GSTR-9 (Annual Return) filing was very challenging for FY 2017-18 until CBIC released their press release dated 04-06-2019 and 03-07-2019 in connection with clarification on source of data to be provided in different tables of GSTR-9 together with clarification on some doubts for how data to be provided in annual return. Further press release issued on 14-11-2019 wherein the Annual Return had been made simplified by clubbing information of different tables into one table which serve the purpose of information. After releasing these three press release, GSTR-9 was not so hard to fill and submit for FY 2017-18.

However we all supposed from GSTN Portal that GSTR-9 for FY 2018-19 would contain tables for showing adjustments for figures of FY 2017-18 reflected in 3B of FY 2018-19. GSTN has not done so and CBIC has also kept mum on this issue. We all are struggling to find solution that how to reflect adjustment of Input Credit availed/reversed and Output Tax unpaid/excess paid for FY 2017-18 and adjusted in GSTR-3B of FY 2018-19.  Now coming to the possible solution in my view of this hardship. There are four scenarios with regard to 2017-18 which could have direct bearing on figures of FY 2018-19.

  1. Output Tax short paid during FY 2017-18 but paid in 3B during FY 2018-19 – [Table 10 of GSTR-9 of FY 2017-18]
  2. Output Tax excess paid during FY 2017-18 but adjusted in 3B during FY 2018-19 – [Table 11 of GSTR-9 of FY 2017-18]
  3. Input Credit excess claimed in FY 2017-18 and reversed in 3B of FY 2018-19 – [Table 12 of GSTR-9 of FY 2017-18]
  4. Input Credit unclaimed in FY 2017-18 but claimed in FY 2018-19 – [Table 13 of GSTR-9 of FY 2017-18]

We would cover all the four aspects one by one with their possible solution.

Output Tax Short Paid During Fy 17-18 But Paid In GSTR-3B of FY 2018-19

In this scenario, GSTR-3B of FY 2018-19 should have include the short paid tax of FY 2017-18. While reporting turnover and tax in table 4 of GSTR-9 of FY 2018-19, only sales/supply data of FY 2018-19 would be used for reporting. The following steps can be used to fill table 4.

Particulars   Turnover IGST CGST SGST
Total turnover & output tax as declared in consolidated GSTR-3B downloaded from portal for FY 2018-19 A
Less: Output Tax declared for FY 2017-18 in FY 2018-19 B
Net Turnover & Output Tax for FY 2018-19 paid in GSTR-3B during FY 2018-19 to be declared in Table 4 of GSTR-9 C [A-B]

The net turnover and output tax as arrived in above table at ‘C’ column shall be declared in Table 4 of GSTR-9 of FY 2018-19

Prepare below mentioned table to fill Table 10 & 11 for GSTR-9 of FY 2018-19

Particulars   Turnover IGST CGST SGST
Total turnover & output tax asper books of accounts of FY 2018-19 D
Less: Net Turnover & Output Tax for FY 2018-19 paid in GSTR-3B during FY 2018-19 asper column ‘C’ above E
Short/Excess output tax paid/setoff during FY 2019-20 F [D-E]

Where output tax is short paid during FY 2018-19 but paid through 3B before 20-10-2019 or extended due date, same shall be declared in Table 10 of GSTR-9. Where output tax is excess paid and adjusted in 3B before 20-10-2019 or extended due date, same shall be declared in Table 11 of GSTR-9.

Output Tax Excess Paid During FY 17-18 But Set Off In GSTR-3B of FY 18-19

In this scenario, the output tax liability of FY 2018-19 would have been discharged through 3B after setoff for excess tax paid during FY 2017-18. While reporting turnover and tax in table 4 of GSTR-9 of FY 2018-19, only sales/supply data of FY 2018-19 would be used for reporting. The following steps can be used to fill table 4.

Particulars   Turnover IGST CGST SGST
Total turnover & output tax as declared in consolidated GSTR-3B downloaded from portal for FY 2018-19 A
Add: Excess Output Tax adjusted for FY 2017-18 in 3B of FY 2018-19 B
Net Turnover & Output Tax for FY 2018-19 paid in GSTR-3B during FY 2018-19 to be provided in Table 4 of GSTR-9 C [A+B]

The net output tax and related turnover for FY 18-19 as arrived in above table at ‘C’ column shall be declared in Table 4 of GSTR-9 of FY 2018-19.

Prepare below mentioned table to fill Table 10 & 11 for GSTR-9 of FY 2018-19

Particulars   Turnover IGST CGST SGST
Total turnover & output tax asper books of accounts of FY 2018-19 D
Less: Net Turnover & Output Tax for FY 2018-19 paid in GSTR-3B during FY 2018-19 asper Column ‘C’ in above table. E
Short/Excess turnover and output tax paid during FY 2019-20 F [D-E]

Where output tax is short paid during FY 2018-19 but paid through 3B before 20-10-2019 or extended due date, same shall be declared in Table 10 of GSTR-9. Where output tax is excess paid and adjusted in 3B before 20-10-2019 or extended due date, same shall be declared in Table 11 of GSTR-9.

