounts before the issue of an invoice at the end of a particular period as per Accounting Standard-9.

2. Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of accounting in the earlier financial year for which the invoice is issued under GST law is required to be declared here.

i.e. GST is payable during the financial year on such revenue (which was recognized as income in the earlier year), the value of such revenue is to be declared here.(booked in 16-17 but invoice rasied in 18-19)

3. The expression ‘financial year’ for 2017-18 — to be 9 months period commencing 1 July, 2017, the value under this clause must be reckoned as at 30th June, 2017.

4. ONLY APPLICABLE TO “SERVICES” ; AS FOR “GOODS” IT WOULD GET COVERED UNDER “UNADJUSTED ADVANCES”.

DOCUMENTS REQUIRED —-

1. Reliance has been placed on the audited financial statements for determining the unbilled revenue and no separate exercise is conducted to validate the same.

5C – Unadjusted advances at the end of the Financial Year

1. It is a business practice to collect Advances from customers before effecting supplies.

2. As per GST Law, any advances received from Customers before the supply is made ; on receipt of such advance GST has to be charged.

3. Advances received would be for various purposes. So, the Advances on which GST is liable should only be considered for the adjustment.

INCLUDE	REASON
Advance received for services as on 31st March 2018	Revenue not recognized in books, but offered to tax for GST
Advance received for Goods before 15th Nov 2017 and the supply of goods not complete as on 31st March 2018	Revenue not recognized in books, but offered to tax for GST

NOTE —

(a)  value of all advances for which GST has been paid but the same has not been  recognized as revenue/sale in the audited Annual Financial Statement shall be declared here.

(b) Even if not considered in the returns GSTR 1 and GSTR 9, the same shall be added as turnover here.

5D – Deemed Supply under Schedule I

1. Requirement of this Sl.No. is to report the transactions which were not reported in the financial statements, though the same are reported in the returns filed since they are treated as deemed supplies under the GST law.

2. Any deemed supply which is already part of the turnover in the audited Annual Financial Statement is not required to be included here.

 SCHEDULE-1 COVERS FOLLOWING SUPPLIES MADE WITHOUT CONSIDERATION  – 

1. Assets Donated would also not escape the levy and would have to be subject to GST Certain other examples would be – decommissioning of an entire plant, impairment of assets, assets taken by a proprietor on completion of its useful life (computer taken by the proprietor) etc. (only if ITC was availed on the above Assets).

2. Supply of goods or services or both between related persons or between distinct persons;

Provided that gifts not exceeding fifty thousand rupees in value in a financial year by an employer to an employee shall not be treated as supply of goods or services or both.

3. Supply of goods-

(a) by a principal to his agent where the agent undertakes to supply such goods on behalf of the principal;

or

(b) by an agent to his principal where the agent undertakes to receive such goods on behalf of the principal.

4. Import of services by a taxable person from a related person or from any of his other establishments outside India, in the course or furtherance of business.

5E – Credit Notes issued after the end of the financial year but reflected in the  annual return

1. Value of credit notes which were issued after Mar 31, 2018 ; for supply accounted in 18-19(not 17-18) ; but such credit notes were reflected in the annual return GSTR –9 for the financial year 2017-18.

i.e. credit notes issued after 01.04.2018 — reported in books in FY 2018-19 – but reflected in GSTR-9 of 2017-18.

2. Above amount would get added with Turnover as per Audited Books to reconcile it with Turnover of GSTR-9.

5F – Trade Discounts accounted for in the audited Annual Financial Statement but are not permissible under GST

1. This clause requires disclosure of trade discounts which have been given effect to, in the audited financial statements ;

but which are not permissible as deduction from the value of supply as per VALUATION RULES.(i.e. not permissible under GST).

2. As per Sec.15(3) following discount is permissible –

a. If discount is mentioned on face of Invoice , it can be reduced from the Value of Supply.

b. If discount is not mentioned on face of Invoice , it can be reduced from the Value of Supply , on fulfilling following conditions :

• • Both Supplier & Recipient have agreed about the discount before the supply &
  • Such discount is specifically linked to relevant invoices &
  • Proportionate ITC attributable to discount has been reversed by the Recipient.

3. The Trade discounts can be issued in various ways and manners like special discounts for maintaining the business relationship ; bonus discount for purchasing goods beyond certain stipulated targets

5H – Unbilled revenue at the end of Financial Year

1. Revenue which was recorded in the books of accounts on the basis of accrual system of accounting i.e. as per AS-9 in current FY (17-18) ;

Invoice for the same would be raised in subsequent FY (18-19) &

then GST would also be paid in FY 18-19.

