The essence of GSTR-9 and GSTR-9C lies in Section 44 of the CGST Act, which mandates the filing of an annual return and a reconciliation statement within the prescribed due date. However, a pertinent question arises—have these annual compliances truly achieved the intended objective envisioned by the legislature?
The primary intent behind introducing the Annual Return (GSTR-9) was to enable taxpayers to provide a consolidated summary of outward supplies, input tax credits, and tax liabilities for the year, thereby allowing the department to verify the correctness of disclosures made in the periodic returns. Similarly, GSTR-9C, the reconciliation statement certified by a professional, was designed to ensure accuracy between the books of accounts and the returns filed.
However, in practice, these objectives seem far from being realized. Since the inception of GST in 2017-18, departmental scrutiny, assessments, and notice issuances—whether under Section 61 (ASMT-10) or Sections 73 and 74 (DRC-01)—have continued independently of the Annual Return or Reconciliation Statement. Notably, most notices are issued solely based on the data furnished in GSTR-1 and GSTR-3B, without any reference to the filed GSTR-9 or 9C.
This raises a fundamental question about the utility of these compliances. If the department itself rarely refers to these filings before initiating proceedings, is there any real value in investing countless hours and professional effort into them? The irony is further compounded by the fact that even departmental officers often lack familiarity with the complex structure of these returns, leading to their limited use in compliance verification or assessments.
Adding to the challenge, taxpayers face rigidity in rectifying inadvertent errors in the annual return or reconciliation statement, as no provision currently allows revision once filed. As rightly said, “Every rose has its thorn,” this lack of flexibility underscores the persistent hurdles despite refinements. Although the filing schema has undergone multiple iterations with the aim of better accuracy and alignment, it still falls short of delivering the intended transparency and simplification. The time and resources devoted to filing these returns should ideally serve a meaningful regulatory purpose.
Conclusion: One can only hope that the legislature undertakes a thoughtful reconsideration of the framework governing GSTR-9 and GSTR-9C, aligning these annual compliances more closely with their intended objectives. When originally conceptualized, these forms were envisioned as instruments to promote transparency, accuracy, and self-assessment discipline within the GST ecosystem—facilitating meaningful reconciliation between the taxpayer’s records and the data reported to the authorities. A recalibration of these forms is therefore necessary to ensure that their requirements are focusing on substantive validation of tax positions rather than repetitive reporting of information already available on the GST portal.
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Correctly pointed out the issue