1. ITC cannot be reversed or availed through annual return. For reversing ITC, taxpayers need to file FORM GST DRC-03.

2. Table 8A of annual return is auto-populated from FORM GSTR-2A as on 01/05/2019.

3. Treatment of tax which was to be paid on RCM for F.Y. 2017-18 but was paid during F.Y. 2018-19 – Since payment was made during F.Y.2018-19, ITC would have been availed in F.Y. 2018-19. Such details will not be declared in annual return for F.Y.2017-18 and will be declared in annual return for F.Y. 2018-19. If there are any variations in the calculation of turnover on account of this adjustment, the same be reported with reasons in reconciliation statement.

4. Aggregate turnover i.e. turnover of all registrations having same PAN is to be used for determining requirement of filing reconciliation statement. If there are 2 registrations in 2 different states on the same PAN, say State A (with turnover of Rs. 1.2 crore) and State B (with turnover of Rs 1 crore ) they are both required to file reconciliation statement individually for their registrations since their aggregate turnover is greater than Rs.2 crore. The aggregate turnover for this purpose shall be for the period July 2017 to March 2018.

5. If the credit note and debit note for any supply was issued and declared in returns of F.Y. 2018-19 and provision for the same has been made in books of accounts for F.Y. 2017-18, the same shall be declared in Pt V of annual return.

6. There is no provision in Pt II of reconciliation statement for adjustment in turnover in lieu of debit notes issued during F.Y. 2018-19 although provision for the same was made in books of accounts for F.Y. 2017-18. In such cases, they may adjust the same in Table 5O of reconciliation statement in FORM GSTR-9C.

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7 Comments

  1. M R Misra says:

    Please refer to your points at sl. no. 3 & 6. If a dealer avails I.T.C for R.C.M supply but does not pay tax & show it in books of accounts then how an Officer can detect it?Similarly, if a recipient R.T.P under audit u/s 44(2) R/W S.2(13) receives debit notes from supplier but does not show it in either books or return how to detect it ?

  2. priyanshi says:

    Ashok Sir I am extremely sorry for delaying in answering the query. I received the query in my mail account at 2:30 pm. I was stuck up in filing GSTR 9.

  3. priyanshi says:

    IF RCM of F.Y. 2017-18 is not paid till today then it has to be paid by DRC-03 and to be shown in Table 4G (Inward supplies on which GST to be paid under RCM) of Annual Return of F.Y. 2017-18. However ITC would not be available of it as of today as the time limit to avail unclaimed ITC of F.Y. 2017-18 has already lapsed.

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