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GST Audit Report – GSTR 9C

A reconciliation statement also known as the GST audit report in FORM GSTR 9C is to be submitted in case the GST audit provisions are applicable to the registered person.

Introduction –

Combine reading of section 35 (5) of the Central Goods and Service Tax Act, 2017 and rule 80 (3) of the Central Goods and Service Tax Rules, 2017 can result into the following conclusions –

  • Every registered person whose turnover exceeds INR 2 Crore during the financial year is required to get his accounts audited;
  • Such an audit can be conducted by either a Chartered Accountant or a Cost Accountant;
  • Following are the list of documents which one needs to submit –
    • Copy of audited annual accounts;
    • Duly certified reconciliation statement (also known as Audit report) in FORM GSTR 9C; and
    • Any other prescribed documents.

A reconciliation statement also known as the GST audit report in FORM GSTR 9C is to be submitted in case the GST audit provisions are applicable to the registered person.

It must be noted here that due date of filing of FORM GSTR 9C would be same as that of annual return in FORM GSTR 9 i.e. 31st December of the subsequent financial year. First Goods and Service Tax audit and filing of the audit report in FORM GSTR 9C is currently in the limelight with its soon emerging due date 31st December, 2018. The present article provides basic understanding of audit report in FORM GSTR 9C.

Understanding Basics Of GST Audit Report (FORM GSTR 9C) –

Simply saying, GSTR 9C is a reconciliation statement which provides a reconciliation between the following figures –

  • Figures as provided under GSTR 9 (annual return); and
  • Figures as per audited annual financial statement.

The difference between the aforesaid figures needs to be reported in GSTR 9C along with the reason for the said difference.

Central Board of Indirect Taxes and Customs (CBIC), vide notification no. 49/2018 – Central Tax dated 13th September, 2018, had published / provided the format of FORM GSTR 9C.

Broadly classifying, FORM GSTR 9C is divided in to below mentioned two basic parts –

Part A – Reconciliation Statement; and

Part B – Certification

Part A Reconciliation Statement is sub-divided into 5 different parts. The said sub-divided 5 parts of Part A, along with the basic understanding of the same, is tabulated hereunder –

PART TITLE EXPLANATION
I Basic details Details of the Financial year, GSTIN, Legal name and whether liable for audit under any act or not needs to be provided.
II Reconciliation of turnover declared in the audited Annual Financial Statement with turnover declared in Annual Return (GSTR 9) As the title itself clarifies, reconciliation of gross and taxable turnover, comparing figures reflected in audited financial statement and figures reflected in GST annual return, needs to be provided and in case of any difference in the same the reason for the same needs to be mentioned.
III Reconciliation of tax paid Rate-wise bifurcation of tax liability is required to be provided here and in case of any difference in tax paid and tax declared in annual return (FORM GSTR 9) the appropriate reason for the said difference needs to be provided here.
IV Reconciliation of Input Tax Credit Input tax credit reflected in the audited financial statement would be reconciled with the input tax credit claimed in annual return (GSTR 9) and in case of any difference, in the same, appropriate reason for the same needs to be provided here.
V Auditor’s recommendation on additional liability due to non-reconciliation This is auditor’s column, under this part the auditor is required to recommend the additional liability, if any, on account of a difference in either the turnover or the input tax credit or both or any other amount payable.

Likewise, Part B – Certification is sub-divided into 2 different parts. The said sub-divided 2 parts of Part B, along with the basic understanding of the same, is tabulated hereunder –

PART TITLE EXPLANATION
I Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by the person who had conducted the audit. The title itself is self-explanatory. In case the person who has conducted an audit is certifying FORM GSTR 9C then the part I is applicable.
II Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the person who has conducted the audit of the accounts. The title itself is self-explanatory. In case the person other than the person who has conducted an audit is certifying FORM GSTR 9C then part II is applicable.

View Comments (4)

  • Dear friend, The Act has defined Form GSTR 9-C prescribed under Section 35 (5) and Sec 44(2) read with GST Rule 83 (10). The GST Act/ Rule has not defined reconciliation Statement as a Audit Report . whereas prepare and signing the Statements and / to verification process in the common portal, the powers were given to GST Practitioners only. under GST Act Sec 48; read with GST Rule 83 (10)

  • GSTR 9-C prescribed under Section 35 (5) and Sec 44(2) read with GST Rule 80 (3). But powers were given only to GST Practitioners specifically prescribed in GST Rule 83 (10) read with Sec.48 for preparing, verify and signing the statements required under GST Act and Rules and to its processing in the common portal

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