As the India continues its winning streak against Pakistan in cricket world cups, the rush for filing GSTR 9 and GSTR 9C is also catching up, continuing the legacy of the first three parts, here we present the 4th and last part of our series of article, “Unravelling GSTR 9- A clause by clause analysis by CA Vishal Jain”. This part deals with the remaining 10 tables (table 10 to table 19) of GSTR 9.
Part V comprises of table 10 to table 13 and is one of the most significant part of GSTR 9. All those transactions which pertains to the FY 2017-18 but is reported in the returns of FY 2018-19, shall be reported in part V of GSTR 9.
Such transactions could be in the form of:
1. Supply of FY 2017-18 omitted to be reported in the returns of FY 2017-18, reported in the returns of FY 2018-19.
2. Amendments made to the supply figures already reported in the returns of FY 2017-18, in the returns of FY 2018-19.
3. Availment of ITC in the returns of FY 2018-19 which was omitted to be availed in the returns of FY 2017-18.
4. Reversal of ITC in FY 2018-19, which was availed in the returns of FY 2018-19.
5. Amendments made to the details of credit note/ debit notes issued and reported in 2017-18.
6. Reporting the Credit notes/ debit notes issued in the FY 2017-18, but reported in the returns of FY 2018-19.
It is pertinent to note that the credit/ debit notes issued in the FY 2018-19, in respect of the supplies of FY 2017-18, the same would not become part of GSTR 9 for the very reason that these are not the transactions of the FY 2017-18, these are the transactions of FY 2018-19.
Further, in case the return for the FY 2017-18 are filled belatedly in FY 2018-19, then it will still be considered as reported in FY 2017-18 and would be disclosed in the above four parts and not in part V. In other words, only those transactions, which belong to FY 2017-18 and are amended or reported in the returns of FY 2018-19, will be disclosed in part V.
Let’s analyze the contents of part V.
| Instructions- Part V | ||||||||||
| Part V consists of particulars of transactions for the previous financial year but paid in the FORM GSTR-3B of April to September of current FY or date of filing of Annual Return for previous financial year (for example in the annual return for the FY 2017-18, the transactions declared in April to September 2018 for the FY 2017-18 shall be declared), whichever is earlier. The instructions to fill Part V are as follows: | ||||||||||
| Pt V | Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of filing of annual return of previous FY whichever is earlier | |||||||||
| Description | Taxable Value | Central Tax | State Tax/UT Tax | Integrated Tax | Cess | |||||
| 1 | 2 | 3 | 4 | 5 | 6 | |||||
| Instructions- Table 10 & 11 | ||||||||||
| Details of additions or amendments to any of the supplies already declared in the returns of the previous financial year but such amendments were furnished in Table 9A, Table 9B and Table 9C of FORM GSTR-1 of April to September of the current financial year or date of filing of Annual Return for the previous financial year, whichever is earlier shall be declared here. | ||||||||||
| 10 | Supplies / tax declared through Amendments (+) (net of debit notes) | • As already discussed in above, the items to be reported in Table 10 are:
(a) Supply of FY 2017-18 omitted to be reported in the returns of FY 2017-18, reported in the returns of FY 2018-19. (b) Debit notes issued in FY 17-18 omitted in 2017-18 and reported in the returns for the months of April 2018 to March 2019. (c) Amendments to invoices related to 2017-18 and reported (with errors) in the GSTR 3B for 2017-18 but now reported (duly rectified) in the returns for the months of April 2018 to March 2019. • The figure reported here will be considered at the time preparing GSTR 9C. |
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| 11 | Supplies / tax reduced through Amendments (-) (net of credit notes) | • (a) Credit notes issued in 2017-18 and reported in the returns of 2018-19.
(b) Amendments to invoices related to 2017-18 and reported (with errors) in the GSTR1 for 2017-18 but now reported (duly rectified) in the returns i.e 3B for the months April 2018 to March 2019 • The figure reported here will be considered at the time preparing GSTR 9C. |
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| Instructions- Table 12 | ||||||||||
| Aggregate value of reversal of ITC which was availed in the previous financial year but reversed in returns filed for the months of April to September of the current financial year or date of filing of Annual Return for previous financial year, whichever is earlier shall be declared here. Table 4(B) of FORM GSTR-3B may be used for filling up these details. | ||||||||||
| 12 | Reversal of ITC availed during previous financial year | • ITC availed in during the period July 2017 to March 2018, which has been reversed during the FY 2018-19.
