(Set up by an Act of Parliament)

CA. Prafulla P. Chhajed


21st August, 2019

Smt. Nirmala Sitharaman
Hon’ble Union Minister for Finance, and Corporate Affairs &
Chairperson, GST Council,
Government of India,
North Block
New Delhi -110 001

Respected Madam,

Reg: Request for extension of Annual returns in Form GSTR 9 and GSTR 9A along with GST Audit Certificate in GSTR 9C from August 31, 2019 to November 30, 2019

The Institute, being a partner in nation building, has always been proactively supporting the Government in implementation of Goods and Services Tax (GST) by providing suggestions at each stage of development, be it pre-implementation or post-implementation of GST, be it on policy issues or procedural aspects. Further, Institute has been playing crucial role in GST Knowledge Dissemination among all the stakeholders through our technical publications, Newsletter, Live Webcasts, e-learning, Courses, Conferences and programme.

We are writing this letter to request your goodseif to extend the date of filing of Annual return and GST Audit by another three months till November 30, 2019 due to the following reasons:

Difficulties in filing Form GSTR 9/9C

Both the forms are not user friendly. A lot of data are required to be filled in these forms which were not part of Form 3B or GSTR — 1 like details of Input Tax Credit. Further, GSTN Portal is taking too much time for downloading/uploading of data. Therefore, taxpayers finding it difficult to file Form GSTR 9/9C which can be observed by the number of return and Audit form filed till date.

Further, only few clarifications for filling the form have recently released (Latest in July, 2019) with a different understanding and “Industry” is taking time to prepare the details. Clarifications on some issues are still required.


In light of the above background, we humbly suggest that the date of filing of Annual return and GST Audit be increased by another three months till November 30, 2019 to help taxpayers to fill these forms in due time and in correct manner. This extension is requested with the understanding that the functionalities on the GSTN portal shall be working in a proper manner and proper mechanism of timely resolution of the issues faced by taxpayers shall be available.

We would be very grateful if your goodself would take an early action in this regard. This will be very helpful for the taxation fraternity and also for the trade & industry. In conclusion, we request that a suitable order may be issued to this effect at the earliest.

We shall be glad to provide any further input as may be required and your office may reach us at [email protected] or 0120-3045954.

Yours faithfully,

(CA. Prafulla P. Chhajed)

Copy to:

(i) Dr. Ajay Bhushan Pandey, Secretary, Revenue & GST Council, Government of India, North Block. New Delhi – 110001

(ii) Shri Yogendra Garg, Principal Commissioner, GST Policy Wing, Central Board of Indirect Taxes & Customs, Government of India, North Block, New Delhi – 110001

(iii) Shri Dheeraj Rastogi, Joint Secretary Office of the Goods & Services 110001  Tax Council, Tower-II, 5th Floor, Jeevan Bharti Building,

Download Above Representation in PDF Format

List of the other recent Representation

S. No. Dated Submitted by Link
15. 24/08/2019 Uttar Pradesh Tax Practitioner Association Extend due date for filing GSTR-9 and GSTR-9C to December
14. 21/08/2019 Rajasthan Tax Consultants’ Association Solve technical issues and extend due date of GSRT 9 & GSTR 9C
13. 21/08/2019 Institute Of Cost Accountants Of India Extend due date of GSTR 9 and GSTR 9C
12.  21/08/2019 Ahilya Chamber of Commerce & Industry Withdraw GST Yearly Return – GSTR 9, 9A & 9C for F.Y. 2017–18
11. 19/08/2019 BCAS and 4 Others Representation on Income Tax and GST Issues faced by taxpayers
10. 19/08/2019 Professional Accountants’ &
Tax Consultants’ Association
Request for Extending Due Dates for filing Annual GST Returns
9. 17/08/2019 Chamber of Tax Consultants Extend due date for filing of GSTR -9, 9A and 9C for F.Y. 2017-18
8. 16/08/2019 Punjab Accountants Association Extend Due Dates of GSTR9/9A/9C
7. 14/08/2019 Western Maharashtra Tax Practitioner’s Association Extend Due date of GST Returns in Flood affected States
6. 13/08/2019 Goods & Services Tax Practitioners Association of Maharashtra Extend GST, Income Tax and other due dates falling in Aug & Sep 2019
5. 12/08/2019 Association of Tax Lawyers, Delhi Request to Extend time limit for claim of ITC for FY 2017-2018
4. 10/08/2019 Karnataka State Chartered Accountants Association Extend Due Date for Filing of Income Tax and GST Returns
3. 18/07/2019 Tax Bar Association, Jodhpur Extend due date for filing of Income-tax returns to 30th Sept 2019
2. 11/06/2019 Goods And Services Tax Practitioners’ Association Of Maharashtra GST Annual Return & subsequent reconciliation for GST Audit- Issues
1. 05/08/2019 Gujarat Sales Tax Bar Association Request for extension of due date of Annual Return- GSTR-9

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