With the implementation of Goods and Services Tax (GST) in India from July 1, 2017, there has been a paradigm shift in indirect taxation structure in India from origin-based tax to destination based tax. Section 35(5) read with Section 44 and Rule 80(3) of Goods and Services Tax (GST) Laws provides that every registered person, whose aggregate turnover during a financial year exceeds two crore rupees, is required to get his/her accounts audited.

The copy of audited annual accounts and a reconciliation statement, duly certified, in Form GSTR-9C has to be submitted on or before the 31st Day of December by the tax payer.

In this regard, the Government has notified Form GSTR-9C on 13th September, 2018 comprising Reconciliation Statement and Certification, which needs to be certified by the Chartered Accountants.

Now, our members have an opportunity as well as responsibility to assist the assessees in filing the statutory Form 9 and also in conducting the GST Audit. In view of the importance of the matter, the Indirect Taxes Committee of ICAI has come out with this ‘Technical Guide on Annual Return & GST Audit’. This Guide has been comprehensively designed and contains clause-by-clause analysis of Form GSTR-9, 9A and Form GSTR -9C. I am confident that this publication will be of great significance and will provide assistance to our members on the critical issues arising while conducting audit. I request my professional colleagues to equip themselves and exercise due care while certifying this Form.

The Goods and Services Tax regime is revolutionary in the realm of commodity taxes and services tax. It has brought about a paradigm shift in the methodology of levy and collection of taxes. It is an internationally recognized multipoint tax system providing for levy of tax on goods as well as services on the value addition occurring at every stage of business activity. GST being in the nature of a self-assessment tax, audit procedures are introduced for error correction and ensuring proper compliance.

This Technical Guide on Annual return & GST Audit is a written attempt to create awareness among the trade/ industry and more importantly for the members to discharge their professional duties. Members would be assisting the smaller clients in filing GSTR-9. Further they would be carrying out the audit under section 35(5) along with drawing up reconciliation statement as required under Section 44(2) of CGST Act, 2017 in Form GSTR-9C and certifying the same for those with a turnover over 2 Crores.

An attempt has been made in this guide to cover areas that are related to the basic principles, policies and special issues pertaining to conduct of a Goods and Services Tax Audit; drawing up reconciliation statement in Form GSTR-9C and certifying; assistance in filing GSTR-9 Form. This paper does not deal with legal interpretations and rulings. This does not contain answers to all the problems that may arise in the day-to-day audit work. In such cases, the GST auditor may have to apply his mind judiciously, keeping in view the intent behind the law, principles and policies.

The practical difficulties faced in filling these forms have been highlighted to the Government which are available at http://idtc.icai.org/budget-memorandum.html . Answers to them are awaited from the Government.

Future changes in the GST Acts, Rules thereon, administrative policies and procedures may require changes to this guide from time to time.

The members who have already started assisting in filing of the Form-9 or conduct of the GST audits and those planning to start immediately could refer to this guide and offer the practical issues arising therefrom.

While, the general scheme of audit, the detailed steps, filling of forms and certification are outlined in the main part of the book, the references and sample documents are incorporated in Annexure and Appendix such as Standard Audit Program, Check list, Audit Working Papers, Notifications, etc. Therefore, these documents should also be perused to understand the entire gamut of the audit scheme under the GST Laws.


S. No. Title
1. Introduction to Goods and Services Tax Audit
2. Auditor and Appointment of Auditor
3. Audit Approach

(Audit Planning, Strategy and Execution)

4. Important Aspects for GST Audit of Multi-Locational Entities
5. Accounting Standards and Ind-AS
6. GST Audit in Computerised Environment
7. Insights on Input Tax Credit under GST
8. Important Aspects to Know
9. Analysis of GSTR-9
10. Analysis of GSTR-9A
11. Analysis of GSTR-9C
Appendix 1 : Provisions of CGST Act, 2017 and IGST Act,2017 as which are

relevant for Audit.

Appendix 2 : Form GSTR 9
Appendix 3 : Form GSTR 9A
Appendix 4 : Form GSTR 9C
Appendix 5 : Council’s Resolution on part time practice
Appendix 6 : Disclosure of substantial interest
Appendix 7 : Professional Ethics & Misconduct
Appendix 8 : Professional misconduct- acceptance of other work in which appointed as Auditor
Appendix 9 : Suggested format for Appointment Letter
Appendix 10 : Suggested Audit Checklist
Appendix 11 : List of Auditing Standards issued by the ICAI
Appendix 12 : List of Accounting Standards notified by the Central Government
Appendix 13 : Letter of Management Representation
Appendix 14 : Abbreviations

Sources :- Download Technical Guide on Annual Return and GST Audit

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  1. S.Kannan says:

    Audited Annual Statement and Audited Annual Accounts are two different things. Any body can explain the legal term ” copy of the audited annual accounts “. As per my opinion the term copy of the audited annual accounts, A chartered Accountant or Cost Accountant who audited annual accounts of a registered person means Accounting Software ( Name of the Software with its version ) DATA on which the annual accounts was audited, so copy of such DATA shall be furnish along with Annual return in form GSTR- 9. I welcome if any legal definition in this regards.

  2. Shivanand Gokak says:

    In GSTR3B ITC utilisation for payment of CGST, SGST first ITC balance of CGST,SGST have to utilise and then IGST can be used. It means if there is no IGST liability , the ITC balance will be in IGST only. If there is any reversal of CGST SGST in subsequent month, whether it can be reversed by using IGST ITC Balance?

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