The due date of filing GST Annual Return in Form GSTR-9/9A & Reconciliation Statement in Form GSTR-9C is 31.08.2019. The utility of the Annual Return is such that taxpayers are facing difficulties in furnishing information particularly inward HSN summary, reconciliation of ITC with GSTR-2A and its matching with ITC populated in table 8A of GSTR-9. Even Chartered Accountants/Cost Accountants are doubts on the form and are facing difficulty in preparing the return. There is no clarify to furnish any adjustment transaction in the return. Being first year the taxpayers have difficulties in preparing the details in the format required in the return. The difficulties faced by taxpayers and consultants are witnessed through the request/representation made by various Associations. Some of them are reproduced below: 

The Western Maharashtra Tax Practitioner’s Association – The Western Maharashtra Tax Practitioner’s Association WMTPA, (formerly known as the ITSTP Association) has written to CBIC on 14th August, 2019 stating that only around 1% of Form GSTR-9 & 9C is filed and the compliance situation is going to be worst in coming days, due to heavy rain in various parts of Country, which has destroyed daily life of millions of people. The Association has stated as:

(a) We would like to highlight to your good office, of which you must be aware that, there is heavy rainfall in state of Maharashtra, Karnataka, Kerala, Andhra Pradesh and Gujarat which has caused disastrous situation of flood.

(b) Heavy Rain and Flood in above mentioned state has severely impacted personal, working and professional life of all individual, taxpayer and professional living in these state

(c) Neither taxpayer are able to communicate to professionals, nor are professionals able to communicate tax payer for GST compliance.

(d) Office of taxpayer and professionals are badly damaged due to flood.

(e) Life of all people in above mentioned states are severely impacted.

Therefore, it is impossible for taxpayers of above mentioned states, to do any tax compliance for coming 1-2 months, until situation improves and come back to normal. It is therefore requested to immediately extend GSTR-9, 9A, 9C for three month up to 30th November, 2019. 

THE INSTITUTE OF COST ACCOUNTANTS OF INDIA: The Institute of Cost Accountants of India vide its letter dated 21.08.2019 has requested CBIC to extend due date of GSTR-9 & 9C. The Institute stated that this is the first year of filing GST Annual Return and submitting GST Audit Report. The taxpayers are new to the entire system and facing complications at the time of filing GSTR-9 and GSTR-9C like: It is very time consuming to file GSTR-9 and GSTR-9C using offline utility (JSON file), taxpayers are facing the problem regarding mismatch between ITC availed in GSTR-3B and ITC as per GSTR-2A, the break-up of input services and capital goods were not required to be furnished in monthly return GSTR-3B but the same is required in the annual return which consumes time.

Further, the taxpayers are required to give all details with broad information to file annual return which is very tedious in nature. Since this is the first full year of return filing and audit, with many changes through many circulars and notifications, the taxpayers are finding it difficult to cope up with the time line given for filing of return. Even, the GST website is not working properly always which are also making delay in Annual Return filing. Hence the association has requested to extend due date of filing GSTR-9 up to 30th September, 2019 and GSTR-9C up to 31st October, 2019 so to ease the hardship faced by the taxpayers. 

THE PUNJAB ACCOUNTANTS ASSOCIATION: The Punjab Accountants Association has vide its letter dated 16.08.2019 requested the Government to extend the due date of filing Annual GST Returns in Form GSTR-9/9A/9C. The members of The Punjab Accountants Association would like to request for the extension of due date of filing GSTR 9/9A & 9C by three months. The main reason cited by them is that the due date is clashing with the due of Income Tax Return to be filed by 31.08.2019 for non-auditable assesses and 30.09.2019 for auditable assesses. The Association has also emphasized that the utility pertaining to these Annual Returns in terms of electronic uploading was made available only in May, 2019. Under these circumstances, all the professionals are facing a lot of strain, as compliance of GST and IT Returns in one go is not possible. Therefore, they humbly request the Honorable Madam, to extend the date of filing of GSTR 9/9A/9C for further at least three months.

Ahilya Chamber of Commerce & Industry: This Chamber states that the stakeholder community of tax payers, tax consultants and even authorities are in a state of utter confusion. If tax payers file yearly return with this complexity and confusion, there will be Crores of Notices issued by Department as these will be system driven. The Chamber strongly feel that even authorities will be not able to handle such huge amount of notices. The Chamber states that the Council need to discuss with stakeholders on different issues, decrease complexity of return, exclude Non GST supply / exempt supply, allow rectification in yearly return, allow HSN code of 2 / 4 digits (as promised in GST Law), payment of additional taxes via DRC-03 through Credit ledger (in addition to cash ledger). In view of these difficulties the Chamber has requested GST Council on 21.08.2019 to immediately withdraw Form GSTR-9, 9A and 9C for FY 2017-18.

BCAS and four others: BCAS has made a representation on 19.08.2019 jointly with the Chartered Accountants’ Association Ahmedabad, Chartered Accountants Association, Surat, Karnataka State Chartered Accountants Association and Lucknow Chartered Accountants’ Society to the Hon’ble Minister of State for Finance and Corporate Affairs, New Delhi for the extension of the due date for filing of Annual Return and Reconciliation Statement.

There are issues like singing issues in GSTR-9/9C by digital signature, validation issues in the excel utility of GSTR-9/9C, issues while uploading Financial Statements in GSTR-9C, issues while making payment for Annual Return via DRC-03, issues related to the non-availability of list of transactions of the auto-populated Input Tax credit amounts in GSTR-9 making matching nearby impossible, issues related to payments made via DRC-03 not getting auto-populated in GSTR-9 and revision of GSTR-9/9C is also not permitted to correct some inadvertent errors.

In view of the aforementioned issues, the Association suggested that the due date for filing of Annual Return and Reconciliation Statement for FY 2017-18 be extended as majority of tax payers are facing above stated difficulties even as on date.

The Chamber of Tax Consultants (CTC): The Chamber has requested on 17.08.2019 to address technical problems faced by taxpayers while uploading and filing of Annual Returns, to relax information called for in Annual Returns which were not required to be compiled or be kept at the time of filing of monthly return & to extend the due date for filing of GST Annual Returns and Reconciliation Statement for F.Y.2017-18 for two months i.e. up to 31st October, 2019.

The Chamber has stated that taxpayers are facing technical issues like json file required for offline preparation of GSTR-9 is taking more than 1 hour for generation, though site states that it would take 20 minutes and also there are lots of issues faced by a taxpayer while downloading Json file from the GST portal and then uploading the same in offline utility tool. Many errors such as ‘Download in process. Please check after 20 mins’, ‘File generation is in progress, please try again after some time’ are being faced amongst other.

The Chamber has also stated that continuous clarifications from Government and GST portal regarding filing of GST 9C would require some additional time for the auditors and tax payers to arrive at a conclusion with respect to correct reporting in GSTR-9 & 9C. Further, the Chamber also stated that the details required in GSTR-9 is detailed information which was not required in monthly return in Form GSTR-3B& GSTR-1. HSN wise summary of inward supplies was also not required in monthly return and therefore it is taking time to prepare it.

In view of the above issues, The Chamber of Tax Consultants, Mumbai which was established in 1926 has requested for extension of due date of GSTR-9, 9A & 9C for two months i.e. up to 31st October, 2019.

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