GSTR-9 and GSTR-9C for FY 2022-23

A. Introduction:

With the time limit to make amendments and claim ITC in respect of FY 2022-23 being the GST returns of October 2023, the businesses are hustling to complete their reconciliation of both revenue and ITC and make necessary changes in books and GST returns.

All these corrections and reporting lead to the consolidated filing of data in the form of GSTR-9 and GSTR-9C for every financial year.

While GSTR-9 is the consolidation of data reported in GSTR-1 and GSTR-3, GSTR-9C is the reconciliation of turnover reported and ITC claimed in GST returns with the financial statements of the taxpayer. Further, data reported in GSTR-9 and GSTR-9C is one of the preliminary documents considered by GST authorities for identification of discrepancies and issuing scrutiny / demand notices under GST law.

The following paragraphs and tables capture the same for taxpayers.

B. Applicability and due date:

Notification No 29/2021-Central Tax dated 30 July 2021 has stricken off Section 35(5) of Central Goods and Services Tax Act, 2017 (‘CGST Act’) thus eliminating the mandatory requirement of GSTR-9C audit signing by a CA or CMA. Now, it is self-certified by the taxpayer.

The below table summarizes the applicability of GSTR-9 and GSTR-9C before we delve into table wise analysis of the annual return and reconciliation statement:

Sr No. Particulars GSTR-9 GSTR-9C
1 Applicability turnover GST regular taxpayer except with aggregate turnover above INR 2 crores GST regular taxpayer with aggregate turnover above INR 5 crores
2 Exclusions · Casual Taxable Person

· Non-Resident Taxable Person

· Input Service Distributor

· Unique Identification Number Holders

· Online Information and Database Access

Retrieval (OIDAR) Service providers

· Composition Dealers

· Persons subject to TCS or TDS provisions

Not applicable
3 Due date 31st December 2023 31st December 2023
4 Late fee / Penalty for delayed filing Late fees of Rs 200 per day of delay (INR 100 each in case of CGST and SGST) subject to a maximum cap of 0.25% of total turnover in respective State / UT. No specific provision so general penalty under Section 125 i.e., INR 50,000 (25,000 each in case of CGST and SGST)

C. Table wise detailed analysis of GSTR-9 and GSTR-9C:

GSTR-9 – Annual return

1. 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 applicable to the Company
4I Credit Notes issued in respect of transactions specified in Table 4B to 4E. Mandatory The credit notes have to be reported separately.
4J Debit Notes issued in respect of transactions specified in Table 4B to 4E. Mandatory The debit notes have to be reported separately.
4K and 4L Supplies / tax declared through Amendments & Supplies / tax reduced through Amendments Mandatory The amendments have to be reported separately.

Note: The liability declared in Table 4 net of adjustments in Table 10 and 11 shall be considered as final tax liability irrespective of the amount of tax paid through GSTR-3B as well DRC-03 filed during the financial year. Any additional liability arising as a result of such disclosure as per books shall be paid through DRC-03 while filing the annual return.

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 and 5E Exempted (5D) and Nil Rated (5E) Mandatory 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.
5F Non-GST supply Mandatory Includes value of “No Supply”
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.

2. ITC details

6. Details of ITC availed during the financial year
6A Total amount of ITC claimed in GSTR-3B Auto-populated This amount is auto-populated from filed GSTR-3B for April – March period. It is a non-editable field.
6B Inward supplies (other than imports and inward supplies liable to reverse charge but includes services

received from SEZs)

Partly optional for reporting of certain data · 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’.

· ITC claimed, reversed, and reclaimed in GSTR-3B shall be reported in Table 6H and not in this table.

6C Inward supplies received from unregistered persons liable to reverse charge (other than 6B above) on which tax is paid & ITC availed Partly optional for reporting of certain data · The details of capital goods need to be reported separately.

· 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. Partly optional for reporting of certain data · The details of capital goods need to be reported separately.

· Details of inputs and input services can be reported on a consolidated basis under the head ‘Inputs’.

6E Import of goods (including supplies from SEZ) Mandatory · The details of capital goods need to be reported separately.

