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General Observations on Annual Return

1. Annual return is not based on annual accounts.

2.  it is not a reconciliation statement . Reconciliation Statement is in GSTR-9C.

3. If some tax is further payable or some claim has not been reflected in monthly/quarterly returns, it can not be depicted in GSTR-9.

4. As per Instruction no. 2 only details for July 2017 to March 2018 to be provided. It means no information regarding April 2017 to June 2018 to be provided. Howveer Part V requires information regarding amendments effected in subsequemt period which pertain to July 2017 to March 2018.

5. Source of Information for Outward supplies in GSTR-1, while source of information for ITC in GSTR 3B.  Hence base of information to be given is not uniform.

6. No data regarding total documents issued during the period has been called for.

7. If information of outward supplies in GSTR-1 differes from information 3B, resolution of such difference is not provided for.

8. Opening and Closing stock figures have not been asked. Neither the goods lying with agent/principal or Job worker have been asked.

9. Inward supplies on which tax is to be paid on reverse charge are not auto polulated because of GSTR-2 not put in place.

10. In 6A, 3B data in table 4A is being auto populated and then bifurcation of the same is being again asked in 6B to 6H.

11. No information regarding Exempted, NIL and NON GST Inward supply is being asked for. Only Outward supply under Exempt/NIL/Non GST category has been asked.

12. No bifurcation viz Inter and Intra state supply required.

Part
Observations
Taxable Value
CT
ST/UT
IGST
Cess
Part I
Basic Details
 
 
 
 
 
1
Financial Year
information regarding nature of business or major commodities or services not required to be furnished
 
 
 
 
 
2
GSTIN
 
 
 
 
 
3A
Legal Name
 
 
 
 
 
3B
Trade Name (if any)
 
 
 
 
 
Part II
Details of Outward and Inward Supplies declared during the financial year
 
 
 
 
 
Nature of Supplies
 
 
 
 
 
4
Detail of advances, inward and outward supplies on which tax is payable as declared in returns filed during the financial year
It should have been pertaining to financial year, because returns might not be filed during financial year only
 
 
 
 
 
4A
Supplies made to unregistered persons(B2C)
Include supplies through E-Commerce operators. Information shall be net of debit and credit notes. Information for Inter state supplies to URD exceeding Rs. 2.5 L can be fetched from Table 5 along with amendments in Table 9 and others summary information can be fetched from Table 7 of GSTR-1 along with amendments in Table 10.
 
 
 
 
 
4B
Supplies made to registered persons
Supplies made to UINs also to be given here. Table 4 of GSTR-1 shall be used including supplies through E-Commerce operator except Not to include supplies on which tax is payable on RCM by recipient (such supplies to be disclosed in 5C) Debit/Credit notes not to be clubbed.
 
 
 
 
 
4C
Zero Rates Supply (Export) on payment of tax (except supply to SEZs)
Information from Table 6A of GSTR-1. Exports without tax to be disclosed in 5A
 
 
 
 
 
4D
Supply to SEZs on payment of tax
Information from Table 6B of GSTR-1. Supply to SEZ to be disclosed in 5B
 
 
 
 
 
4E
Deemed Exports
Information from Table 6C of GSTR-1. To cover deemed exports under 48/2017-CT dated 18-10-17 i.e. Supply of goods against Advance authorization/ EPCG/ to EOU/ EHTP/ STP/ BTP
 
 
 
 
 
4F
Advance on which tax has been paid but invoice has not been issued (not covered by A to E)
Advances against goods was also taxable up to 15-11-2017 till struck down by 66/2017-CT. Information regarding unadjusted advances may betaken from Table 11A of GSTR-1
 
 
 
 
 
4G
Inward Supplies on which tax is to be paid on reverse charge
To carry information from para 3.1(d) of GSTR-3B. It shall include all supplies taxable u/s 9(3)/9(4) and import of service but not import of goods for which IGST is paid
 
 
 
 
 
4H
Sub Total (A to G above)
 
 
 
 
 
 
Less:
4I
Credit Notes issued in respect of transactions specified in (B) to (E ) above
Table 9B of GSTR-1 may be used. Credit notes to URD to be clubbed with 4A. There can be refund voucher against advances for supplies not made u/s 31(3)(e ) against 4F. Also There is no provision for post supply discount u/s 15(3)(b)
 
 
 
 
 
Add:
4J
Debit Notes issued in respect of transactions in (B) to ( E) above
Information to be carried from 9B. Debit note in transactions with URD to be clubbed with 4A.
 
