Problems with GSTR 9 Form design and DRC 3 module on GST Portal
1. It has button called COMPUTE LIABILITIES & when u click, it doesn’t show any additional liability. How officer will going calculate at time of assessment? If at all any difference coming from GSTR 9. Amazing Form design. We wonder that this button is only for Computing Late Fees.
2. It Auto populates GSTR 1 data in table 4 & 5. Needless to say, this is most confusing thing Portal does without asking. GSTR 1 is last sort of data reference that one would depend on.. For filling table 4 & 5? Why making all confuse????
3. The biggest problem is SOURCE of information. They must mention that first source of information & only source of information must be BOOKS OF ACCOUNTS. In help section of Form in each Table, They only mentioned GSTR 1 & GSTR 3B which might not be correct source when GST returns are not matching with Books.
4. Any additional liability (which you calculate at your own) (Form never does) Need to be paid by cash in DRC 3 . Why?? What if, it is related to ITC reversal?? Why we can’t use ITC balance?? (We understand for outward liability differences, paying by cash is still logical)
5. Regarding DRC 3. This module also very confusing on Portal. Let me explain one of problem in DRC3. Let me Explain with Example. In FY 17-18, IGST claimed in GSTR 3B.. Rs 11.5 lacs..GSTR 3B never asks State wise IGST claims. In FY 17-18, IGST as per books.. Rs. 11 lacs. I am going to reverse this in DRC 3 excess claimed 50000. The Form DRC 3 asks which place of supply, I need to select. (There must be around 500 invoices of inwards and time is limited to check Place of supply. There may be so many invoice which I might have claimed wrongly or duplicate entry or etc etc reasons).
6. Considering level of toughness this GSTR 9 form has for FY 17-18, will this form be made easy for GSTR 9 of 18-19? For 18-19, data will be Chaos Some reporting in FY 18-19 Some reporting in FY 19-20 Some reporting of FY 17-18 reported in FY 18-19 GSTR3B and GSTR1. Total chaos it would be.
7. The biggest problem of GSTR 9 is that GSTR 9C will get data from GSTR 9 & it will reconcile it . Every table of GSTR 9C, you have fill Books data & compare with GSTR 9C figures. If there is problem in GSTR 9 in presentation of data then wrong data will be compared.
8 .There is no revision option for GSTR 9 , what if one dealer files wrongly GSTR 9 & then it is very difficult for GST Auditor to prepare GSTR 9C because GSTR 9C compares BOOKS VS GSTR 9 FIGURE in each table. There should be revision option.
9. It asking useless details in table 14 to 17. Don’t they have all these details from GSTR 1 and GSTR 2A???? Though some details have been relaxed. But what about those who had filled these details by hook & crook? What about time wastage??
10. Table 10 to 13 asks for data which might be reported in FY 2018-2019 GSTR 3B . However, Where to report those transactions which might have reported in FY 2019-20 GSTR 3B & 1.