· 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
6K TRAN-I ITC Mandatory Since the window for TRAN-I was re-opened in FY 2022-23, any ITC availed in TRAN-I needs to be reported here.
6L TRAN-II ITC Mandatory Since the window for TRAN-II was re-opened in FY 2022-23, any ITC availed in TRAN-I needs to be reported here.
6M Any other ITC availed but not specified in 6B to 6L above. Mandatory ITC claimed in GST ITC-01(ITC on stock for newly registered taxpayers) and GST ITC-02 (ITC transferred in case of change in business constitution example merger, demerger, amalgamation etc.) shall be declared here.
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’.

· Reversal of transitional credit fields (7F and 7G) is required to be reported separately.

· The authorities are increasingly scrutinizing the GST reversal under Rule 42/ 43 and Section 17(5). Their separate reporting has also become mandatory in Table 4B now. Hence, it is necessary to ensure that total amount disclosed here matches with GSTR-3B.

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 2021-22 and reflected in Form GSTR-2A (table 3 & 5 only) shall be auto-populated in this table.

Note: For FY 2022-23, as per Section 16(2) of the CGST Act, the taxpayer were required to avail ITC basis the data reflected in GSTR-2B and not GSTR-2A. Hence, reconciliation with GSTR-2A will create additional burden on the taxpayer in terms of differences in reporting by suppliers and availment of ITC by taxpayers.

Further, any notice issued by GST authorities basis Table 8 difference could be easily contested that the GST Act itself has removed the requirement of reconciliation with GSTR-2A and hence, notice cannot be issued basis the same.

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 upto specified period Mandatory This table contains the details of ITC in respect of inward supply invoices received during the FY 2022-23 but availed in FY 2022-23 upto the GSTR-3B for the month of October 2022 filed upto 30 November 2022.
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

3. Other detail tables

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 2022-23 made in GSTR 1 filed for the period between April 2022 to October 2022 filed upto 30th November is to be declared here.

 

· Any tax pertaining to FY 2022-23 paid in FY 2023-24 may be disclosed in Table 10 of GSTR-9.

12 Reversal of ITC availed during previous financial year Optional ITC availed in FY 2022-23 reversed in GSTR-3B for the period between April 2022 to October 2022 filed upto 30th November 2023 is required to be declared here.
13 ITC availed for the previous financial year Optional · Goods / services received in FY 2022-23 for which ITC is availed in GSTR 3B filed for the period between April 2022 to October 2022 upto 30th November 2023 is to be declared here.

· ITC reversed in 2022-23 as per provisions of Section 16(2) but reclaimed in GSTR 3B for the period between April 2022 to October 2022 will not come in this table as the same will be furnished in annual return to be filed for FY 2023-24.

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 HSN Wise Summary of outward supplies Mandatory It is mandatory to fill the HSN summary for outward supplies as follows –

· Above 5 crores – 6 digits

· Upto 5 crores – 4 digits for all B2B suppliers.

18 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 with amount specified in Para B above.

GSTR-9C – Reconciliation statement

1. Form GSTR-9C has to be self-certified by the taxpayer instead of being certified by CA/ CMA.

2. Table 5B – Unbilled Revenue at the beginning of the year can be disclosed in table 5O.

3. Other Turnover reconciliations items from table 5C to 5N – Should be disclosed separately and cannot be clubbed in Table 5O. Earlier, for period upto FY 2021-22 could be clubbed together and reported in table 5O.

4. Table 12B and 12C – Now they are mandatorily required to be disclosed separately.

5. New rate of 6% (3% – CGST and SGST each) included in tax rate table.

6. Table 14 – Optional to fill expense wise ITC claim details.

7. As per the instructions to the filing of GSTR-9C, any liability paid through DRC-03 as a part of difference arising from reconciliation statement shall be discharged through electronic cash ledger only.

