The government has issued the notifications providing the details for filing of annual return in Form GSTR-9 and reconciliation statement in Form GSTR-9C for FY 2020-21. In its continued endeavor to reduce the burden on small taxpayers, the government has issued Notification No 29/2021-Central Tax, Notification No. 30/2021-Central Tax and Notification No. 31/2021-Central Tax dated 30 July 2021. Through these notifications, the government is trying to reduce the annual compliances burden on the small taxpayers.

Notification No 29 /2021-Central Tax dated 30 July 2021 strikes off the illustration of an isolated hand giving the GST Goods and Services Tax Section 35(5) of CGST Act, 2017 thus eliminating the mandatory requirement of audit under GST by a CA or CMA. It also amends Section 44 of CGST Act, 2017 dealing with annual return and reconciliation statement.

Notification No 30/2021-Central Tax dated 30 July 2021 amends Rule 80 of CGST Rules, 2017 and Form GSTR-9 and Form GSTR-9C. Further, taxpayers having aggregate turnover upto INR 5 crores have been exempted from filing of reconciliation statement in GSTR-9C. The major amendments are as follows:

GSTR-9 – Annual return

Outward supply details

Table No of Form GSTR-9 Table details Optional or mandatory Additional remarks, if any
4. Details of advances, inward and outward supplies made during the year on which tax is payable
4A to 4G B2C (4A) and B2B (4B) supplies, Export (4C) and SEZ (4D) supplies on payment of tax, deemed exports (4E), advances on which tax paid but invoice not issued (4F), inward supplies on which tax is paid on RCM basis (4G) Mandatory, if details available
4I Credit Notes issued in respect of transactions specified in Table 4B to 4E. Optional The credit notes can be consolidated in detail reported in Table 4B to 4E instead of reporting here separately.
4J Debit Notes issued in respect of transactions specified in Table 4B to 4E. Optional The debit notes can be consolidated in detail reported in Table 4B to 4E instead of reporting here separately.
4K and 4L Supplies / tax declared through Amendments & Supplies / tax reduced through Amendments Optional The amendments can be adjusted against details reported in Table 4B to 4E instead of reporting here separately.
5. Details of Outward supplies made during the financial year on which tax is not payable
5A, 5B and 5C Export (5A) and SEZ (5B) supplies without payment of tax, supplies on which tax is to be paid by recipient on reverse charge basis (5C). Mandatory
5D, 5E and 5F Exempted, Nil Rated & Non-GST supply Optional The details of such supplies can be provided in “Exempt” field in Table 5D on consolidated basis, if bifurcation of such supplies in not available.
5H Credit Notes issued in respect of transactions specified in Table 5A to 5F. Optional The credit notes can be consolidated in detail reported in Table 5A to 5F instead of reporting here separately.
5I Debit Notes issued in respect of transactions specified in Table 5A to 5F. Optional The debit notes can be consolidated in detail reported in Table 5A to 5F instead of reporting here separately.
5J and 5K Supplies declared through

Amendments & Supplies reduced through Amendments

Optional The amendments can be adjusted against details reported in Table 5A to 5F instead of reporting here separately.