With regard to Table 9 for total tax payable, the figures of total tax paid as arrived system computed should not be changed as it is the total liability duringr FY 18-19 which is actually discharged through 3B. In my view a reconciliation statement is to be prepared in excel sheet for total tax paid asper Table 6.1 of consolidated GSTR-3B of FY 2018-19. The format of reconciliation of total tax paid could be as under.

Particulars   IGST CGST SGST
Total Tax Paid asper Table 6.1 of consolidated GSTR-3B of FY 18-19 A
Less: Short output Tax for FY 17-18 paid in 3B of FY 18-19 B
Add: Excess Tax paid during FY 17-18 and setoff during FY 18-19 C
Less: Input Reversal for FY 2017-18 in 3B of FY 18-19 added in output tax liability at Table 6.1 of 3B D
Less: Input Reversal for FY 2018-19 in 3B of FY 18-19 added in output tax liability at Table 6.1 of 3B E
Less: RCM paid for FY 17-18 in 3B of FY 18-19 added in output tax liability at Table 6.1 of 3B F
Less: RCM paid for FY 18-19 in 3B of FY 18-19 added in output tax liability at Table 6.1 of 3B G
Output Tax Paid for FY 18-19 through 3B of FY 18-19 match with Output Tax on supply declared in Table 4 of GSTR-9 H [(A+C)-(B+D+E+F+G)]

The above three tables in each case should be prepared properly with name, financial year and GSTN of taxpayer and should be enclosed with GSTR-9C as optional attachments where GST audit is mandatory. Where no GST Audit but some liability is to be paid through DRC-03, these sheets can be attached with DRC-03. In any other case, these sheets may be submitted to proper officer with a covering letter.

Input Tax Credit Excess Claimed During FY 17-18 But Reversed In GSTr 3B of FY 2018-19

Where input tax excess claimed during FY 17-18 is reversed through GSTR-3B of FY 18-19, it has not disturbed Table 4A for Input Tax credit claimed for FY 18-19 rather reversal of FY 17-18 has been put in Table 4B of 3B. The figures in Table 6A of GSTR-9 would fetch data from Table 4A only. Therefore reversal of FY 17-18 in FY 18-19 has no bearing on Table 6 of GSTR-9. Infact reversal of FY 17-18 done in FY 18-19 is added to output tax liability in Table 6.1 of 3B of FY 18-19. Therefore we have nothing to do in Table 6 of GSTR-9 for FY 18-19. We have to provide reconciliation of Tax Payable as reflected in Table 6.1 of consolidated 3B of FY 18-19 in the format as provided above as a separate attachment. There will be no adjustment in GSTR-9 of FY 18-19. It is better not to show this reversal of FY 17-18 in Table 7 of GSTR-9. Only provide a reconciliation summary of tax payable asper Table 6.1 of consolidated 3B asper above format to make your clear view to tax authorities.

Input Tax Unclaimed During FY 2017-18 But Claimed In GSTR 3B Of FY 2018-19

We must prepare a table before filling details in Table 6 as provided below.

Particulars   Table Of GSTR-9 IGST CGST SGST
Reconciliation Of Table-6 Of GSTR-9
   
Total Itc As Per GSTR 3B Filed For FY 2018-19 A 6A          21,96,607.63            6,43,586.77             6,43,586.77
Less: ITC Claimed For Fy 2017-18 In 3B OF FY 2018-19 B 6M                28,603.63                      431.77                      431.77
Net ITC Of FY 2018-19 Claimed In GSTR-3B C  [A-B]          21,68,004.00            6,43,155.00             6,43,155.00
Less: ITC Claimed Against RCM Payments D 6D                                –                  1,901.00                   1,901.00
ITC Claimed Of FY 2018-19 Other Than RCM E [C-D] 6B          21,68,004.00            6,41,254.00             6,41,254.00
 
ITC As Per Books
Inward Supply Other Than RCM & Imports F          22,08,861.00            6,60,897.00             6,60,897.00
ITC To Be Claimed Up to Due Date Of 3B Of Sept 2019 G [F-E] 8C                40,857.00                17,742.00                17,742.00

In Table 6B of GSTR-9, we should provide figures as arrived in column ‘E’ above as it is the ITC of B2B inward supplies for FY 2018-19. Figures of RCM Input availed are to be provided in respective Table 6D of GSTR-9 both for FY 17-18 and FY 18-19. There will be a difference in Table 6J equal to ITC claimed for FY 2017-18. We should fill-up ITC of FY 2017-18 claimed in FY 18-19 in Table 6M ‘Any other ITC availed but not specified above’. In this way total ITC claimed in GSTR-3B of FY 18-19 would match with total ITC of Table 6 of GSTR-9.