 
 
 
 
Add:
4K
Supplies/Tax declared through Amendments
To carry information from Table 9A and 9C of GSTR-1. New Invoices inserted in subsequent months to be may not be covered here. Only amendments to invoices/debit/credit notes shall be covered here If amendments don’t affect total taxable value/tax then nothing to be disclosed. For supplies/tax declared during April to Sep 2018, information to be disclosed in 10.
 
 
 
 
 
Less:
4L
Supplies/Tax reduced through Amendments
To carry information from Table 9A and 9C of GSTR-1. New Invoices inserted in subsequent months to be may not be covered here. Only amendments to invoices/debit/credit notes shall be covered here If amendments don’t affect total taxable value/tax then nothing to be disclosed. For supplies/tax declared during April to Sep 2018, information to be disclosed in 10.
 
 
 
 
 
4M
Subtotal (I to L) above
 
 
 
 
 
 
4N
Supplies and Advances on which tax is to be paid (H+M)
 
 
 
 
 
 
5
Details of Outward Supplies on which tax is not payable as declared in returns filed during the financial year
It should be pertaining to financial year
 
 
 
 
 
5A
Zero rated Supply (Export) without payment of tax
Source: Table 6A of GSTR-1. Tax paid supplies to be disclosed in 4C
 
 
 
 
 
5B
Supply to SEZs without payment of tax
Source: Table 6B of GSTR-1. Tax paid supplies to be disclosed in 4D
 
 
 
 
 
5C
Supply on which tax is to be paid by recipient on reverse charge basis
Source: Table 4B of GSTR-1. Not to include debit/credit notes for such supplies
 
 
 
 
 
5D
Exempted
Source: Table 8 of GSTR-1. To include non-Nil rated but exempted supplies
 
 
 
 
 
5E
NIL Rated
Source: Table 8 of GSTR-1.
 
 
 
 
 
5F
NON GST Supply
Source: Table 8 of GSTR-1. It shall coverer 9(2) and Schedule III supplies and also “no supply”. Whether rebate on account of post supply discount/short payment to be covered here
 
 
 
 
 
5G
Sub Total (A to F above)
 
 
 
 
 
 
Less:
5H
Credit Notes issued in respect of transactions specified in (A) to (F ) above
Source : Table 9B of GSTR-1
 
 
 
 
 
Add:
5I
Debit Notes issued in respect of transactions in (A) to (F) above
Source : Table 9B of GSTR-1
 
 
 
 
 
Add:
5J
Supplies/Tax declared through Amendments
Source : Table 9A and 9C of GSTR-1
 
 
 
 
 
Less:
5K
Supplies/Tax reduced through Amendments
Source : Table 9A and 9C of GSTR-1
 
 
 
 
 
5L
Sub Total H to K
 
 
 
 
 
 
5M
Turnover on which tax is not to be paid (G + L above)
 
 
 
 
 
5N
Total Turnover (including advances) [4N+ 5M-4G)
It shall include all supplies whether or not tax is payable. Also to include unadjusted advances.4G is inward supplies on which tax is to be paid, hence in order to calculate total outward supplies, inward supplies have been reduced. Supplies from April 17 to June 17 shall also not be included
 
 
 
 
 
Part III
Detail of ITC as declared in returns filed during the financial year
It should be pertaining to financial year
 
 
 
 
 
6
Detail of ITC availed as declared in returns filed during the financial year
Value of Inward supplies has not been declared in returns. So, whether NIL figure to be reported or accounting figure to be reported
 
 
 
 
 
6A
Total amount of input tax availed through 3B (sum total of Table 4A of GSTR-3B)
Value of inward supplies is not provided in 3B, so it can not auto populate
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6B
Inward Supplies (other than imports and inward supplies on which tax is to be paid on reverse charge but incudes services received from SEZ)
Inputs
Capital goods
Source: Table 4A.5 “other ITC” of GSTR 3B. Bifurcation of inward supplies required. It shall include supplies from unregistered persons on which reverse charge is not paid. ITC availed from Apil to September 2018 to be provided in 8C. Reclaimed ITC not to be taken here
 
 
 
 
 
 
 
 
 
 
Input Services
 
 
 
 
 
6C
Inward supplies received from unregistered persons liable to reverse charge (other than B above) on which tax is paid and ITC availed)
Inputs
Source: Table 4A.3 of GSTR-3B. It shall cover inward supplies liable to tax u/s 9(4). Import of service not to be included here
 
