Recently financial budget 2021 has proposed to omit the provision section 35(5) and amend the section 44 of CGST Act, 2017. After acceptance of bill by president of India GST audit need not to file. Recently CBIC clarified through retweet on tweeter that ‘Section 35 and 44 of CGST Act are proposed to be amended in Finance Bill, 2021. However, these proposals will come into effect from a date to be notified later. For FY 2019-20, the existing provisions shall continue.’

GSTR-9

  • Form GSTR-9 is an annual return which is required to be filed as per section 44 read with rule 80(1) of CGST rules, 2017. Initially annual return was required to be filed by every registered person irrespective the amount of turnover. Thereafter CBIC issued Notification No. 47/2019 and 77/2020- Central Tax gives benefit of optional filing of annual return for registered person whose aggregate turnover in a financial year does not exceed Rs 2 crore, for F.Y. 2017-18, F.Y. 2018-19 and FY 2019-20 as well.

GSTR-9C

  • Form GSTR-9C is a statement of reconciliation between the annual return GSTR-9 filed and the amount as per the audited financial statement of the taxpayer. GSTR-9C is required to file by the taxpayer as per section 35(5) read with rule 80(3) of CGST rules, 2017. Initially annual return was required to be filed by every registered person having turnover exceeding Rs. 2 Cr. Thereafter CBIC issued Notification No. 16/2020- Central tax dated 23rd March, 2020 to revise the threshold limit to Rs. 5 Cr. For F.Y. 2018-19 & onwards.

Applicability of GSTR-9 & GSTR-9C for FY 2019-20

Table No Particulars GSTR-9 GSTR-9C
1.         Turnover up to Rs. 2 Cr. Optional Optional
2.         Turnover more than Rs. 2 Cr. And up to Rs. 5 Cr. Mandatory Optional
3.         Turnover more than Rs. 5 Cr. Mandatory Mandatory

Table-wise details requirement in form GSTR-9

Forms contain tables which are required to be filled by the taxpayers. As the GST is new for all, there are lots of confusions amongst the taxpayer regarding collection of data and how to fill the tables. CBIC issued notification 79/2019 and amended the form GSTR-9 and GSTR-9C and made some tables, clause of the form optional. Table-wise details required is as below:

Table No. Particulars FY 2019-20
4. Details of advances, inwards and outward supplies on which tax is payable as declared in returns filed during the FY.

  • Table 4A, B, C, D, E, F
Mandatory
  • Table I, J, K, L
There is an option to fill these details separately or can be clubbed with Table 4B to 4E.
5. Details of outward supplies on which tax is not payable made during the financial year-

  • Table 5 A, B, C
Mandatory
  • Table 5 D, E, F
The consolidated details can be disclosed in the exempted row.
  • Table 5 H, I, J, K
There is an option to fill these details separately or can be clubbed with Table 5A to 5F
6. Details of ITC availed as declared in the returns during the financial year.

  • 6A, Others
 

 

Mandatory

  • 6B, 6C, 6D, 6E
For Input and input services there is option to provide breakup or total in inputs only.

Capital Goods should be shown separately.

There is an option to either report in Table 6C and in Table 6D separately or report the consolidated details of Table 6C and 6D in Table 6D only

7. Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year

  • 7A, 7B, 7C, 7D, 7E

 

 

Either fill separately or report the entire amount in 7H only

  • 7F, 7G, 7H
Mandatory
8. Others ITC related information Mandatory
9. Details of tax paid as declared in returns filed during the financial year Mandatory
10 & 11 Supplies / tax declared/reduced through Amendments (+) (-) (net of credit /debit notes) Mandatory
12 & 13 Reversal of ITC availed during previous financial year and ITC availed for the previous financial year. Optional
15 Particulars of demand and refund Optional
16 Information on supplies received from composition taxpayers, deemed supply under section 143 and goods sent on approval basis. Optional
17 HSN wise summary of outward Supplies Optional
18 HSN wise summary of inward supplies Optional