• Ex: ITC on motor vehicle wrongly availed in 17-18 now reversed in FY 2018-19. • The figure reported here will not be considered at the time preparing GSTR 9C and are here merely for disclosure purposes. |
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| Instructions- Table 13 | ||||||||||
| Details of ITC for goods or services received in the previous financial year but ITC for the same was availed in returns filed for the months of April to September of the current financial year or date of filing of Annual Return for the previous financial year whichever is earlier shall be declared here. Table 4(A) of FORM GSTR-3B may be used for filling up these details. However, any ITC which was reversed in the FY 2017-18 as per second proviso to subsection (2) of section 16 but was reclaimed in FY 2018-19, the details of such ITC reclaimed shall be furnished in the annual return for FY 2018-19. | ||||||||||
| 13 | ITC availed for the previous financial year | • ITC pertaining to the FY 2017-18 not availed in 17-18, now availed in FY 2018-19.
• The same would also be reported in the table 8C above. • The figure reported here will not be considered at the time preparing GSTR 9C and are here merely for disclosure purposes. |
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| 14 | Differential tax paid on account of declaration in 10 & 11 above | |||||||||
| Description | Payable | Paid | ||||||||
| 1 | 2 | 3 | ||||||||
| Integrated Tax | • The additional liability created on account of declaration in table 10 & 11 above will be reported here.
• Additional liability needs to be discharged via form DRC- 03. • Excess payment has to be claimed as refund. |
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| Central Tax | ||||||||||
| State Tax/UT Tax | ||||||||||
| Cess | ||||||||||
| Interest | ||||||||||
| Pt VI | Other Information | |||||||||
| 15 | Particulars of Demands and Refunds | |||||||||
| Details | CGST | SGST | IGST | Cess | Interest | Penalty | Late fees/Others | |||
| Instructions- Table 15A, 15B, 15C, 15D. | ||||||||||
| Aggregate value of refunds claimed, sanctioned, rejected and pending for processing shall be declared here. Refund claimed will be the aggregate value of all the refund claims filed in the financial year and will include refunds which have been sanctioned, rejected or are pending for processing. Refund sanctioned means the aggregate value of all refund sanction orders. Refund pending will be the aggregate amount in all refund application for which acknowledgement has been received and will exclude provisional refunds received. These will not include details of non-GST refund claims. | ||||||||||
| A | Total Refund claimed | • Details of refund claimed and sanctioned during the FY 17-18 needs to be reported here, including pendency thereof.
• Rejection of the refund application is required to be reported separately. |
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| B | Total Refund Sanctioned | |||||||||
| C | Total Refund Rejected | |||||||||
| D | Total Refund pending | |||||||||
| Instructions- Table 15E, 15F, 15G | ||||||||||
| Aggregate value of demands of taxes for which an order confirming the demand has been issued by the adjudicating authority shall be declared here. Aggregate value of taxes paid out of the total value of confirmed demand as declared in 15E above shall be declared here. Aggregate value of demands pending recovery out of 15E above shall be declared here. | ||||||||||
| E | Total Demand of Taxes | • The proceedings which has resulted in demand notices is required to be reported here.
• The amount paid against these notices would also be reported here, with the pendency thereof. • The demand notice may also include the notices received for E-way bill issues. |
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| F | Total taxes paid in respect of E above | |||||||||
| G | Total demands pending out of E above | |||||||||
| 16 | Information on supplies received from composition taxpayers, deemed supply under section 143 and goods sent on approval basis | |||||||||
| Details | Taxable Value | Central Tax | State Tax/UT Tax | Integrated Tax | Cess | |||||
| 1 | 2 | 3 | 4 | 5 | 6 | |||||
| Instructions- Table 16A | ||||||||||
| Aggregate value of supplies received from composition taxpayers shall be declared here. Table 5 of FORM GSTR-3B may be used for filling up these details. | ||||||||||
| A | Supplies received from Composition taxpayers | • In this column, sum total of inward supplies received from composition taxpayers need to be disclosed.
• This would be a tedious task for the tax payers to identify the status of vendors. |
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| Instructions- Table 16B | ||||||||||
| Aggregate value of all deemed supplies from the principal to the job-worker in terms of sub-section (3) and sub-section (4) of Section 143 of the CGST Act shall be declared here. | ||||||||||
| B | Deemed supply under Section 143 | • Deemed supply under section 143 means any inputs/capital goods sent for job work has not been received back with the specified time limit under section 143 (inputs – 1 year and capital goods – 3 years) because of which, such supplies are considered as deemed supply in the hands of the person who had sent the goods.