 
 
 
 
Capital goods
 
 
 
 
 
Input Services
 
 
 
 
 
6D
Inward supplies received from registered persons liable to reverse charge (other than B above) on which tax is paid & ITC availed
Inputs
Source: Table 4A.3 of GSTR-3B. It shall covered RCM u/s 9(3)
 
 
 
 
 
Capital goods
 
 
 
 
 
Input Services
 
 
 
 
 
6E
Import of goods (including supplies from SEZ)
Inputs
Source: Table 4A.1 of GSTR 3B. Import of service from SEZ is already covered by 6B
 
 
 
 
 
Capital goods
 
 
 
 
 
6F
Import of service (excluding inward supplies from SEZ)
Source: Table 4A.2 of GSTR 3B. Import of service from SEZ is already covered by 6B
 
 
 
 
 
6G
Input Tax credit received from ISD
Source Table 4A.4 of GSTR 3B
 
 
 
 
 
6H
Amount of ITC reclaimed (other than B above) under the provisions of this Act
It shall covered S. 16(2) 3rd Proviso and S. 42(7)
 
 
 
 
 
6I
Subtotal (B to H)
 
 
 
 
 
6J
Difference (I-A)
This shall give excess ITC claimed in returns. If ITC is short claimed the amount shall be negative. As per Instructions, Ideally it should be zero
 
 
 
 
 
6K
Transition Credit through TRAN-1 (including revisions, if any)
 
 
 
 
 
6L
Transition Credit through TRAN-II
 
 
 
 
 
6M
Any other ITC availed but not specified above
ITC claimed under ITC-01 (S. 18(1)) or ITC-02 (S. 18(3)) may be taken
 
 
 
 
 
6N
Sub Total (K to M above)
 
 
 
 
 
6O
Total ITC availed (I + N above)
 
 
 
 
 
7
Details of ITC reversed and ineligible ITC as declared in returns filed during the financial year
 
 
 
 
 
7A
As per Rule 37
Source: Table 4B.2 of GSTR 3B.Reversal of ITC in case of non-payment of consideration in 180 days
 
 
 
 
 
7B
As per Rule 39
Distribution of Input Tax credit by ISD
 
 
 
 
 
7C
As per Rule 42
Source: Table 4B.1 of GSTR 3B. Reversal of ineligible ITC in Inputs and Input Services
 
 
 
 
 
7D
As per Rule 43
Source: Table 4B.1 of GSTR 3B.Reversal of Ineligible ITC on capital goods
 
 
 
 
 
7E
As per S. 17(5)
Reversal of Blocked Credit. Source: Table 4D.1 of GSTR 3B.
 
 
 
 
 
7F
Reversal of TRAN-1 credit
Ineligible ITC of Tran-I
 
 
 
 
 
7G
Reversal of TRAN-II credit
Ineligible ITC of Tran-II
 
 
 
 
 
7H
Other reversals (pl specify)
Reversal of ITC through ITC-03 on switching to exemption/composition u/s 18(4) or sale of capital goods u/s 18(6) or cancellation of RC u/s 29(5) read with Rule 44 may get covered here. Source: Table 4B.2 of GSTR 3B.
 
 
 
 
 
7I
Total ITC reversed (A to H above)
 
 
 
 
 
7J
Net ITC available for Utilization (6O-7I)
 
 
 
 
 
8
Other ITC Information
 
 
 
 
 
8A
ITC as per GSTR-2A (Table 3 & 5 of GSTR-2A)
It shall not include tax paid on imports and inward supplies. It reflects the outward supplier declared by suppliers
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8B
ITC as per sum total of 6B and 6H above
Source: 4A.5 of GSTR 3B and ITC reclaimed
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8C
ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZs) received during 2017-18 but availed during April to September 2018
Source: 4A.5 of GSTR 3B and ITC reclaimed for April 2018 to Sep 2018
 
 
 
 
 
8D
Difference [A- (B+ C)]
 
 
 
 
 
8E
ITC available but not availed (out of D)
Sum total of 8E and 8F should be equal to 8D
 
 
 
 
 
8F
ITC available but ineligible (out of D)
 
 
 
 
 
8G
IGST paid on import of goods (including supplies from SEZ)
 
 
 
 
 
8H
IGST credit availed on import of goods (as per 6E)
Auto populated from 6E
 
 
 
 
 
8I
Difference G-H
IGST on imports not availed
 
 
 
 
 
8J
ITC available but not availed on import of goods (Equal to I)
Why they are having two different rows for same item ? What does it mean ?
 