2. Above amount will get reduced from the Turnover as per Books so as to arrive to Turnover of GSTR-9; as GSTR-9 doesn’t includes such unbilled amount.

3. Also refer Point 5B as discussed above.

5I – Unadjusted Advances at the beginning of the Financial Year

1. NIL – for the first year ; as GST was not applicable on advances received in FY 16-17 & till 30.06.2017.

5J – Credit notes accounted for in the audited Annual Financial Statement but are not permissible under GST

1. All the adjustments made by issuing a Credit Note ; in the Books of Accounts ; by way of  reduction in the Turnover of Books ; without having GST effect shall be reported here.

2. Identify all Non-GST Credit notes, which have effect of reducing the Turnover as per Books.

3. Since, these Non-GST credit notes have reduced the Turnover of Books but they aren’t reflected in any GST returns(as they are non-gst).

4. Hence added back to arrive to the Turnover as per GSTR-9.

5K – Adjustments on account of supply of goods by SEZ units to DTA Units

1. Value of all goods supplied by SEZs to DTA units ; for which the DTA units have filed bill of entry shall be declared here.

2. Such outward supplies are not required to be reported by SEZ units in their GST Returns (as it is Import for the DTA unit).

3. Hence, the data cannot be retrieved from the returns filed by such SEZ units.

4. Though above transaction would be ‘sale’ for the purpose of Financial Statements of SEZ unit; but will not be considered as supply for GST purposes and hence, needs to be deducted from the turnovers of financial statements for the purpose of arriving at the turnover as per GSTR 9.

5M – Adjustments in turnover under section 15 and rules thereunder

1. Any difference between the turnover reported in the audited Financial Statements &Turnover reported in GSTR-9 due to difference in Value of Supply (Valuation Rules) shall be declared here.

2. Section 15 provides that transaction value will be considered as Value of Supply only if :-

• Supplier and the recipient are not related  &
• Price is the sole consideration for the supply.

3. Even if the price for a supply is agreed to be the transaction value, few adjustments (provided for under Section 15 itself) are required to carried out ; for the purpose of computation of ‘Value’ on which GST is required to be paid.

For Eg. –

• ADD – Any taxes, duties, cesses, fees and charges levied under any law for the time being in force other than this Act.

• ADD – Incidental expenses, including commission and packing,freight charged by the supplier to the recipient & recovered thereon.

• ADD – Any amount that the supplier is liable to pay in relation to such supply, but which has been incurred by the recipient of the supply and not included in the price.

5N- Adjustments in turnover due to foreign exchange fluctuations

1. Forex Transactions are accounted in the books of accounts based on RBI REFERENCE RATE ; whereas CGST Rules require value of taxable goods to be determined based on the exchange by CBEC NOTIFIED RATE .

2. Hence difference between RBI REFERENCE RATE & CBEC NOTIFIED RATE shall be declared here.

3. Additionally, difference in amount booked in accounts and actual amount received would also result in Forex Gain/Loss which again needs to be adjusted from the Annual Turnover as per as per financials(i.e. reduce forex gain & add forex loss) to arrive at the revenue as per GSTR 9.

5O- Adjustments in turnover due to reasons not listed above

1. This is a residuary clause for difference between the turnover due to reasons not listed above.

2. The following broad head of adjustments can be reported under this Sl.No.: –

• turnover considered as ‘supply’ under GST but not considered as income in the audited Annual Financial Statements;

• turnover discovered as ‘supply’ during the course of audit, but not considered in books of account and Form GSTR 9.

Sl No.	Particulars	Action
1	Physician sample distributed by the pharmaceutical company to physician for free	(+)
2	Notice pay recovered from employees	(+)
3	Gifts given to customers/vendors/distributors	(+)
4	Stocks issued to discharge CSR obligation	(+)
5	Sales promotion / advertisement reimbursement received and considered as supply	(+)
6	Out of pocket expenses considered in the value of supply	(+)
7	Value of Capital Goods on which GST paid on sale	(+)
8	Profit on sale of Capital goods disclosed in audited Annual Financial Statements	(-)
9	Loss on sale of Capital goods disclosed in audited Annual Financial Statements	(+)
10	Income in Profit and Loss account recognized based on special circumstances	(-)
11	value on which GST is liable to be paid in respect of transactions where income is recognized based on special circumstances	(+)
12	Discounts which are not to be excluded from the value of supply as per Section 15	(+)
13	Sale reversals in financials as risk & rewards not transferred.	(+)
14	Provision for doubtful debts written back	(+)
15	Interest income	(-)
16	Miscellaneous income or Any other amount	(-)

                                         (views are strictly personal)