GSTR-4 (NEW) Vs. GSTR-9A (For Composition Tax Payers )

The most awaited form GSTR-4 (Yearly) has been made available on the GSTN portal to be filed by all Composition Taxable persons on or before extended due date i.e. 31.08.2020. Earlier this GSTR-4 form is required to be filed on Quarterly basis till financial year 2018-19. Later the content of the form has been changed along with periodicity of filing (shifted to yearly) the same without change in the number allotted to this form. Whereas from 01.04.2019, composition taxpayers are required to file Form GST CMP 08 (Statement for payment of Self-assessed tax), on quarterly basis. 

Surprisingly it is mentioned as “GSTR-4 Annual Return” in the News update dt.21.07.2020, FAQs & user manual as well hosted at GSTN portal which is not as per the law since it is mentioned as a Return for Financial year vide form GSTR-4 notified earlier.

Path: Logon to your dashboard, click on Services > Returns > Annual Return >Select FY>Search>GSTR 4> FILE THE RETURN.

 Currently only the online filing has been enabled on the portal. Shortly offline tool will also be made available.

This has caused a major confusion among the stakeholders that should a Taxpayer need to file both GSTR-4 & GSTR-9A returns for the same financial year and if so what is the difference between these two return forms ?

Here is the basic differences one should know between GSTR-4 & GSTR-9A Return Forms:-

1) It is a Return for Financial Year prescribed u/s.39 r.w.r 6 2 To be filed on or before 30th  April. (Now extended upto 31.08.2020 for F.Y 2019-20) It is an Annual Return prescribed u/s. 44 r.w.r 80 to be filed for every Financial Year.
2) Mandatory w.e.f F Y: 2019-20 onwards. It has been made optional for F Y:2018-19 but Mandatory for FY: 2019-20 to be filed by 31.12.2020 in addition to GSTR-4.
 3) Inward Supplies including supplies on which tax is to be paid on  reverse charge are to be Furnished at INVOICE LEVEL (As per GST portal to be furnished at GSTIN & RATE wise entries) Here consolidated figures for Inward Supplies is to be furnished (Taxable Value & Taxes break up).  Rate wise summary is not required.
4) No such provision is available here. Particulars of the transactions for the previous FY Declared in returns of April to September of current FY or upto date of filing of annual return of  previous FY whichever is earlier has to be furnished in this Return.
5) No such requirement in this Return. Particulars of Refunds & Demands (claimed, rejected, Etc) is to be filled under Other Information table.
6) No such requirement in this Return. Details of input tax credit reversed or availed To be disclosed here if a Taxpayer opt in / out of Composition Scheme.

Finally it is very difficult to convince a Taxpayer and make him ready to file both returns for one financial year in this Covid-19 pandemic situation. Moreover it is better and convenient to all if both the forms are merged and may be denoted as GSTR-4A in order to save valuable time of Tax Consultants and cost perspective to the Tax Payers as well.

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Location: GUNTUR, Andhra Pradesh, IN
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Tax Consultant (IT & VAT) since 1993 also Certified GSTP. View Full Profile

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One Comment

  1. Achyutanna Ranga Rao says:

    Good discussion on the new returns relates to composition tax payers. How ever this may not be right time to brought new system at this COVD-19 time

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May 2021