All about simplification of GSTR-9 (Annual Return) & GSTR-9C (Reconciliation Statement)
In a relief to taxpayers, the government on Thursday extended the due dates for filing GST annual returns (GSTR-9) and reconciliation statement (GSTR-9C) for financial year 2017-18 to 31st December 2019 and for the financial year 2018-19, to 31st March 2020.
Responding to the long awaited demand of trade & industry for simplification of GSTR-9 & 9C, the government has decided to simplify these forms by making various fields of these forms as optional. The CBIC has notified the amendments regarding the simplification of the annual return and reconciliation statement forms vide Notification No. 56/2019 – Central Tax dated 14th November, 2019.
Here in this article, the simplifications/ relaxations carried out by the government vide aforesaid notification has been presented clause wise and table wise for easy understanding of readers. It is important to note here that all the simplifications/ relaxations (except amendment in Certification in Part-B of GSTR-9C) discussed in foregoing paragraphs are only for first two years of GST i.e. for Financial Year 2017-18 and Financial Year 2018-19.
1. Option to fill Table-4B to Table-4E (related to supplies on which tax is payable) net of Credit Notes/ Debit Notes/ Amendments:
a. No Separate details of Credit notes/ Debit Notes are required in Table-4I & 4J. Thus details of Credit notes/ Debit Notes can be merged with details given in Table-4B to Table-4E.
b. No Separate details of Supplies or tax declared/ reduced through amendments is required in Table-4K & 4L. Meaning thereby these details can be merged with details given in Table-4B to Table-4E.
c. It may be noted that the details of B2C supplies in Table-4A is already required as net of Credit notes/ Debit Notes.
2. Option to fill Table-5A to Table-5F (related to supplies on which tax is not payable) net of Credit Notes/ Debit Notes/ Amendments:
a. No Separate details of Credit notes/ Debit Notes are required in Table-5H & 5I. Thus details of Credit notes/ Debit Notes can be merged with details given in Table-5A to Table-5F.
b. No Separate details of Supplies declared/ reduced through amendments is required in Table-5J & 5K. Meaning thereby these details can be merged with details given in Table-5A to Table-5F.
3. Option to report Exempted, Nil rated and Non GST Supplies (Table-5D to 5F) on consolidated basis in the “exempted” row only i.e. in Table-5D.
4. In Table-6B to 6E, Option to report ITC on Inputs, Capital Goods and Input Services on consolidated basis under “Inputs” row only:
a. Bifurcation of Normal ITC among Inputs, Capital Goods and Input Services is not required,
b. Bifurcation of RCM ITC among Inputs, Capital Goods and Input Services is not required,
c. Bifurcation of Import ITC among Inputs and Capital Goods is not required.
5. Option to Report RCM ITC on Inward supplies from registered persons (Table-6D) and unregistered person (Table-6C) on consolidated basis in Table-6D.
a. Thus there is no need to bifurcate the RCM ITC among supplies received from registered suppliers and unregistered person, as all the supplies can be reported under registered supplier table (Table-6D).
b. Thus the entire RCM ITC falling under Input/ Capital Goods and Input Services table of Table-6C & Table-6D may be reported in totality in Input row of Table-6D.
6. Option to report the entire amount of reversal (From Table-7A to 7E) under Table 7H only
a. An option has been provided to report the consolidated reversal of ITC falling under Table-7A to 7E in Table-7H.
b. However, reversals on account of TRAN-1 credit (Table 7F) and TRAN-2 (Table 7G) are to be separately reported,
7. Option to upload the details for the entries in Table 8A to 8D in duly signed PDF format in FORM GSTR-9C (without the CA certification)
8. Option to not fill Table-12 (Reversal of ITC availed during preceding year) & Table-13 (ITC Availed for the preceding year)
9. Option to not fill Particulars of Demands and Refund (Table- 15A to 15G)
10. Option to not provide Information on supplies received from composition taxpayers, deemed supply under section 143 and goods sent on approval basis (Table- 16A to 16C)
11. Option to not provide HSN Wise Summary of Outward & Inward supplies (Table-17 & 18)
1. Relaxation from providing separate details for adjustment in turnover in Table-5B to 5N, rather the consolidated details may be provided in Table-5O.
2. Option to not fill Table-12B & 12C under reconciliation of ITC:
a. Details of ITC booked in earlier Financial Years claimed in current Financial Year in Table-12B is not required to be given.
b. Details of ITC booked in current Financial Year to be claimed in subsequent Financial Years is not required to be given.
3. Big relaxation from furnishing expense wise bifurcation of ITC in Table-14:
a. Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of accounts are not required as filing of Table-14 has been made optional.
1. Auditor’s comment on Cash Flow Statement is required only when the Cash Flow Statement has been prepared.
2. Wording of Auditor’s opinion has been substituted to “True and Fair” from “True and Correct”.
Now with the simplifications in these forms, all the GST taxpayers would be able to file their annual returns (GSTR-9) along with reconciliation statement (GSTR-9C) in time without much hurdle.
(Disclaimer: This write up is based on the understanding and interpretation of the author and the same is not intended to be a professional advice.)
[The author is Chartered Accountant and can also be reached at firstname.lastname@example.org]