As we are into 1st week of December 2022, the said month assumes comparatively more importance from GST compliance perspective since 31 December 2022 is the due date to furnish GSTR 9 and GSTR 9C for FY 2021-22. In this article, we would mainly comment on applicability of GSTR 9 and 9C along-with key pre-requisites.

1. Applicability for FY 2021-22:

The applicability of GSTR 9 and GSTR 9C for FY 2021-22 is akin to that of FY 2020-21. However, for easy reference, we have reiterated the same below:

  • GSTR 9 is to be furnished by all taxpayers whose aggregate turnover exceeds INR 2 crore.
  • Conversely, GSTR 9 is exempt for taxpayers whose aggregate turnover is less than or equal to INR 2 crore.
  • Further, a self-certified statement in GSTR 9C should be furnished by taxpayers whose aggregate turnover exceeds INR 5 crore.
  • Accordingly, a taxpayer (whose aggregate turnover is between INR 2 crores and INR 5 crore) is required to only file GSTR 9.

2. Key Pre-Requisites:

  • Finalisation of books of accounts.
  • In case of multi-state GSTINs, extraction of state-wise trial balance whereby total of all states should be tallied with turnover/ input tax credit (‘ITC’) as per financials.
  • From outward perspective, transactional level reconciliation of GSTR 1 vs GSTR 3B vs books of accounts.
  • From inward perspective, transactional level reconciliation of GSTR 2B vs GSTR 3B vs books of accounts.
  • To track reporting of outward as well as inward supply transactions (along-with amendments) of FY 2021-22 in GSTR 1/ GSTR 3B of April 2022 to October 2022 tax periods filed till 30 November 2022.
  • To also extract details of ITC pertaining to FY 2020-21 availed in FY 2021-22 for reporting the same in GSTR 9C.
  • HSN wise outward supply details should be collated. (6 digit HSN for taxpayers with more than INR 5 crore turnover. 4 digit HSN for all B2B supplies by taxpayers having less than INR 5 crore turnover).
  • GST rate-wise break-up of turnover as well as liability reported in GSTR 9 should be prepared (along-with RCM transactions).
  • To verify GST data available on income tax website.

GSTR 9 and 9C - Optional to Mandatory reporting in FY 2021-22

3. Key change (from optional to mandatory reporting) in FY 2021-22 GSTR 9 and 9C:

Table – GSTR 9 Particulars Reporting in FY 2021-22 Remarks
4I, 4J, 4K and 4L Credit notes / Debit notes/Amendments (+)/(-) with respect to Table 4B to Table 4E Mandatory to disclose separately
5D and 5E Exempted and NIL rated supply Exempt and NIL rated supply can either be shown separately in Table 5D and 5E or the consolidated value could be disclosed in Table 5D.
5F Non-GST supply (includes ‘no supply’) Mandatory to disclose separately
6C RCM ITC on procurement from unregistered person Mandatory to disclose separately No option to report consolidated 6C and 6D value in Table 6D. The said option was available till FY 2020-21.
6D RCM ITC on procurement from registered person Mandatory to disclose separately
17 HSN wise summary of Outward Supplies Mandatory to disclose separately 6 digit HSN for taxpayers with more than INR 5 crore turnover.

4 digit HSN for all B2B supplies by taxpayers having turnover upto INR 5 crore.

Table – GSTR 9C Particulars Reporting in FY 2021-22 Remarks
12A to 12D Reconciliation of net ITC as per financials with ITC as per GSTR 9 Mandatory to disclose Table 12B and Table 12C separately Disclosure of values in Table 12B and Table 12C was optional till FY 2020-21

The aforesaid tables should be thoroughly looked into as these changes are applicable only from FY 2021-22 onwards. Therefore, the possibility of IT systems not being geared up to the reporting requirements is quite high.

Disclaimer: This article provides general information existing at the time of preparation and we take no responsibility to update it with the subsequent changes in the law. The article is intended as a news update and Affluence Advisory neither assumes nor accepts any responsibility for any loss arising to any person acting or refraining from acting as a result of any material contained in this article. It is recommended that professional advice be taken based on specific facts and circumstances. This article does not substitute the need to refer to the original pronouncement

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