9A or 9C – Which one to go for GST Annual Summary?

Since the day yearly return recording has been reported in GST hall, the taxpayers are amazed on the appropriateness of the structure type to them. Would it be a good idea for them to document GSTR 9 or GSTR 9 C or both? What’s more, who is to document what?

This blog illuminates the base rationale behind the two structures and encourages you choose which one is for you.

To begin with, yearly return is an announcement of return which is required to be recorded every year by each enrolled individual (aside from few indicated classifications of people) under GST giving condensed subtleness of outward supply and expenses paid subsequently, input charge credits asserted, charges paid and discount guaranteed in the budgetary year in regard of which such month to month/quarterly returns are documented. This yearly return must be documented with the GSTN utilizing structure GSTR 9.

Presently the GSTR 9 in itself is sorted in different structure types dependent on taxpayers entities.

Sr. No. Annual Return Applicability to Taxpayers
1 GSTR 9 All taxpayers except mentioned below in note 1
2 GSTR 9A Taxpayer those applies for composition scheme
3 GSTR 9B Tax collector who files GSTR 8. Read Note 2 mentioned
4 GSTR 9C Taxpayer whose aggregate turnover exceeds 2 cr. & need to audit his

accounts under GST

Note 1 – Following citizens don’t have to document GSTR 9

  • Easygoing Taxable Person
  • Non-Resident Taxable Person
  • Information Service Distributor
  • Arrangement Dealers
  • People subject to TCS or TDS arrangement

Note 2 – GSTR 9B isn’t relevant for Financial year 2017-2018 in light of the fact that GSTR 8 got appropriate from first Oct 2018.

As 9A is a totally extraordinary class to be utilized by citizens in composite plan and 9B not material this year, how about we have a short correlation of GSTR 9 and GSTR 9C, their organizations, pertinence and variety in structure types.

While GSTR 9 is a yearly return structure recording, GSTR 9C is basically a compromise proclamation to be set up by citizens whose total turnover surpasses Rs. 2 crore and have experienced GST review. Such organizations need to document their CA ensured inspected fiscal summaries alongside GSTR 9C. In this way, in a perfect world, GSTR 9C is reliant on arrangement of your GSTR 9 return.

Extra point to note here is that there are no amendment arrangements for the yearly return yet. Thus, the arrival ought to be set up with complete exactness. IRISGST, a powerful GST recording stage is presently outfitted with GSTR 9 documenting utility. With IRISGST you can without much of a stretch mass bring auto-drafted subtleties from GSTN servers, analyze auto-drafted subtleties utilizing GSTR 1 and 3B and your records, audit table-wise GSTR 9 information and get comprehensive reports dependent on GST returns and compromise results to set up the information for extra segments of GSTR 9.

Give us now a chance to see some essential distinction between the two forms:

 

Key Points GSTR-9 Annual Return GSTR-9C Reconciliation Statement
Nature It is combination of all details provided in GST returns i.e. GSTR 1 and GSTR 3B made during financial year 2017-2018. It is reconciliation between annual GSTR 9

return filed and audited annual financial

statements

Applicable to As per Legal provision of Section 44(1) of CGST Act, every registered person is required to file GSTR-9. Hence, irrespective of the Turnover, every registered person under GST is required to file GSTR-9. Every registered person, whose aggregate

turnover during a financial year exceeds the

prescribed limit of Rs. 2 Crore, shall get his

accounts audited by a chartered accountant

or a cost accountant and need to file GSTR 9C.

Not applicable to
  • Casual Taxable Person
  • Non-Resident Taxable Person
  • Input Service Distributor
  • Input Service Distributor
  • Composition Dealers
  • Those who are not applicable to file

GSTR-9

  • And also a registered person whose

aggregate turnover in an FY is less

than INR 2 Cr.

Due date for filing
  • 31st December of the subsequent financial year
    E.g. 31st December 2018 for FY 2017-18
  • This due date extended till 30th June 2019 (Order No.03/2018-Central tax)
  • 31st December of the subsequent

financial year

  • E.g. 31st December 2018 with or after

filing GSTR-9 for FY 2017-18

  • This due date extended till 30th June

2019 (Order No.03/2018-Central tax)

Late fees &
  • As per section 47(2) of CGST Act, Late fee for belated filing of GSTR-9 is Rs.100 per day
In a situation where a registered person files

only GSTR 9, but fails to file GSTR 9C,

the filing of GSTR 9C is not considered to

penalty subject to maximum of 0.25% of turnover in a state/UT. Similar provision is there in SGST Act also.

  • Hence, in total there will be late fee of Rs.200 per day subject to 0.50% of turnover in a state on late filing of GSTR-9.
have been defaulted. However, For GSTR 9C

there may be consequences of default in

complying with the provisions of Section 44(2).

Additional Tax liability Additional liability for the FY 2017-18 not declared in FORM GSTR-1 and FORM GSTR-3B may be declared in this return. (As per Notification 74/2018 dt 31/12/2018 ) In GSTR 9C, GST auditor need to mention

additional tax liability arise and it’s reasons of

arise.

Payment of additional Tax liability
  • Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ?Annual Return? in the drop down provided in FORM DRC-03.
  • It may be noted that such liability can be paid through electronic cash ledger only (As per notification 74/2018 dt 31-12-2018)
  • Towards the end of the return,

taxpayers shall be given an option to

pay any additional liability declared in

this form, through FORM DRC-03.

Taxpayers shall select ?reconciliation

statement in the drop down provided in

FORM DRC-03.

  • It may be noted that such liability can be

paid through electronic cash ledger

only

(As per notification 74/2018 dt 31-12-2018)

Availed ITC Taxpayers cannot claim input tax credit unclaimed during FY 2017-18 through this return. ITC cannot be availed through GSTR 9C
Details need to provide in Return  

  • Details of the outward supplies, inward supplies on which tax is payable, ITC and tax paid, late fees as per the GST returns filed between July 2017 and March 2018
  • Along with its amendments made between April 2018 and September 2018.
  • Declaration of demands/ refunds, supplies from composition dealers, Job works, goods sent on an approval basis
  • HSN wise summary of outward Supplies
  • HSN summary for inward supplies. Here for inward supplies need to consider only which in value independently account for 10% or more of total value of inward supplies (As per notification no 74/2018 dt 31/12/2018)
  • • Late fees payable is required.
 

  • Part-A -Reporting of reconciliation needed

between turnover, tax paid and ITC.

  • Report on Auditor’s recommendation of any

additional tax liability.

  • Part -B -Certificate by GST Auditor/ CA/

CMA

Return Mandatory  

  • It is mandatory to file all your FORM GSTR-1 and FORM GSTR-3B for the FY 2017- 18 before filing this GSTR 9 return.
  • The details for the period from July 2017 to March 2018 are needed to be provided in this return.
GSTR 9 is mandatory to file before filing of GSTR 9C
Annexures No annexures to be attached Annexure of Audited financial statement is required

 

Additionally as of late 31st GST board Meeting was hung on 22 December 2018. To know the features of gathering contact us.

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Certicom Consulting [ Kedia Arpana & Co ] is a group of Chartered Accountants in the business of Small Business Setup & Statutory Compliance including for Professionals for the past 15 years. We have been an established and popular company with an excellent track record for the best customer satisfaction.

Certicom Consulting

Certicom Consulting [ Kedia Arpana & Co ] is a group of Chartered Accountants in the business of Small Business Setup & Statutory Compliance including for Professionals for the past 15 years. We have been an established and popular company with an excellent track record for the best customer satisfaction.