The difference in ITC asper books of accounts and ITC claimed asper Table 6B of GSTR-9 is the ITC unclaimed for FY 2018-19 as provided in Column ‘G’ of above table. It should be declared in Table 8C of GSTR-9 and also in Table 13 if claimed in next FY 2019-20 upto due date of 3B of September 2019.

The above working made in Excel sheet may be attached as an optional attachment with GSTR-9C. Where GSTR-9C is not applicable it may be enclosed with DRC-03 if any payment is to be made against filing of GSTR-9. In any other case you may choose to submit it to proper officer for future reference.

The above tables may be modified with specific requirements of taxpayer and can be used as a tool for self-working and reconciliation. It may be submitted to tax authorities for clarifying data in more efficient way as format of GSTR-9 is not comprehensive covering all aspects.

This my personal suggestion for filing of GSTR-9

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14 Comments

  1. CA Dipak Unadkat says:

    Dear Sir

    Your article is superb and very well explained. It will be very much useful to us. I wanted to know that in 8C of Annual Return in Form No 9, they have given ITC of 2017-18 taken in 2018-18 and also ITC of 2018-19 in 19-20. How to disclosed ITC of 2017-18 taken as well reversed in 2018-19 here and also how to match with table 6. Pl guide.

    1. nitinkumsgl says:

      Thank you for appreciating words,

      ITC of FY 17-18 which is taken in 3B of 2018-19 should be disclosed in Table 6M, in this way Table 6B will carry only the ITC of FY 2018-19 to Table 8B for comparison to Table 8A. Where ITC of FY 2018-19 is claimed in FY 2019-20, it should be disclosed in Table 8C and Table 13.

      Where ITC of FY 17-18 is reversed in FY 2018-19, there will be no mention of it in GSTR-9. ITC reversal can be netting off with ITC in the month of reversal. Where ITC is Nil or less in the month of reversal, it could be added to Ouput Tax in Table 6.1 of GSTR-3B. Where it has been added to Output Tax in Table 6.1, it will form part of Table 9 in “Tax Paid”.

      In case of excess ITC claimed reversed in next year there is no need to disclose it in any Table of GSTR-9. Provide a reconciliation of Table 9 (Taxes Paid) with GSTR-9C as additional disclosure in the format already given in this Article.

      If you still have any doubt, you can email your query to nitinkumsgl@gmail.com

  2. Sachin Tyagi says:

    Sir, this is very good article. In this article you have clear that how we can show adjustments in GSTR 9. The way of explaining is awesome. I hope that you will post the GST related article in future also.

  3. Sheetal says:

    In case where output tax of 1718 is paid in 1819, we declare it in Table 10. The payment of tax should be reported in Table 9 or Table 14 or both.? Please guide
    In auto computed details it appears in Table 9.

    1. nitinkumsgl says:

      Where Output TAx of FY 17-18 is paid in FY 2018-19 and you are filing GSTR-9 of F.Y. 2018-19 then such output tax shall be included in Table 9. You must show sales figures and output GST in Table 4 for FY 2018-19 asper consolidated GSTR-3B of FY 2018-19. Output GST of FY 18-19 must be shown upto the amount which has been actually paid thru 3B. Total liability asper Table 4 should be shown in Table 9. On comparison of Tax Payable and Tax paid in Table 9, there would be difference equal to Output GST paid for FY 17-18. Let the difference arrive. Prepare a reconcniliation of Table 9 as suggested in this Article itself and enclose it with GSTR-9C or DRC-03 or submit manually as already advised in this Article.

  4. Prabagarane V says:

    Sir, Your reconciliation for statement to fill up Form9 could be understood. Thank you sir for your detailed illustration.But how to match Form 9 with Form 9C in such type of situations

    1. nitinkumsgl says:

      Just follow the tables given in the article and fillup GSTR-9. You can do one thing you prepare GSTR-9 and 9C simultaneously and put comparing figures of GSTR-9 by mannually in GSTR-9C. Show output tax in Table 9 of GSTR-9 as arrive in Table 4 of GSTR-9. I have my personal experience to prepare lot of GSTR-9 and 9C. There will be no difference in 9C.

  5. Rajeev Joshi says:

    ITC of 2017-2018 which was availed in GSTR- 3B of 2018-2019, Now I want to ask that in GSTR 9 of 2018-2019 In which col. I should show that ITC, because As per GSTR 2A and GSTR 3B a mismatch of same amount is reflecting.

        1. nitinkumsgl says:

          As you know that there is no specific table for showing carryforward ITC of FY 2017-18, we have choose 6M for it as there is no other table suitable for it. If we add this carryforward credit in 6B then it will be automatically transferred to 8B and shall be higherside than 8A. It will lead to non reconciliation of Table 8A and 8B. It is better to seperate the carryforward ITC in 6M so that reconciliation of ITC of FY 2018-19 should be there in 8A and 8B. You can tell the authorities that you have shown carryforward ITC in 6M by enclosing a statement of reconciliaton of ITC as depicted in this article itself.

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