Table-wise details requirement in form GSTR-9C

Table No. Particulars FY 2019-20
5 Reconciliation of Gross Turnover

  • 5A is mandatory
  • Net 5B to 5N can show in 5O
 

Mandatory

7 Reconciliation of Taxable Turnover Mandatory
9 Reconciliation of Tax paid Mandatory
11 Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10 above) Mandatory
12 Reconciliation of Net Input Tax Credit (ITC)

  • 12A
 

Mandatory

  • 12B, 12C
Optional
14 Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account Optional
16 Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above) Mandatory

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31 Comments

  1. Mewada says:

    Sir, I have declare sales in GSTR-1 of FY 19-20 but same was not shown in GSTR-3B. Later when comes to know I have added liability in GSTR3B of FY 20-21. Now how to this in GSTR-9 in Table 4 (which is showing correct liability), Table 9 (Showing less liability) & do I have to mentioned anything in Table 10 to 13 ??.

  2. Sanjeev says:

    Table 14 of GSTR-9C is optional as per this article but there is no mention of the same in Notification no. 79/2020 dated 15th Oct 2020.
    Please clarify?

      1. Sanjeev says:

        As per “Table-wise details requirement in form GSTR-9C” Under Table 14 “Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account” it says “Optional”.

  3. C W MARATHE says:

    FOR FIN YE 2019-20 TABLES 17 & 18 FOR HSN CODEWISE SUPPLIES ARE MANDATORY OR OPTIONAL. REF NOTIFICATIONS 77/2020 TO 79/2020 THERE IS NO REF TO TABLES 17 OR 18 IN THIS NOTOFICATION WHICH SAY THAT THEY ARE OPTIONAL. PL CLARIFY

    1. Robin0013 says:

      Refer page no. 15 point no. (e) of the notification no. 79/2020 dated 15th Oct. 2020. Read this with reference to Notification 74/2018. Point (e) is as follows:

      (e) in paragraph 8, in the Table, in second column, for the letters, figures and word “FY 2017-18 and 2018-19” wherever they occur, the letters, figures and word “FY 2017-18, 2018-19 and 2019-20” shall be substituted.

    2. Vilas Reddy says:

      I have been through the suggested notification, there is still a doubt as there is no reference of HSN which says that the same is optional for FY 19-20

      1. Mayur says:

        Summary of supplies effected and received against a particular HSN code to
        be reported only in this table. It will be optional for taxpayers having annual
        turnover upto ₹ 1.50 Cr. It will be mandatory to report HSN code at two digits
        level for taxpayers having annual turnover in the preceding year above ₹ 1.50
        Cr but upto ₹ 5.00 Cr and at four digits‘ level for taxpayers having annual
        turnover above ₹ 5.00 Cr. UQC details to be furnished only for supply of
        goods. Quantity is to be reported net of returns. Table 12 of FORM GSTR1 may be used for filling up details in Table 17. It may be noted that this
        summary details are required to be declared only for those inward
        supplies which in value independently account for 10 % or more of
        the total value of inward supplies.
        [For FY 2017-18, 2018-19 and 2019-20]126, the registered person shall
        have an option to not fill this table.] 1

  4. sumit holani says:

    Dear Sir,

    In table no 6 of gstr 9 whare information of our input. We are required of input biferaction ike input if goods, input of caoital goods, input of services etc. Please clearify that i am correct or not.

  5. CA SANDEEP DEVIDAN says:

    Notification No 74/2019 talks about Waiver of Late Fee for GSTR 1, it does not give exemption from reporting certain requirements of GSTR 9 & 9C for FY 2019-20. Please look into it.

  6. srikrishna chaitanya reddy divya b says:

    sir
    with regard to table 17 and 18 in GSTR-9 , notification 56/2019 says , it is optional only 2017-18 and 2018-19. is there any further notification???

  7. Abhiram Bhat says:

    Hi Robin,

    As per notification no 74/2019 it says only about wavier of late fee and does not mention about GSTR 9 and 9C, so can you provide us correct notification to have reference

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