As we approach the end of the financial year 2022-23, it’s crucial for businesses to understand the applicability of GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement). The applicability of these returns depends on your aggregate turnover, and compliance is essential to avoid late fees and interest charges. In this article, we’ll explore the applicability of GSTR-9 and GSTR-9C for different turnover categories and delve into the reporting requirements for each.
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APPLICABILTY OF GSTR-9 & GSTR9C FOR FY 2022-23
| S.NO | TURNOVER | GSTR-9 APPLICABILITY | GSTR-9C APPLICABILITY |
| 1. | Aggregate turnover is Less than Rs 2 crore. | No (Can File Voluntarily) | No (Can File Voluntarily) |
| 2. | Aggregate turnover is exceeds Rs 2 crore but upto Rs 5 Crores. | Yes | No (Can File Voluntarily) |
| 3. | Aggregate turnover exceeds Rs 5 Crores | Yes | Yes |
| Following List of Taxpayers need not to file GSTR-9:
ISD, Taxpayers opting for Composition scheme, Casual taxable person, NRTP, Persons paying TDS under section 51 or TCS under section 52, Persons supplying OIDAR services from out of India to a person in India Due Date for filing GSTR-9 & GSTR-9C for FY 2022-23 is 31-12-2023 |
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GSTR-9 & GSTR-9C MANDATORY V/S OPTIONAL REPORTING FOR FY 2022-23
| FORM GSTR-9 ANNUAL RETURN | ||
| TABLE NO: | PARTICULARS | NATURE OF REPORTING |
| 4A to 4G | Taxable Outward Supplies (B2C, B2B, Zero rated supply (Export) on payment of tax (except supplies to SEZs), Supply to SEZs on payment of tax, Deemed Exports), Advances on which tax has been paid but invoice has not been issued & Inward Supplies on which tax is to be paid on RCM basis |
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| 4I to 4L | Credit Notes, Debit Notes, Amendments with respect to 4B to 4E Supplies |
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| 5A to 5C | Zero Rated Supply (Export) without payment of tax, Supplies to SEZ without payment of tax, Supplies on which tax is to be paid by recipient on RCM basis |
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| 5D to 5F | Exempted, Nil-Rated & Non-GST Supply (includes no supply) |
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| 5H to 5K | Credit Notes, Debit Notes, Amendments with respect to 5A to 5F Supplies |
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| 6A | Auto Populated ITC Availed through GSTR3B (Sum total of Table 4A of Form GSTR3B) | – |
| 6B to 6D | ITC on Inward Supplies for forward charge & Reverse Charge (Inputs, Capital Goods, Input Services) |
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| 6E | Import of Goods (Including supplies from SEZ) |
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| 6F to 6M | Other ITC Availed Related Information |
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| 7A to 7E | ITC Reversal as per Rule 37,39,42,43, Section 17(5) |
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| 7F & 7G | ITC Reversal due to Tran-I & Tran-II credit |
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| 8A to 8K | Other ITC Related Information |
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| 9 | Details of Tax Paid as Declared in returns filed during the year |
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| 10,11 | Outward Liability pertaining to FY 2022-23 shown/reduced in FY 2023-24 till 30th Nov 2023 (NN 18/2022-CT) |
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| 12,13 | ITC pertaining to FY 2022-23 reversed/shown in FY 2023-24 till 30th Nov 2023 (NN 18/2022-CT) |
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| 14 | Differential Tax paid on account of declaration in 10 & 11 above | – |
| 15,16 | Information of Demands & Refunds & Information on Supplies received from Composition Taxpayers, deemed supply under section 143 and goods sent on approval basis |
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| 17 | HSN for Outward Supply |
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| 18 | HSN for Inward Supply |
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FORM GSTR-9C RECONCILIATION STATEMENT | |
| TABLE NO: | PARTICULARS | NATURE OF REPORTING |
