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TMI BlogAnnual returns in GSTR 9 - clarificationsX X X X Extracts X X X X X X X X Extracts X X X X ..... the Central Board of Indirect Taxes has issued three clarificatory circulars on 04.06.2019 and 03.07.2019 taking note of the difficulties faced in filing the information in the various Tables of the GSTR 9. In order to assist the taxpayers, all the clarifications issued regarding the annual returns (GSTR 9) and the reconciliation statement (GSTR 9C) are summarized below. This will ensure qualitative filing of information by the taxpayers. 3. Primary data source for declaration in annual return: Time and again taxpayers have been requesting as to what should be the primary source of data for filing of the annual return and the reconciliation statement. There has been some confusion over using FORM GSTR-I, FORM GSTR-3B or books of accounts as the primary source of information. It is important to note that both FORM GSTR-I and FORM GSTR-3B serve different purposes. while, FORM GSTR-I is an account of details of outward supplies, FORM GSTR-3B is where the summaries of all transactions are declared and payments are made. Ideally, information in FORM GSTR-I, FORM GSTR-3B and books of accounts should be synchronous and the values should match across different forms and the b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Credit in Part IV: Information contained in FORM GSTR- 2A as on 01.05.2019 shall be auto-populated in Table 8A of FORM GSTR-9. Some taxpayers have reported that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A. Please note that this may happen due to following reasons: a. Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-I of the supplier taxpayer. But figures in table 8A of Form GSTR-9 are auto- populated only on the basis of filed GSTR-I by the supplier taxpayer. In case, Form GSTR -l is not filed by your supplier, then credit related to those invoices will not appear in table 8A of your Form GSTR-9. b. Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR- I, which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April, 2019, will not get auto-populated in table 8A of Form GSTR-9. c. In table 8A of Form GSTR-9, only latest values have been auto-populated based on filed Form GS ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... never entered the electronic credit ledger of any taxpayer. Therefore, taxpayers need not be concerned about the values reflected in this table. This is merely an information that the Government needs for settlement purposes. Figures in Table 8A of FORM GSTR-9 are auto-populated only for those FORM GSTR-I which were furnished by the corresponding suppliers by the due date. Thus, ITC on supplies made during the financial year 2017-18, if reported beyond the said date by the corresponding supplier, will not get auto-populated in said Table 8A. It may also be noted that FORM GSTR-2A continues to be auto-populated on the basis of the corresponding FORM GSTR-I furnished by suppliers even after the due date. In such cases there would be a mis-match between the updated FORM GSTR-2A and the auto-populated information in Table 8A. It is important to note that Table 8A of the annual returns is auto populated from FORM GSTR-2A as on 1st May, 2019. 8. Payment of any unpaid tax: Section 73 of the CGST Act provides a unique opportunity of self- correction to all taxpayers i.e. if a taxpayer has not paid, short paid or has erroneously obtained/been granted refund or has wrongly avai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , high speed diesel, aviation turbine fuel, petroleum crude and natural gas and transactions specified in Schedule 111 of the CGST Act. 11. Reverse charge in respect of Financial Year 2017-18 paid during Financial Year 201819: Many taxpayers have requested for clarification on the appropriate column or table in which tax which was to be paid on reverse charge basis for the FY 2017-18 but was paid during FY 2018-19. It may be noted that since the payment was made during FY 2018-19, the input tax credit on such payment of tax would have been availed in FY 2018-19 only. Therefore, such details will not be declared in the annual return for the FY 2017-18 and will be declared in the annual return for FY 2018-19. If there are any variations in the calculation of turnover on account of this adjustment, the same may be reported with reasons in the reconciliation statement (FORM GSTR-9C). 12. Role of chartered accountant or a cost accountant in certifying reconciliation statement: There are apprehensions that the chartered accountant or cost accountant may go beyond the books of account in their recommendations under FORM GSTR-9C. The GST Act is clear in this reg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... credit declared in the annual return. It may be noted that only those expenses are to be reconciled where input tax credit has been availed. Further, the list of expenses given in Table 14 is a representative list of heads under which input tax credit may have been availed. The taxpayer has the option to add any head of expenses. 17. Filing GSTR 9: While filing Form GSTR 9 'Proceed to File' button will be enabled only if 'Compute Liability' is clicked. This button is meant for computation of late fees only. Please note Form GSTR 9 once filed cannot be revised. 18. Issues in filing the Form GSTR 9C: a. Turnover for filing Form GSTR- 9C: Form GSTR-9C is to be filed by all those taxpayers whose aggregate turnover has exceeded ₹ 2 crore in a financial year. Turnover of complete year i.e. from 1st April, 2017 to 3 1 st March, 2018 has to be taken into account for calculating the turnover. For example, if a taxpayer has a turnover of ₹ 2.1 Cr for the period 1st April, 2017 to 31st March, 2018 and a turnover of ₹ 1.9 Cr for the period 1st July, 2017 to 31st March, 2018, then the taxpayer is required to file form G ..... X X X X Extracts X X X X X X X X Extracts X X X X
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