The process of preparing and filing of annual return in GSTR 9 for FY 2018-19 under GST has started and there have been a number of doubts arising as to how to reconcile the output tax liability under various tables pertaining to the FY 2018-19, because the GSTR 3B filed for 2018-19 contains rectifications for the FY 2017-18 also and there would be certain liability excess/ short declared in GSTR 3B filed for 2018-19 which might have been rectified in the GSTR 3B for the period April 2019 to September 2019. These issues have arisen because the GSTR 3B once filed cannot be rectified and any correction if required needs to be done in subsequent returns within the time limit prescribed under Section 39(9) and other relevant provisions as allowed vide Circular No. 26/26/2017-GST, dated 29-12-2017.

There may be various types of issues arising in the reconciliation/ its presentation in the GSTR 9, especially because the monthly returns for FY 2018-19 contained rectifications pertaining to FY 2017-18, but there is no table/ column or part for mentioning the same for reconciliation in the GSTR 9 of FY 2018-19. This problem may arise while filing GSTR 9 for subsequent years also if and until the Forms remain unchanged.

To understand how the output tax liability can be dealt with under the relevant tables in GSTR 9, regarding the liability relating to FY 2018-19 along with the rectifications of preceding year and rectifications relating to FY 2018-19 done in the succeeding year, a few case studies presented as below may be helpful.

For the sake of simplicity in understanding, Case Study No 1 to 4 have considered only one head of GST, without separate data under CGST, SGST and IGST. The real cases may need such break up but the same approach can be applied.

Case –I : Output Tax Liability short declared in FY 2017-18 partly rectified in 2018-19; Output Tax Liability short declared in FY 2018-19 partly rectified in September 2019 of FY 2019-20 (+,+)
DETAILS OF OUTPUT TAX LIABILITY
Financial Year
Books of Accounts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
60
15
18-19
200
25
165
190
15
20
TREATMENT IN RELEVANT TABLES OF GSTR 9
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
Table
Tax payable
Tax paid
Tax payable
Tax paid
4
60 + 15 = 75
190 – 25+20 = 185
9
60 + 15 = 75
60 (Rs 15 paid through DRC 03 cannot be added in Table 9)
190-25+20 = 185
165+25 =190 (Rs 20 paid through DRC 03 cannot be added and Rs 25 paid for 2017-18 cannot be reduced in Table 9)
10
25
15
11
0
0
14
25
15
Case –II : Output Tax Liability excess declared in FY 2017-18 rectified in 2018-19; Output Tax Liability excess declared in FY 2018-19 rectified in September 2019 of FY 2019-20 (-,-)
 DETAILS OF OUTPUT TAX LIABILITY
Financial Year
Books of Accounts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
120
18-19
200
-20
230
210
-30
TREATMENT IN RELEVANT TABLES OF GSTR 9
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
Table
Tax payable
Tax paid
Tax payable
Tax paid
4
120
210 – (20) = 230
9
120
120
210 – (20) = 230
210
10
0
0
11
-20
-30
14
-20
-30
Case –III : Output Tax Liability short declared in FY 2017-18 partly rectified in 2018-19; Output Tax Liability excess declared in FY 2018-19 rectified in September 2019 of FY 2019-20 (+,-)
 DETAILS OF OUTPUT TAX LIABILITY
Financial Year
Books of Accounts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
60
15
18-19
200
25
230
255
-30
TREATMENT IN RELEVANT TABLES OF GSTR 9
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
Table
Tax payable
Tax paid
Tax payable
Tax paid
4
60 + 15 = 75
255-25 = 230
9
60 + 15 = 75
60 (Rs 15 paid through DRC 03 cannot be added in Table 9)
255-25 = 230
230+25 = 255 (Rs 25 paid for 2017-18 cannot be reduced in Table 9)
10
25
0
11
0
-30
14
25
-30
Case –IV : Output Tax Liability excess declared in FY 2017-18 rectified in 2018-19; Output Tax Liability short declared in FY 2018-19 partly rectified in September 2019 of FY 2019-20 (-,+)
 DETAILS OF OUTPUT TAX LIABILITY
Financial Year
Books of Accounts
GSTR 3B
GSTR 3B (FY 18-19)
GSTR 3B (April to Sept 2019)
DRC 03
(FY 17-18)
Relating to (FY 17-18)
Relating to (FY 18-19)
Total GSTR 3B (FY 18-19)
Relating to (FY 18-19)
Annual Return
17-18
100
120
18-19
200
-20
180
160
5
15
TREATMENT IN RELEVANT TABLES OF GSTR 9
GSTR 9 (FY 2017-18)
GSTR 9 (FY 2018-19)
Table
Tax payable
Tax paid
Tax payable
Tax paid
4
120
160- (20) +15 = 195
9
120
120
160- (20) + 15 = 195
160
10
0
0
11
-20
5
14
-20
5
Case –V : Output Tax Liability of CGST and SGST for FY 2018-19 declared as IGST in FY 2018-19 by mistake (not rectified in any manner in GSTR 3B of FY 2019-20 upto September 2019)
DETAILS OF OUTPUT TAX LIABILITY
Financial Year
Books of Accounts (FY 18-19) – Correct
GSTR 3B (FY 18-19) -Incorrect
Taxable value
IGST
CGST
SGST
Taxable value
IGST
CGST
SGST
18-19
100
9
9
100
18
TREATMENT IN RELEVANT TABLES OF GSTR 9
Table
IGST
CGST
SGST
4
18-18 = 0
9
9
9 – Tax Payable
18-18 = 0
9
9
9 – Tax Paid
18 (Rs 18 wrongfully paid under IGST cannot be reduced in Table 9. However, refund can be claimed within 2 years from date of payment)
NIL (Rs 9 to be paid through DRC 03 since cannot be added in Table 9)
NIL (Rs 9 to be paid through DRC 03 since cannot be added in Table 9)
10
0
0
0
11
0
0
0
14
0
0
0

The above may help in preparing the GSTR 9 for FY 2018-19. There can be many more very complex situations which may need to be resolved and reported after proper reconciliation, however, the basic principles guiding the process shall remain the same.

Author: Article is jointly Authored by CA Raginee Goyal (Sr Partner) and CA Jewel Goyal (Partner) of Raginee Goyal & Associates.

CA Raginee Goyal and CA Jewel Goyal

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Qualification: CA in Practice
Company: Raginee Goyal & Associates
Location: Guwahati, Assam, IN
Member Since: 30 Nov 2017 | Total Posts: 3
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2 Comments

  1. siddharth bodas says:

    Article is very informative thanks for the same,
    In case of ITC if we go by same logic,
    while filing GSTR 9 of 18-19, how to deal with ITC claimed/reversed in 3B of18-19 relating to 17-18. As in table 9 figures relating to ITC are autopopulated.

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