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The due date of filing the GSTR 9 Annual return and GSTR 9C Audit for FY 2018-19 is 30th Sept 2020 [NN 41/2020 – CT] – However it may extend to December 2020 due to the COVID outbreak and there having several representations made for the same.

Applicability of GSTR-9 and 9C for FY 2018-19

Aggregate turnover* GSTR-9  GSTR-9C Audit Reference
Up to 2 crs Optional Optional Sec 35(5) r/w 80(3)
More thane 2 crs to 5 crs Mandatory Optional [benefit given] The proviso to rule 80(3)
More than 5 crs Mandatory Mandatory S. 44(1) r/w rule 80(3)

*Aggregate turnover: In accordance with section  2(6) of CGST Act, Aggregate turnover to means the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess; 


1. Section 35(5) Every registered person whose turnover during a financial year exceeds the prescribed limit shall get his accounts audited by a chartered accountant or a cost accountant and shall submit a copy of the audited annual accounts, the reconciliation statement under sub-section (2) of section 44 and such other documents in such form and manner as may be prescribed.

2. The above clause of GST Audit would not apply to any department of the central government ora State Government or a local authority, whose books of account are subject to audit by the Comptroller and Auditor-General of India or an auditor appointed for auditing the accounts of local authorities under any law for the time being in force

3. Every registered person whose aggregate turnover during the financial year 2018-2019 exceeds five-crore rupees shall get his accounts audited as specified under sub-section (5) of section 35 and he shall furnish a copy of audited annual accounts and a reconciliation the statement, duly certified, in FORM GSTR-9Cfor the financial year 2018-2019.

Relaxation in GSTR 9 for 2018-19

Undisclosed liability

It is clarified in the form that additional liability i.e. unpaid liability such as

1. short disclosed in GSTR-3 when compared to GSTR-1

2. liability of invoices did not disclose

3. RCM liability not paid

4. Reconcile the account balance with all the customers to ensure that there are no differences which may creep up at a later point of time where there is any difference on short paid pay in GSTR-9

The above liability not disclosed in FY 2018-19 in GSTR 1 and GSTR 3B can be disclosed in GSTR-9.

Note that  ITC not availed within time limit [i.e. for FY 2018-19 it was 20.10.2019 Sept GSTR-3B due date] cannot be claimed through the annual return. Only excess availed needs to pay back along with interest [ Interest to paid only when it was utilized from electronic credit ledger sec. 50 r/w sec. 100 of the Finance (No. 2) Act, 2019 r/w NN 63/2020 CT] 

Credit notes/ Debit notes/ Amendments option: 

Option to show outward supplies such as B2B, SEZ supplies, Exports, Deemed exports net of credit notes, debit notes and amendments, instead of separately disclosing in Table 4I, 4J, 4K & 4L respectively.

Similarly for credit notes/debit notes/amendments in lieu of outward supplies on which tax is not payable. (Table 5H, 5I, 5J & 5K) This is available for FY 2017-18 & FY 2018-19 only. 

Exempt, Nil rated & non-GST supply: 

In Table 5D, 5E & 5F – Option to disclose exempted, nil rated and Non-GST supply under “Exempt supply” for FY 2017-18 & FY 2018-19 only. 

ITC bifurcation into Inputs/Input Services/Capital goods optional: 

The details of Inward supplies, ITC on RCM paid and Imports of goods – option to provide break-up of ITC under Inputs, Input Services and Capital goods has been provided. Where not possible, entire ITC can be disclosed under “Inputs” only. This is available for FY 2017-18 & FY 2018-19 only. 

ITC on RCM segregation optional and could be merged

Table 6C & 6D (ITC on RCM from un-registered or registered parties) – option available to club the values and disclose as one under Table 6D only (ITC-RCM on registered entities). This is available for FY 2017-18 & FY 2018-19 only.

ITC reversal may be clubbed (other than TRAN reversal): 

Table 7A to 7E which includes ITC reversals under various GST provisions (Rule 37, 39, 42 & 43 & Section 17(5)) – option available to club all such reversals under Table 7H (Others).

Although, specifically provided that TRAN-1& 2 ITC reversals (under Table 7F & 7G) to be disclosed separately mandatorily. This is available for FY 2017-18 & FY 2018-19 only.

GSTR-2A auto-populated

For FY 2018-19 the FORM GSTR-2A generated as on the 1st November 2019 shall be auto-populated in table 8A

GSTR 2A Vs GSTR 3B may be provided with GSTR 9C: 

Option available to the taxpayer, to file GSTR 2A Vs GSTR 3B shown under Table 8A to 8D can be prepared and uploaded as a signed PDF format while filing GSTR 9C.

The auditor’s certification (CA/CMA) would not be required for the same and it could be updated in PDF form in GSTR-9C 

Part V – Table 12 & 13 is optional and may not be filled 

ITC of period FY 2018-19 availed but reversed/availed missed out in April 2019 to September 2019 disclosure for same have been made optional  

Demands & Refund details optional: 

Table 15 – which relates to details of refund claimed, sanctioned, rejected, pending & demands, taxes paid on demands and dues thereof may be filled at the option of the assessee.

Table 16 optional: 

details w.r.t

1. supplies received from composition taxpayers

2. deemed supply under section 143 i.e. deemed from Principal to Job worker if goods/CG not received within 1/3 yrs respectively

3. goods sent on approval basis

The above has been made optional

HSN details – Outward & Inward optional: 

Table 17 & 18 disclosing HSN wise details of inward and outward supplies have been made optional for FY 2017-18 & 2018-19 only.

Author Bio

Partner at Kumar & Associates, Chartered Accountants, and Heading - Indirect Tax division at K. Raghu & Co. Experienced professional in consultation, litigation, and compliance in Indirect Tax (IDT). Qualified as a Chartered Accountant in the year 2022 and he has graduated in the commerce View Full Profile

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  1. Rina says:

    Table 17 & 18 disclosing HSN wise details of inward and outward supplies have been made optional for FY 2017-18 & 2018-19 only. Is it for all taxpayer having turnover about 5 crore

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