• For the annual return of 2017-18, this column may not be filled because the inputs/capital goods sent for job work during July 2017 will still within the time limit of 1/3 years respectively. |
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| Instructions- Table 16C | ||||||||||
| Aggregate value of all deemed supplies for goods which were sent on approval basis but were not returned to the principal supplier within one eighty days of such supply shall be declared here. | ||||||||||
| C | Goods sent on approval basis but not returned | • The details of deemed supply with respect to goods sent on approval but not has been approved within the period of six months is required to be reported here.
• The reporting is merely disclosure in this column and the actual transaction which have been shown in table 4 above. |
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| Instructions- Table 17 & 18 | ||||||||||
| Summary of supplies effected and received against a particular HSN code to be reported only in this table. It will be optional for taxpayers having annual turnover upto ₹ 1.50 Cr. It will be mandatory to report HSN code at two digits level for taxpayers having annual turnover in the preceding year above ₹ 1.50 Cr but upto ₹ 5.00 Cr and at four digits’ level for taxpayers having annual turnover above ₹ 5.00 Cr. UQC details to be furnished only for supply of goods. Quantity is to be reported net of returns. Table 12 of FORM GSTR-1 may be used for filling up details in Table 17. It may be noted that this summary details are required to be declared only for those inward supplies which in value independently account for 10 % or more of the total value of inward supplies. | ||||||||||
| 17 | HSN wise Summary of outward supply | |||||||||
| HSN Code | UQC | Total Quantity | Taxable Value | Rate of Tax | Central Tax | State Tax/UT Tax | Integrated Tax | Cess | ||
| 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | ||
| • The outward supply made by the registered person during July 2017 to March 2018 need to be reported HSN wise in this section.
• The details would be available from Table 12 of GSTR-1 |
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| 18 | HSN wise Summary of inward supply | |||||||||
| HSN Code | UQC | Total Quantity | Taxable Value | Rate of Tax | Central Tax | State Tax/UT Tax | Integrated Tax | Cess | ||
| 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | ||
| • The inward supplies received during the period July 2017 to March 2018 needs to be reported at HSN level.
• It may be noted that this summary details are required to be declared only for those inward supplies which in value independently account for 10 % or more of the total value of inward supplies. • This data would not be available from any of the returns filed by the registered person. • Hence, it is important to prepare this detail from the accounting software and to be reported in this column. • Therefore, there would be lot of challenges to fill the data in the HSN wise with respect to inward supplies. |
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| Instructions- Table 19 | ||||||||||
| Late fee will be payable if annual return is filed after the due date. | ||||||||||
| 19 | Late fee payable and paid | |||||||||
| Description | Payable | Paid | ||||||||
| 1 | 2 | 3 | ||||||||
| A | Central Tax | • Late fee will be payable if annual return is filed after the due date.
• The late fee is Rs.100 per day and maximum of quarter percentage (0.25%) of the turnover in the state or union territory. • This figure would be auto-populated in case of delayed filing on Annual return. |
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| B | State Tax/UT Tax | |||||||||
This is the fourth and last part of the series of article on GSTR-9, “unravelling GSTR 9- A clause by clause analysis by CA Vishal Jain”. Thank you readers for the love and support.
Special thanks to CA Ashish Chaudhary Sir for vetting this.
The members who have already started assisting in filing of the Form-9 or conducting the GST audits and even those who are planning to start these activities could refer to this write-up and give us their comments on any practical issues arising therefrom.
The author is a qualified chartered accountant and can be reached at: Email: thevishjain@gmail.com
Disclaimer: The information cited in this Guide has been drawn primarily from the www.cbec.gov.in and other sources. Readers are requested to note Sl. Nos / Table no’s etc., wherever mentioned refer to the appropriate part / table of the relevant Forms. While every effort has been made in this write-up to avoid any kind of errors or omissions. It is likely that errors may have crept in. Any mistake, error or discrepancy noted by the reader should be brought to the notice of the author so that suitable edits / corrections shall be effected in the next edition. It is notified that the author will not be responsible for any damage or loss to anyone of any kind or in any manner whatsoever by the use of this write-up.
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In your GSTR-9 article Part III -Instruction for 6D you have mentioned “Supplies on which ITC is availed in FY 2018-19, will be reported in Part V.”
But in your Article Part-IV you forget to mention where to add in Part V that inward supplies on which Reverse charge liability was paid & ITC availed during 2018-19