ITC details and onward tables

6. Details of ITC availed during the financial year
6B Inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) Partly optional The details of capital goods need to be reported separately. However, details of inputs and input services can be reported on a consolidated basis under the head ‘Inputs’.
6C Inward supplies received from unregistered persons liable to reverse charge (other than 6B above) on which tax is paid & ITC availed Optional The details of Table 6C can be reported on a consolidated basis in Table 6D. Further, the details of capital goods need to be reported separately. However, details of inputs and input services can be reported on a consolidated basis under the head ‘Inputs’.
6D Inward supplies received from registered persons liable to reverse charge (other than B above) on which tax is paid and ITC availed. Mandatory, if details available
6E Import of goods (including supplies from SEZ) Mandatory The details of capital goods need to be reported separately. However, details of inputs and input services can be reported on a consolidated basis under the head ‘Inputs’.
6F Import of services (including inward supplies from SEZ) Mandatory
6G ITC received from ISD Mandatory
6H Amount of ITC reclaimed (Other than Table 6B) Mandatory
7. Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year
7A, 7B, 7C, 7D, 7E, 7F, 7G and 7H As per Rule 37, Rule 39, Rule 42, Rule 43, Section 17(5), Reversal of TRAN-I credit, Reversal of TRAN-II credit, Other reversals Partly Optional Accumulated amount of reversal from 7A to 7E can be filled in 7H i.e. in ‘Other reversal’, but reversal of Transitional credit fields are mandatory.
8A ITC from GSTR-2A Auto-populated The total credit available for inwards supplies (other than imports and inwards supplies liable to reverse charge but includes services received from SEZs) pertaining to the FY 2020-21 and reflected in Form GSTR-2A (table 3 & 5 only) shall be auto-populated in this table.
8B ITC as per Table 6B + 6H Auto-populated This table is auto-populated basis the details furnished in Table 6B and Table 6H in the annual return.
8C ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during the financial year but availed in the next FY (2021-22) year up to September 2021. Mandatory This table contains the details of ITC in respect of inward supply invoices received during the FY 2020-21 but availed in FY 2021-22 upto the GSTR-3 to be filed for the month of September 2021.
8E and 8F ITC available but not availed (8E) and ITC available but ineligible (8F) Mandatory Ideally, if the value of Table 8D is positive, then the sum total of 8E and 8F shall be equal to 8D.
8G IGST paid on import of goods (including supplies from SEZ) Mandatory
9 Details of tax paid as declared in returns filed during the financial year. Mandatory This table is mandatory. It is required to be filled on the basis of tax payable and paid as declared in GSTR-1 and GSTR-3B.
10 & 11 Supplies / tax declared through amendments and Supplies / tax reduced through amendments Optional Amendment of invoices pertaining to FY 2020-21 made in GSTR 1 filed for the period between April 2021 to September 2021 is to be declared here.
12 Reversal of ITC availed during previous financial year Optional ITC for the FY 2020-21 reversed in GSTR-3B for the period between April 2021 to September 2021 is required to be declared here.
13 ITC availed for the previous financial year Optional ITC for the FY 2020-21 availed in GSTR 3B filed for the period between April 2021 to September 2021 is to be declared here. ITC reversed in 2020-21 as per provisions of Section 16(2) but reclaimed in GSTR 3B for the period between April 2021 to September 2021 will not come in this table as the same will be furnished in annual return to be filed for FY 2021-22.
14 Differential tax payable on account of declarations made in Table 10 and 11. Mandatory, if any tax becomes payable. This table contains the tax payable as a result of declarations made in Table 10 and Table 11.
15A, 15B, 15C and 15D Details of refund claimed during the year including sanctioned, rejected or pending amount. Optional It is not mandatory to provide refund related details.
15E, 15F and 15G It also covers total demand of taxed made during the year, amount paid and pending amount. Optional It is not mandatory to provide demand details in GSTR-9.
16A, 16B and 16C Supplies received from Composition taxpayers (16A), deemed supply under Section 143 (16B), goods sent on approval basis but not returned (16C). Optional It is not mandatory to fill Table 16.
17 and 18 HSN Wise Summary of outward supplies and HSN Wise Summary of Inward supplies Optional It is not mandatory to fill the HSN summary.
19 Late fee payable and paid Mandatory, wherever applicable If annual return is filed late, this table is required to be filled.

GSTR-9C – Reconciliation statement

  1. Form GSTR-9C has to be self-certified by the taxpayer instead of being certified by CA/ CMA.
  1. The relaxations provided in reporting of data for certain tables of Form GSTR-9C in FY 2020-21 will continue for FY 2020-21 as well.
  1. Verification table by CA/CMA in Part B of Form GSTR-9C has been deleted. Now, only verification by the registered person is required in GSTR-9C for applicable registered taxpayers.

Notification No 31/2021-Central Tax dated 30 July 2021 has exempted the registered persons with aggregate turnover upto INR 2 crores in FY 2020-21 from filing of Form GSTR-9 for FY 2020-21.

Due date of filing: The due date to file GSTR-9 and GSTR-9C for FY 2020-21 is on or before 31 December 2021.

Late fee for delay in filing: Any registered person failing to furnish the GSTR-9 by the due date, shall be liable to pay a late fee of INR 200 (INR 100 for CGST and SGST each) every day during which such failure continues subject to a maximum of an amount calculated at a half per cent of his turnover in the State or Union territory. Further, while calculating maximum late fee, ‘turnover in State’ or ‘turnover in Union territory’ should be taken into consideration.

Through the above amendments, the government has tried to reduce the compliance burden on taxpayers but at the same time putting onus on taxpayers to provide, true and correct information in the annual return and reconciliation statement.

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Disclaimer: The above article is based on the information provided in the tax laws, rules, notifications, circulars, various tax platforms and the author’s personal view of the tax law. Please refer to the latest law and consult the author before forming an opinion basis the information provided above as tax laws are subject to frequent changes. The author is not responsible for any issues arising as a result of opinion based on the above article without consultation. The author welcomes the feedback of the readers at [email protected] .

The views expressed in the article are personal views of the author and in no way should be construed to be the views of the firm that the author is associated with.

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6 Comments

  1. RAJESH SHARMA says:

    I am a accountant and gst and income tax practice I like your article. Now Request to you please give the new article agst. GST Rule-10 agst. GST Cancellation Notice and How to complain agst. local gst Astt.comm. to Upper department.

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