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The Gujarat Sales Tax Bar Association has requested Hon’ble FM to that due date for filing GSTR 9, 9A and 9C for the year 2017-18 should be extended by at least 3 months till 30th November, 2019. Full text of the representation is as follows:-

4th Floor, ‘C’ Block, Multi Storied Building, Lal Darwaja, Ahmedabad – 380 001.
Ph. : (079) 25506305 website : e-mail : Trust Regd. No. F/2005

Date 5th August, 2019.

The Hon’ble Finance Minister,

Respected Madam,

Subject : Request for extension of due date of Annual Return- GSTR-9.

We have already stepped into the third year of GST. GSTR-9 is an Annual Return format, which must be filed by all those who are registered under GST. Therefore, all regular taxpayers must file GSTR-9, while there’s a separate form for composition scheme taxpayers and e-commerce operators. Taxpayers with annual turnover of Rs. 2 crore, must also file GSTR-9C along with GSTR-9.

Taxpayers and tax professionals are struggling with compliance for F.Y. 2017-18 for filing the Annual Return called GSTR-9, Annual Return due date is extended from 30th June, to 31st August, 2019 for F.Y. 2017-18.

Annual return is a complex form that requires extensive reconciliation. Some businesses are yet to draw reconciliation between GSTR-1, GSTR2A and GSTR-3B, too many changes in the process of filing have kept some away from compliance with GSTR-9. GSTR-1 is filed by businesses to report supplies made by them and GSTR-3B is used for payment of taxes and GSTR-2A is for matching of the transactions. While GSTR-9 may seem like a collation of these three returns, it is not as simple as that. It requires taxpayers to carry out extensive reconciliation.

This reconciliation is between the returns filed by them for reporting supplies, paying taxes and those filed by their vendors and also books of account.

The information sought in GSTR-9 is split between tables some of which gets auto populated by returns already filed, while some have to be filed in by the taxpayers themselves.

Some taxpayers who paid RCM tax of one financial year in the next financial year’s GSTR-3B may face reporting issues. Suppose RCM tax is paid via GSTR-3B of F.Y. 2018-19, but supplies (inward supplies) were received in F.Y. 2017-18. Due to the manner in which information is plotted in the tables, such a tax payment if included has the effect of increasing turnover in GSTR-9, leading to payment gaps.

GSTR-1 form allows taxpayers to report additions and amendments to supplies made. While actual taxes paid are plotted in the Annual Return via GSTR-3B. Table No. 10 and Table No. 11 of the GSTR-9 have to be used for reporting amendments made and must be as per GSTR-1 based on instructions provided. However, Table No. 9 includes tax paid as per GSTR-3B, leading to confusion on how amendment must be included in the annual return. This can be lead to mismatch between the two sets of information where these are not an exact match.

After roll out of GST, we are in the third year but still glitches of system exist. As per latest CAG report (July 31)

There have been cases where some small businesses, paid taxes online but filed an incorrect GSTR-3B due to lack of resources and time.

So they are caught in a situation where taxes are paid, but incorrect values are reflecting in the auto-populated parts of GSTR-9, through GSTR-3B.

Some businesses are yet to draw reconciliations, between GSTR-1, GSTR2A and GSTR-3B. Too many changes in the process of filing have kept some away from compliance with GSTR-9.

Some businesses have un-reconciled issues or cases where B2B sales and B2C have been misreported and cannot be amended now (since amendment is only allowed once).

Successfully filing of GSTR-9 requires data to be thoroughly reviewed and reconciled. Understanding the causes of differences between the books of accounts and GST annual return is key to satisfactory compliance. Thousands of line items of data cannot be reconciled without using a smart solution that quickly points out and helps fix gaps. Therefore, businesses must begin with preparation of GSTR-9 without any further delay.

Ongoing issues with GSTR-9 must be quickly resolved. This must be done on a priority basis while a new GST return mechanism is being planned, after all a successful closure of the first year will help taxpayers move on and prepare to match and reconcile data for the following years.

Also where ITC is not available due to fault of the seller, buyers are unwilling to forego credit, leading to potential disputes with the authorities. Notably, no additional ITC claims can be made via GSTR-9, though additional tax payable found during reconciliation must be duly deposited with the government.

