Issues Reported in Filing Form GSTR 9/9C by tax payers: Process to Follow

For filing of Form GSTR 9/9C, by a normal taxpayer for financial year 2017-18, which is required to be filed by them on GST Portal latest by 30th June, 2019.  Taxpayers have mentioned few issues in submitting their Form GSTR 9/9C, details below:

(A)   Relating to Annual Return Form GSTR 9:

  1. Auto-population of ITC figures in Table 8A of Form GSTR-9 based on Form GSTR-2A: Some taxpayers have mentioned that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the numbers as appearing in their Form GSTR-2A. Following reasons may possible:
  1. Data in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-1 of the supplier taxpayer. But data in table 8A of Form GSTR-9 are auto-populated only on the basis of filed Form GSTR-1 by the supplier taxpayer. In case, Form GSTR -1 is not submitted by your supplier, then credit related to those invoices will not show in table 8A of your Form GSTR-9.


  1. Data in table 8A of Form GSTR 9 are auto populated only for those Form GSTR-1, which are submitted by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Hence, 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 but it will be available in Form GSTR-2A.
  1. In table 8A of Form GSTR-9, only recent values have been auto-populated based on filed Form GSTR-1, taking into account all the amendments made, if any. Suppose an invoice with taxable value of Rs 100/- with tax of Rs. 18/- was filed in Form GSTR-1 in the month of January, 2018 and same was amended to Rs 90 as taxable value in the month of March, 2018, then
  2. the Form GSTR-2A of January, 2018 will show ITC of Rs. 18
  3. the Form GSTR-2A of March, 2018 will show ITC of Rs 16.20 &

iii.          the table 8A of Form GSTR-9 will contain ITC of Rs 16.20.

  1. In table 8A of Form GSTR-9, ITC related to all such invoices have been removed in which place of supply lies in supplier’s taxpayers State, instead of State of the receiver taxpayer. These numbers will be shown in Form GSTR-2A of the recipient. For example if a taxpayer of State A visits State B and stays in a hotel in State B, the tax paid by the person to the hotel in State B will appear in his Form GSTR-2A, but the same will not be shown in table 8A of Form GSTR-9.
  1. The data in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.
  1. Proceed to File button not enabled: While filing Form GSTR 9 ‘Proceed to File’ button will be enabled only if ‘Compute Liability’ is clicked. This button is there for computation of late fees only. ‘Preview Draft GSTR 9 PDF’ button is clicked to view the submitted information. Thereafter on checking the declaration box and selecting the authorized signatory details, user has to click on ‘File’ button to file the return. Please note Form GSTR 9 once filed cannot be revised.

(B)   Relating to Form GSTR 9C, Reconciliation statement :

  1. Turnover for filing Form GSTR- 9C: Form GSTR-9C is to be filed by all those taxpayers whose aggregate turnover has exceeded Rs 2 crore in a financial year. Turnover of complete year i.e. from 1st April, 2017 to 31st March, 2018 has to be taken into account for calculating the turnover. For example, if a taxpayer has a turnover of Rs. 2.1 Cr for the period 1st April, 2017 to 31st March, 2018 and a turnover of Rs. 1.9 Cr for the period 1st July, 2017 to 31st March, 2018, then the taxpayer has to file form GSTR- 9C.
  2. User getting error message while using Excel version : You are also advised to use Microsoft excel version higher than 2007 while preparing for Form GSTR 9C.
  3. Providing Membership Number by Auditor: While filing Part B of Form GSTR-9C, Auditors are advised to give their membership number without prefixing ‘0’ in their membership number. If membership number is ‘016’, then auditor should enter ’16’ on the aforesaid part in the membership number field & not ‘016’.

All the taxpayers are requested to file their FORM GSTR-9 & 9C sooner possible to avoid last minute rush and to avoid payment of late fee.

For any concerns or further info, please contact Certicom.