What is GSTR-9
Every registered person under GST is required to furnish an annual return specified under rule 80 of CGST rules, due to covid government has eased compliance for small taxpayers having the turnover of less than 2 crore from furnishing annual returns for the last three years.
Even though annual returns represent a summary of GSTR-1 and GSTR-3B filed for the last 12 months by the taxpayers yet it contains important information which helps the assessing officer to complete assessment work. one such table is 8A of GSTR-9. which is a reconciliation of GSTR-2A taken at a cut-off date with ITC availed under GSTR-3B for the respective financial year.
Why Table 8A is important to reconcile
Section 16 of the CGST act provides us the conditions for taking ITC, one such condition is that taxpayers are not allowed to take ITC on invoices and debit notes after furnishing of annual return or September month of following to end of the financial year, whichever is earlier (refer section 16(4)), further rule 36(4) of CGST rule restricts taxpayers taking ITC on invoices not appearing in your GSTR-2A. Since assessment involves determining correct availement of ITC, the department will heavily rely on table 8A generated by the GST portal in allowing credit, any discrepancy noticed will be easily disallowed by the department and later taxpayer will have to go for an appeal which is always difficult
What can go wrong in Table 8A
Table 8A is generated from GSTR-2A taking cut-off date usually 31st October of the financial year and taxpayers need to take care of the following things to make sure their ITC credits are duly matched with ITC availed in GSTR-3B
1. The supplier has correctly quoted the place of supply
2. The Supplier GST No is not canceled and the Invoice date is after the cancellation date
3. The supplier has filed GSTR-1 within due dates
4. supplier is quoting the exact invoice number and date as shared with you
5. Taxable value and tax charged is correct
6. has furnished all returns including GSTR-3B
What to do if ITC figures do not match with Table 8A
For annual returns already filed, it is advisable to once again reconcile the figures appearing in Table 8A with GSTR-3B and record reasons for variation, and present the same to assessing officer during the audit. it will help them to understand issues and minimise the unwanted litigation later.
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