Conclusion:

In conclusion, understanding and complying with the requirements of GSTR-9 and GSTR-9C for the financial year 2022-23 is crucial for businesses operating under the GST regime in India. The annual return (GSTR-9) and reconciliation statement (GSTR-9C) play a significant role in consolidating and reconciling financial and tax data, which is vital not only for fulfilling regulatory obligations but also for avoiding scrutiny and demand notices from GST authorities.

The applicability and due dates for these forms have been clarified, and it’s essential for businesses to meet these deadlines to avoid late fees and penalties. The detailed analysis of the various tables within GSTR-9 and GSTR-9C provides valuable insights into the specific data that needs to be reported. Careful and accurate reporting in these tables is essential for maintaining compliance and ensuring smooth business operations.

*****

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 gauravmittal756@gmail.com.

Author Bio

Qualification: CA in Job / Business
Company: Transaction Square
Location: Pune, Maharashtra, India
Member Since: 17 Apr 2021 | Total Posts: 31
Currently working as Assistant Manager at Transaction Square - a marque mergers & acquisitions, tax and advisory firm in India. My main work includes indirect tax due diligences, compliances, advisory, structuring and restructuring support, state incentive schemes and foreign trade policy sup View Full Profile

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16 Comments

  1. Rushi says:

    ” I hereby solemnly affirm and declare that I am uploading the reconciliation statement in Form GSTR-9C prepared and duly signed by the Auditor and the nothing has been tampered or altered by me in the statement.I am also uploading other statements, as applicable, including financial statement, profit and loss account and balance sheet etc…”

    in GSTR-9C verification here asking statement signed by Auditor, the word not removed till can file the GSTR 9C wihtout singed by Auditor…?

  2. Vikas says:

    Hi. Just need a quick clarification – In Table 8C – April to March 22 ITC – received but Claimed in next year will be apperaed correct? i.e., upto November 2023.

    2. In Table 12 & 13 Subsequently ITC claimed in 3B upto November 2023 relating to financial year 2022-23 will be shown correct?gtnauditors@gmail.com

  3. Vikas says:

    Hi. Just need a quick clarification – In Table 8C – April to March 22 ITC – received but Claimed in next year will be apperaed correct? i.e., upto November 2023. 2. In Table 12 & 13 Subsequently ITC claimed in 3B upto november 2023 relating to financial year 2022-23 will be shown correct?gtnauditors@gmail.com

    Read more at: https://taxguru.in/goods-and-service-tax/gstr-9-gstr-9c-fy-2022-23applicabilitydue-dates-analysis.html
    Copyright © Taxguru.in

    1. GAURAV MITTAL says:

      Dear Sir,

      Request you to share the basis for the comment i.e., Notification through which it has become mandatory.

      Regards,
      Gaurav

  4. Zaid Moriswala says:

    Sir I am downloading pdf of article but it was not downloaded properly the sides of the article has been cuts down pdf not show all details.
    How can i found full details please help me

  5. Col SK CHAKRAVARTY says:

    Ifiled GSTR 9 FOR FIN YEAR 2017-18&GSTR9C BY 08 FEB2020.CE
    Due to inadequate knowledge&confusion due to new system entry of exempted amount was shown in colmn 7 instead of coln 8 secondly in GSTR 1b2c the quaterlyl showed excessive amount by mistake. Please advise action.

  6. Gagandeep Singla says:

    sir, Previous year ITC availed this current year.In GST-9 In which column it should show.Because Co. from which we purchased goods Show sale in GSTR-1 this year. Please clarify
    Thanking You.

    1. GAURAV MITTAL says:

      Sir, if it is received by you in FY 2022-23 and recorded in financials of FY 2022-23, then they will appear in Table 8C. However, if they have been reported by vendor in FY 2023-24 in their GSTR-1 and you have recorded them in financials of FY 2023-24 and availed ITC in 3B also in FY 2023-24, then such ITC will not be reported in the GSTR-9 of FY 2022-23.

      Hope this clarifies your query. If you have any further doubt, please reach out to me at gauravmittal756@gmail.com

  7. CA Sumit Doshi says:

    Nice Article… Keep posting such informative article where knowledge sharing helps to many professionals… Regards CA Sumit Doshi, Vapi, Gujarat.

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