Taxpayers and tax consultant are also required to keep in mind the hundreds of amendments and clarifications issued by the government since inception of GST in July-2017. Besides major amendments in the GST Act in February-2019, over 200 tax notifications, including amendments in rules, about 180 tax rate notifications over 100 circulars, 20 orders, over 125 press releases and over 50 FAQ series and flyers have been issued till the date.

Further, the press releases and clarifications on certain points “lack clarity” and at some places, these are “against the GST laws” and need reconsideration, while some clarifications have “even increased the confusion” already prevailing in the minds of the taxpayers, tax consultants and auditors.

The time limit extended is not sufficient. The procedure of filing of Annual Return is very confusing with hundreds of changes in the rules and taxes. It is very crucial for the government to understand that the present form and law are not in agreement at certain places and are cumbersome as well as ambiguous to some extent.

It is practical as well as reasonable to appreciate the fact that as these forms and expectations there under are unreasonably complex and prone to error and mistake, hasty and unclear filling will only deteriorate the present situation that was created due to chaos that occurred in 2017-18. Unlike other tax returns, there is no option to revise monthly or quarterly returns under GST which is the main cause of the entire prevailing situation.

The government made available GST Annual Return 9, 9A & 9C for 2017-18 online in March-2019 and offline in April-2019, after nearly 20 months.

Taxpayers and tax professionals are given only 5 months to understand and file the most complex return form in the history of Indian Taxation. The due date of filing GSTR-9, 9A and 9C for 2017-18 and 2018-19 should be notified to be kept together, so that a total reconciliation can be done for both the years. This will help in better compliance and reporting.

Alternatively, the due date for filing GSTR 9, 9A and 9C for the year 2017-18 should be extended by at least 3 months till 30th November, 2019.

Your honor is humbly requested to consider our humble request and extend the due dates immediately and oblige.

Thanking You,
Yours faithfully,
For, The Gujarat Sales Tax Bar Association,

Urvish V. Patel

Snehal K. Thakkar

Copy to,

– The Hon. Finance Minister State of Gujarat.
– The Hon. Chief Commissioner of State Tax-SGST.
– The Hon. Chief Commissioner of Central Tax-CGST.

Download Representation on Extension of due date of Annual GST Return

List of the other recent Representation

S. No. Dated Submitted by Link
10. 19/08/2019 BCAS and 4 Others Representation on Income Tax and GST Issues faced by taxpayers
9. 19/08/2019 Professional Accountants’ &
Tax Consultants’ Association
Request for Extending Due Dates for filing Annual GST Returns
8. 17/08/2019 Chamber of Tax Consultants Extend due date for filing of GSTR -9, 9A and 9C for F.Y. 2017-18
7. 14/08/2019 Western Maharashtra Tax Practitioner’s Association Extend Due date of GST Returns in Flood affected States
6. 13/08/2019 Goods & Services Tax Practitioners Association of Maharashtra Extend GST, Income Tax and other due dates falling in Aug & Sep 2019
5. 12/08/2019 Association of Tax Lawyers, Delhi Request to Extend time limit for claim of ITC for FY 2017-2018
4. 10/08/2019 Karnataka State Chartered Accountants Association Extend Due Date for Filing of Income Tax and GST Returns
3. 18/07/2019 Tax Bar Association, Jodhpur Extend due date for filing of Income-tax returns to 30th Sept 2019
2. 11/06/2019 Goods And Services Tax Practitioners’ Association Of Maharashtra GST Annual Return & subsequent reconciliation for GST Audit- Issues
1. 05/08/2019 Gujarat Sales Tax Bar Association Request for extension of due date of Annual Return- GSTR-9 (As Above Post)

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  1. says:

    GSTR 9 filing date should be extended till Dec 2019 otherwise it may create lot of litigation. It is better to extend and make GSTR 9 very simple.

  2. sunil says:

    Yes Date should be extended as the date required in 9 & 9c is not mentioned in GSTR-1 & GSTR-3B.

  3. N. R. THAKRE says:

    Yes extend the due date for filling annual returns and also request to allow revised monthly returns to compile all the errors and differences between annual return and books of accounts

  4. Ranjith says:

    yes pls extend the date to Dec , Allow to revise the monthly returns and annual returns as in the case of VAT ,so that the annual return and the books of accounts will be same

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