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 |
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Part I |
Basic Details |
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1 |
Financial Year |
information regarding nature of business or major commodities or services not required to be furnished |
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2 |
GSTIN |
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3A |
Legal Name |
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3B |
Trade Name (if any) |
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Part II |
Details of Outward and Inward Supplies declared during the financial year |
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Nature of Supplies |
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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 |
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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. |
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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. |
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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 |
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4D |
Supply to SEZs on payment of tax |
Information from Table 6B of GSTR-1. Supply to SEZ to be disclosed in 5B |
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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 |
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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 |
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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 |
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4H |
Sub Total (A to G above) |
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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) |
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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. |
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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. |
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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. |
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4M |
Subtotal (I to L) above |
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4N |
Supplies and Advances on which tax is to be paid (H+M) |
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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 |
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5A |
Zero rated Supply (Export) without payment of tax |
Source: Table 6A of GSTR-1. Tax paid supplies to be disclosed in 4C |
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5B |
Supply to SEZs without payment of tax |
Source: Table 6B of GSTR-1. Tax paid supplies to be disclosed in 4D |
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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 |
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5D |
Exempted |
Source: Table 8 of GSTR-1. To include non-Nil rated but exempted supplies |
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5E |
NIL Rated |
Source: Table 8 of GSTR-1. |
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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 |
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5G |
Sub Total (A to F above) |
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Less: |
5H |
Credit Notes issued in respect of transactions specified in (A) to (F ) above |
Source : Table 9B of GSTR-1 |
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Add: |
5I |
Debit Notes issued in respect of transactions in (A) to (F) above |
Source : Table 9B of GSTR-1 |
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Add: |
5J |
Supplies/Tax declared through Amendments |
Source : Table 9A and 9C of GSTR-1 |
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Less: |
5K |
Supplies/Tax reduced through Amendments |
Source : Table 9A and 9C of GSTR-1 |
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5L |
Sub Total H to K |
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5M |
Turnover on which tax is not to be paid (G + L above) |
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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 |
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Part III |
Detail of ITC as declared in returns filed during the financial year |
It should be pertaining to financial year |
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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 |
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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 |
Auto |
Auto |
Auto |
Auto |
Auto |
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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) |
InputsCapital 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 |
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Input Services |
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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 |
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Capital goods |
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Input Services |
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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) |
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Capital goods |
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Input Services |
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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 |
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Capital goods |
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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 |
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6G |
Input Tax credit received from ISD |
Source Table 4A.4 of GSTR 3B |
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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) |
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6I |
Subtotal (B to H) |
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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 |
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6K |
Transition Credit through TRAN-1 (including revisions, if any) |
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6L |
Transition Credit through TRAN-II |
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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 |
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6N |
Sub Total (K to M above) |
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6O |
Total ITC availed (I + N above) |
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7 |
Details of ITC reversed and ineligible ITC as declared in returns filed during the financial year |
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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 |
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7B |
As per Rule 39 |
Distribution of Input Tax credit by ISD |
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7C |
As per Rule 42 |
Source: Table 4B.1 of GSTR 3B. Reversal of ineligible ITC in Inputs and Input Services |
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7D |
As per Rule 43 |
Source: Table 4B.1 of GSTR 3B.Reversal of Ineligible ITC on capital goods |
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7E |
As per S. 17(5) |
Reversal of Blocked Credit. Source: Table 4D.1 of GSTR 3B. |
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7F |
Reversal of TRAN-1 credit |
Ineligible ITC of Tran-I |
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7G |
Reversal of TRAN-II credit |
Ineligible ITC of Tran-II |
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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. |
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7I |
Total ITC reversed (A to H above) |
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7J |
Net ITC available for Utilization (6O-7I) |
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8 |
Other ITC Information |
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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 |
Auto |
Auto |
Auto |
Auto |
Auto |
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8B |
ITC as per sum total of 6B and 6H above |
Source: 4A.5 of GSTR 3B and ITC reclaimed |
Auto |
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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 |
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8D |
Difference [A- (B+ C)] |
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8E |
ITC available but not availed (out of D) |
Sum total of 8E and 8F should be equal to 8D |
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8F |
ITC available but ineligible (out of D) |
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8G |
IGST paid on import of goods (including supplies from SEZ) |
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8H |
IGST credit availed on import of goods (as per 6E) |
Auto populated from 6E |
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8I |
Difference G-H |
IGST on imports not availed |
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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 ? |
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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 |
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Part IV |
9 |
Detail of tax paid as declared in returns filed during the financial year |
Tax Payable |
Paid through cash |
Paid through ITC |
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IGST |
Source Table 6.1 of GSTR 3B |
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CT |
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ST/UT |
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Cess |
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Interest |
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Late Fee |
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Penalty |
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Other |
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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 |
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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 |
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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 |
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12 |
Reversal of ITC availed during previous financial year |
Source: Table 4B of GSTR 3B for April to Sep 2018 |
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13 |
ITC availed for the previous financial year |
Source: Table 4A of GSTR 3B for April to Sep 2018 |
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14 |
Differential tax paid on account of declaration in 10 & 11 above |
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Description |
Payable |
Paid |
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IGST |
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CT |
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ST/UT |
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Cess |
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Interest |
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Part VI |
Other Information |
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15 |
Particulars of Demand and Refund |
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15A |
Total Refund Claimed |
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15B |
Total Refund Sanctioned |
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15C |
Total Refund rejected |
The information regarding re credit of information not asked |
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15D |
Total Refund pending |
Provisional refunds received to be excluded |
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15E |
Total demand of taxes |
Whether it shall include demand of taxes u/s 142(8) in respect of taxes under existing law |
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15F |
Total taxes paid in respect of E |
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15G |
Total Demand pending out of E |
15E-15F |
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16 |
Information on supplies received from composition taxpayers, deemed supply u/s 143 and goods sent on approval |
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16A |
Supplies received from composition tax payers |
Source : Table 5 of GSTR 3B |
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16B |
Deemed supply u/s 143 |
Deemed Supplies after 1 year/3 year of being sent u/s 143(3)/(4) |
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16C |
Goods sent on approval basis but not returned |
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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 |
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HSN Code |
UQC |
Total Qty |
Taxable Value |
Rate of Tax |
CT |
ST/UT |
IGST |
Cess |
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1 |
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4 |
5 |
6 |
7 |
8 |
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18 |
HSN Wise summary of Inward supplies |
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HSN Code |
UQC |
Total Qty |
Taxable Value |
Rate of Tax |
CT |
ST/UT |
IGST |
Cess |
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1 |
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3 |
4 |
5 |
6 |
7 |
8 |
9 |
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19 |
Late fee payable and Paid |
Payable |
Paid |
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19A |
Central Tax |
There is no provision for late fee in IGST. This late fee is for annual return |
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19B |
State Tax |
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Verification |
OBSERVATIONS |
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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 |
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Place |
Signature |
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Name of Authorized Signatory |
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Date |
Designation/Status |
NO THE NET OF DR/CR NOTES IS CORRECT
Good reference guide.
Sir, can you please provide similar observation of GSTR-9C?
Regards,
Babu