| PT II (5A) | Turnover (including exports) as per audited financial statements for the State / UT (For multi-GSTIN units under same PAN the turnover shall be derived from the audited Annual Financial Statement) |
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| PT II (5B-5O) | Adjustments related to turnover |
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| PT II (6) | Reasons for Un-Reconciled Difference in Annual Gross Turnover | – |
| PT II (7A to 7F) | Reconciliation of Taxable Turnover |
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| PT II (8) | Reasons for Un-Reconciled Difference in Taxable Turnover | – |
| PT III (9A to 9Q) | Reconciliation of Rate-wise Liability and Amount Payable |
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| PT III (10) | Reasons for Un-reconciled Payment of Tax | – |
| PT IV (11A to 11K) | Additional Amount Payable but Not Paid (due to reasons specified under Table No: 6,8 and 10) | – |
| PT IV (12A to 12D) | Reconciliation of Net Input Tax Credit (ITC) |
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| PT IV (13) | Reasons for Un-reconciled Difference in ITC | – |
| PT IV (14) | Reconciliation of ITC Declared in Annual Return (GSTR9) with ITC Availed on Expenses as per Audited Annual Financial Statement or Books of Account |
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| PT IV (15) | Reasons for Un-reconciled Difference in ITC | – |
| PT IV (16) | Tax Payable on Un-reconciled Difference in ITC (due to reasons specified in Table No: 13 and 15) | – |
| PT V | Additional Liability Due to Non-reconciliation | – |
| Refer Notifications: – 56/2019-CT Dated 14-11-2019, 79/2020-CT Dated 15-10-2020, 30/2021-CT Dated 30-07-2021, 14/2022-CT Dated 05-07-2022, 38/2023-CT Dated 04-08-2023 | ||
LATE FEE FOR DELAYED FILING OF GSTR-9 & GSTR-9C FOR FY-2022-23*
| S.NO | Registered Person having Aggregate Annual Turnover | Late Fees |
| 1 | Upto Rs 5 Crore | Rs 50 per day (Rs25 + Rs25/-), Subject to the maximum of an amount of 0.04% of turnover in the state or Union territory |
| 2 | Rs 5 crores to Rs 20 crores | Rs. 50 per day (Rs25 + Rs25/-), Subject to a maximum of an amount of 0.04% of turnover in the state or Union territory |
| 3 | More than Rs 20 Crores | Rs 200 per day (Rs100 + Rs100/-), Subject to a maximum of an amount of 0.5% of turnover in the state or Union territory |
*Refer Notification No: 07/2023-CT Dated 31-03-2023
INTEREST COMPUTATION UNDER SECTION 50 READ WITH RULE 88B
| S.NO | NATURE OF LIABILITY | COMPUTATION |
| 1. | Output liability | @ 18% p.a. – On Net Tax Liability -Where supplies made during tax period are declared in the return for the said period. If not then @ 18% p.a. on Gross Tax Liability (irrespective of ITC balance availability.) |
| 2. | RCM liability | @18% p.a. – Always on Gross basis as RCM tax liability is always payable in cash. |
| 3. | ITC | @18% p.a. – Only when ITC ‘wrongly availed and utilized’ exceeds the balance in electronic credit ledger.
Where ‘IGST ITC wrongly availed and utilized’, then total balance in electronic credit ledger under the heads of IGST + CGST + SGST taken together has to be considered for calculation of interest under section 50(3) read with rule 88B |
Conclusion:
Understanding the applicability of GSTR-9 and GSTR-9C for FY 2022-23 is crucial for taxpayers to ensure compliance and avoid late fees and interest charges. The nature of reporting, whether mandatory or optional, varies based on the type of transaction and the category of the taxpayer’s turnover. By adhering to the deadlines and reporting requirements, businesses can maintain transparency and meet their GST compliance obligations effectively. It’s advisable to seek professional guidance for accurate and timely filing to prevent financial and legal consequences.
Disclaimer: The views expressed are strictly of the author. The contents of this document are solely for informational purpose. It does not constitute professional advice or recommendation. The author does not accept any liabilities for any loss or damage of any kind arising out of any information in this article nor for any actions taken in reliance thereon.
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