Understanding Part III of GSTR – 9C Reconciliation of Tax Paid

The Central Board of Indirect Taxes and Customs, vide notification no. 49/2018 – Central Tax dated 13th September, 2018, has provided the format of FORM GSTR – 9C.

As per section 35 (5) of the Central Goods and Service Tax Act, 2017, read with rule 80 (3) of the Central Goods and Service Tax Rules, 2017, FORM GSTR – 9C is required to be filed by every registered person whose aggregate turnover during a financial year exceeds INR 2 Crore.

FORM GSTR – 9C is basically a reconciliation statement / return which provides for a reconciliation of turnover, input tax credit and tax paid as reflected in the GST returns and annual books of accounts. FORM GSTR – 9C is divided into 5 different parts and PART III of the same deals with ‘RECONCILIATION OF TAX PAID’. Current article would help to understand part III of FORM GSTR – 9C.

Broadly, PART III is sub-divided into following 3 parts –

1. Point No. 9 – Reconciliation of rate wise liability and amount payable thereon;

2. Point No. 10 – Reasons for un-reconciled payment of amount;

3. Point No. 11 – Additional amount payable but not paid (due to reasons specified under Table 10).

POINT NO. 9 – RECONCILIATION OF RATE WISE LIABILITY AND THE AMOUNT PAYABLE THEREON –

This section provides for the reconciliation of tax paid as per reconciliation statement and the amount of tax paid as declared in the annual return filed in form GSTR – 9. Details of rate-wise bifurcation of taxable value and central tax, state /UT tax, integrated tax and cess needs to be provided. The format of point no. 9 is reproduced hereunder –

Under point A, C, E, G, I, J and K rate wise bifurcation of taxable value, central tax, state / UT tax, integrated tax, cess in to 5%, 12%, 18%, 28%, 3%, 0.25% and 0.10%, needs to be provided. In simple terms, liability on which tax is payable needs to be bifurcated in rate wise categories.

Further under point no. B, D, F and H mentioned as 5% (RC), 12% (RC), 18% (RC) and 28% (RC), respectively, rate wise bifurcation of supplies under which tax is payable by the receiver on reverse charge basis needs to be provided.

Point No. P is total of point no. A to point no. O and the same is auto generated.

Under point no. Q total amount of tax paid as the same being declared in the annual GSTR-9 return needs to be mentioned here. Figures from table 9, 10 and 11 of GSTR-9 would be reflected here.

POINT NO. 10 – REASONS FOR UN-RECONCILED PAYMENT OF AMOUNT –

Under point no. 10 the reason for the difference between total amount of tax paid as per reconciliation statement (point no. 9P) and the total amount of tax paid as declared under annual return (point no. 9Q). In simple terms, in case there is any difference / figure in point no. 9R the reason for the said difference needs to be provided here.

In case the amount of tax payable under point no. 9P and amount of tax paid under point no. 9Q is same and there is no difference then point no. 10 would remain blank.

POINT NO. 11 – ADDITIONAL AMOUNT PAYABLE BUT NOT PAID (DUE TO REASONS SPECIFIED UNDER TABLE 10) –

At point no. 11 the amount payable, which is due on account of the reason specified at table 10 (i.e. point no. 10 above) and the said amount is payable but not yet paid, through cash needs to be mentioned. The amount so payable needs to be bifurcated and mentioned in appropriate rate i.e. 5%, 12%, 18%, 28%, 3%, 0.25%, 0.10%, interest , late fee, penalty or any other amount.

In Next Article we will discuss Part IV of GSTR – 9C Reconciliation of Tax Paid.