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Indirect Tax Committee of ICAI has submitted 23 Suggestions on GSTR 9– Annual GST Return to Hon’ble Union Minister of Finance, Shri Arun Jaitley, which are as follows:-
Suggestions on GST Annual return form
EXECUTIVE SUMMARY
| S. No. | Topic(s) | Suggestion (s) |
| 1. | Total amount of ITC availed through Form GSTR 3B |
It is suggested that Table 6 (A) figures be auto populated from table 4A to 4D as applicable in spite of only from 4A. |
| 2. | Table 18 HSN inward is required whereas no such requirement in GSTR 3B | It is suggested that this requirement of reporting of HSN wise inward supplies be done away with. |
| 3. | Part I and J of table 8 require same information | It is suggested that intention for putting separate rows for same information be clarified. |
| 4. | Compilation of Returns filed earlier |
It is suggested that data in GSTR 9 be auto populated from the returns filed earlier. |
| 5. | Segregated details of ITC availed as I/IS/CG | It is suggested that since there is no difference in treatment of ITC on Goods & services and such details were not asked in earlier period returns therefore the bifurcation of the same in the Annual return leads to recapturing of accounting entries as assessee has not recorded the same in the notified formats, therefore such requirement be omitted. |
| 6. | Details of outward and inward supplies declared during the financial year | It is suggested that suitable clarification be issued clarifying upto what extent information can be furnished in the annual return. It may also be clarified whether an assessee can furnish information beyond earlier submitted returns. |
| 7. | ITC as per GST 2 A | It is suggested to clarify whether ITC will be available to the assessee on the basis of GSTR 2A even if conditions of section 16 are not complied with. |
| 8. | Part V of GSTR 9 disclosure or reporting |
It is suggested that a suitable clarification be issued regarding providing particulars of transactions declared in returns upto date of filing of annual return of previous year is just a reporting requirement or a tax calculation mechanism. |
| 9. | Requirement to report Debit note / credit note issued this year | It is suggested that suitable explanation with proper examples be given to clarify whether Debit/ credit note issued in 201819 for 2017-18, should that be reported in this Form. |
| 10. | Segregated details of outward supplies on which tax is not payable | It is suggested to merge the requirement of supplies on which tax is not payable despite separate reporting of nil, exempted and non-taxable supply as it is not serving any purpose but causing difficulty in compilation as these segregations have not been captured by assessee. |
| 11. | Clarification on Taxes Payable |
It is suggested that suitable explanation with proper examples be given to clarify the tax Payable reporting in Part II and Part IV. |
| 12. | Reporting of Amendments | It is suggested that suitable explanation with proper examples be given to clarify whether Part V is merely a subset of Part II to be used as reconciling item for the subsequent year. |
| 13. | Requirement for filing details of ineligible ITC be done away | It is suggested that this requirement of reporting information related to ITC available but ineligible, be do away with as this credit is not eligible and reporting of same is not serving any purpose. |
| 14. | Option of Period selection should be there in GSTR 9 | It is suggested that option for selection of period for which taxpayer is filing Annual return be provided in the return. |
| 15. | Due date of filing the form be extended | It is suggested that the due date of GSTR 9 be extended to 31st March, 2019. |
| 16. | Cross charge be taken in Annual return | It is suggested to clarify the reporting of cross charge in Annual return. |
| 17. | Reporting requirements | It is suggested that the reporting requirement of pre-GST supplies and Non-GST supplies under GSTR-9 be clarified. |
| 18. | Some Sort of Notes to Annual Return | Word file to insert some description / Explanation should be provided at the end so that transactions which are reported by mistake or left out or incorrectly reported & which are very difficult to correct via subsequent GSTR 3B or 1 even as per circular 26 for any reason, can be explained by the taxable person & hence it can act as a disclosure tool in connection with the concealment part specified in the Verification at the end |
| 19. | To capture difference between GSTR 2A and GSTR 3B | It is suggested to incorporate other reasons of difference in the table. |
| 20. | ITC reversed during the year and reclaimed specifically in case of 180 days | It is suggested to provide respective column to avail such credit. |
| 21. | Difference of opinion between any additional taxes (HSN difference or POS difference / valuation difference etc.) | It is suggested to clarify difference of opinion between any additional taxes (HSN difference or POS difference / valuation difference etc.) and how to report such transactions. |
| 22. | Other suggestions | It is suggested to issue suitable clarifications on the following:> Whether the formats of Annexures are standardized or can be customized in terms of presentation?> Whether the information to be provided on Input Tax Credit restrictions as per sections 17(5), 42 and 43 of CGST Act, 2017 should be detailed or consolidated value?> In Table 15, there is no clarity on how to provide details on various types of refunds in relation to exports, inverted duty structure, wrong payments and double tax payments.> As per the Annual return there is 2 years reconciliation statement required, whether the annexures in relation to this are standardized or can be customized? |
| 23. | Permit availment of ITC pertaining to FY 2017-18 till filing of Annual return | It is suggested to make suitable modification in Form GSTR 9 to allow input tax credit for invoices pertaining to FY 2017-18 till 31st December, 2018 |
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V V practical & worthy suggestions. Sad that the Govt has not taken into confidence the premier body before formulating the Annual Return.
The Suggestions are really commendable and the Govt should treat the suggestions in Right Spirit & see that the GST Returns are still made Simpler instead of number of returns. At the Same time 3B return may please be done away with
Fantastic job! very important and valuable suggestions