 
 
 
 
8K
Total ITC to be lapsed in current financial year (E +F + J)
It shall not be available even for subsequent determination of short paid tax u/s 73/74
 
 
 
 
 
Part IV
9
Detail of tax paid as declared in returns filed during the financial year
Tax Payable
Paid through cash
Paid through ITC
IGST
Source Table 6.1 of GSTR 3B
 
 
 
 
 
CT
 
 
 
 
 
ST/UT
 
 
 
 
 
Cess
 
 
 
 
 
Interest
 
 
 
 
 
Late Fee
 
 
 
 
 
Penalty
 
 
 
 
 
Other
 
 
 
 
 
Part V
Part of the transactions for the previous FY declared in returns of April to September of current FY or up to date of filing of annual return of previous FY which ever is earlier
 
 
 
 
 
Add:
10
Supplies/Tax declared through Amendments (net of debit notes)
Shouldn’t it be debit notes and not net of debit notes. Source Table 9A and 9C of GSTR-1 for April to Sep 2018
 
 
 
 
 
Less:
11
Supplies/Tax reduced through Amendments (net of credit notes)
Shouldn’t it be credit notes and not net of credit notes. Source Table 9A and 9C of GSTR-1 for April to Sep 2018
 
 
 
 
 
12
Reversal of ITC availed during previous financial year
Source: Table 4B of GSTR 3B for April to Sep 2018
 
 
 
 
 
13
ITC availed for the previous financial year
Source: Table 4A of GSTR 3B for April to Sep 2018
 
 
 
 
 
14
Differential tax paid on account of declaration in 10 & 11 above
 
 
 
 
 
Description
Payable
Paid
IGST
 
 
 
 
 
CT
 
 
 
 
 
ST/UT
 
 
 
 
 
Cess
 
 
 
 
 
Interest
 
 
 
 
 
Part VI
Other Information
 
 
 
 
 
15
Particulars of Demand and Refund
 
 
 
 
 
15A
Total Refund Claimed
 
 
 
 
 
15B
Total Refund Sanctioned
 
 
 
 
 
15C
Total Refund rejected
The information regarding re credit of information not asked
 
 
 
 
 
15D
Total Refund pending
Provisional refunds received to be excluded
 
 
 
 
 
15E
Total demand of taxes
Whether it shall include demand of taxes u/s 142(8) in respect of taxes under existing law
 
 
 
 
 
15F
Total taxes paid in respect of E
 
 
 
 
 
15G
Total Demand pending out of E
15E-15F
 
 
 
 
 
16
Information on supplies received from composition taxpayers, deemed supply u/s 143 and goods sent on approval
 
 
 
 
 
16A
Supplies received from composition tax payers
Source : Table 5 of GSTR 3B
 
 
 
 
 
16B
Deemed supply u/s 143
Deemed Supplies after 1 year/3 year of being sent u/s 143(3)/(4)
 
 
 
 
 
16C
Goods sent on approval basis but not returned
 
 
 
 
 
17
HSN Wise summary of outward supplies
HSN code is optional for turnover up to 1.5 crore. 2 Digit HSN Code to be used for turnover from 1.5 crore to 5 crore. 4 digit HSN code to be used for turnover more than 5 crore. Quantity to be reported net of returns. UQC details to be provided for goods only.
Source: Table 12 of GSTR-1. Column of Total Value in Table 12 of GSTR-1 has been left out of purview
HSN Code
UQC
Total Qty
Taxable Value
Rate of Tax
CT
ST/UT
IGST
Cess
1
2
3
4
5
6
7
8
9
18
HSN Wise summary of Inward supplies
HSN Code
UQC
Total Qty
Taxable Value
Rate of Tax
CT
ST/UT
IGST
Cess
1
2
3
4
5
6
7
8
9
19
Late fee payable and Paid
Payable
Paid
19A
Central Tax
There is no provision for late fee in IGST. This late fee is for annual return
19B
State Tax
Verification
OBSERVATIONS
I hereby solemnly affirm and declare that information given herein above is true and correct to the best of my knowledge and belief and nothing has been concealed there from and in case of reduction in output tax liability the benefit there of has been. will be passed on to the recipient of supply
Words “there from” restricts the concealment clause. There is no declaration regarding passing on the benefit of increase in ITC
Place
Signature
Name of Authorized Signatory
Date
Designation/Status

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