Key Changes in GST Annual Return for FY 2023-24: A Guide to Filing Without Errors

GST Annual Return

Key Changes in GST Annual Return for FY 2023-24: A Guide to Filing Without Errors

GST Annual Return

The GST Annual Return filing season is here, and it’s crucial for registered taxpayers to ensure accuracy to avoid potential mismatches, particularly with Input Tax Credit (ITC). The GST annual return for FY 2023-24 must be filed on or before December 31, 2024. However, there are several changes in the process that taxpayers need to understand to ensure smooth compliance.

Who Needs to File the GST Annual Return?

GST-registered taxpayers, except those in specific categories, must file the annual return in Form GSTR-9. Exceptions include:

  • Input Service Distributors
  • Persons paying tax under TDS/TCS
  • Casual taxable persons
  • Non-resident taxable persons

For taxpayers with a turnover of up to ₹2 crores, filing the GST annual return is not mandatory for FY 2023-24.

For businesses with turnovers exceeding ₹2 crores, the following rules apply:

  • Turnover ₹2-5 crores: Filing GSTR-9C (reconciliation statement) is optional.
  • Turnover above ₹5 crores: Filing GSTR-9C is mandatory.

Changes in GSTR-9 for FY 2023-24

The most notable update in the GSTR-9 relates to the sourcing of ITC details in Table 8A. Previously, ITC details in Table 8A were auto-populated using data from GSTR-2A, a statement of inward supplies. Starting from FY 2023-24, Table 8A will now derive its data from GSTR-2B.

What is GSTR-2B?

GSTR-2B is an auto-drafted statement reflecting ITC based on invoices uploaded by suppliers in their respective GSTR-1 returns. This change is expected to:

  • Simplify the reconciliation process.
  • Minimize manual efforts by taxpayers.

Implications of the Change

Switching from GSTR-2A to GSTR-2B emphasizes the need for taxpayers to ensure their suppliers upload invoices promptly. Any delays or errors in supplier filings can lead to discrepancies, requiring additional effort to reconcile ITC claims.

  • Table 8A: Now populated based on GSTR-2B, reflecting eligible ITC.
  • Table 8D: Highlights discrepancies between ITC claimed and ITC auto-populated for reconciliation purposes.

Additionally, Table 6 of GSTR-9 will report ITC based on actual utilization for the financial year as per returns filed.

Key Steps for Accurate Filing

To avoid mismatches and ensure compliance:

  1. File Monthly/Quarterly Returns First: Ensure all monthly or quarterly returns (under the QRMP scheme) are filed before starting the annual return. GSTR-9 data is auto-populated from these returns.
  2. Monitor GSTR-2B Closely: Regularly check GSTR-2B to ensure all eligible ITC is captured.
  3. Reconcile ITC Claims: Compare ITC in GSTR-3B with GSTR-2B data to avoid mismatches.

Read More: GST Amnesty 2024: Waiver of Interest and Penalties Under Section 128A

The new approach of using GSTR-2B for auto-populating ITC in GSTR-9 aims to improve accuracy and reduce errors. However, it places greater responsibility on taxpayers to maintain data accuracy and coordinate with suppliers. Proactive monitoring and timely action will help ensure smooth filing for FY 2023-24.

For further assistance with GST compliance, consider reaching out to experts to navigate the complexities of annual return filing and reconciliation.

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Key Relaxations and Optional Tables in GSTR-9 and GSTR-9C for FY 2023-24

Key Relaxations and Optional Tables in GSTR-9 and GSTR-9C for FY 2023-24

GSTR-9

With the approaching deadline for filing GSTR-9 and GSTR-9C for FY 2023-24, the Central Board of Indirect Taxes and Customs (CBIC) has implemented several relaxations to ease the compliance process. These updates, outlined in the CGST (Amendment) Rules, 2024, aim to reduce the reporting burden on taxpayers while making the filing process more efficient and straightforward.

Below is a comprehensive summary of the key relaxations and optional reporting tables introduced in GSTR-9 and GSTR-9C for FY 2023-24:

1. Simplifications in GSTR-9

A. Outward Supplies and Adjustments (Table 5)

  • Exempted and Nil-Rated Supplies (5D & 5E):
    Taxpayers can report the consolidated value of both exempted supplies and nil-rated supplies in Table 5D.
  • Credit and Debit Notes (5H & 5I):
    The value of credit and debit notes can be reported on a net basis against the original supplies (Tables 5A-5F).
  • Amendments to Supplies (5J & 5K):
    Similarly, amendments to supplies can also be reported on a net basis for Tables 5A-5F.
GSTR-9

B. Input Tax Credit (ITC) Details (Table 6)

  • Inward Supplies (6B, 6C & 6D):
    Taxpayers now have the option to report ITC on inputs and input services in a single consolidated column under “Inputs.”
  • Imports (6E):
    ITC on imported goods and services can also be consolidated under the “Inputs” column.

C. Reversal of ITC (Table 7)

  • Reversal of ITC (7A to 7E):
    Instead of filling multiple sub-tables, taxpayers can report all reversals in a consolidated manner under Table 7H, labeled as “Other Reversals.”

D. Tax Paid (Table 9)

Taxpayers are required to provide an annual summary of GST payments, as reflected in their GSTR-3B returns, ensuring alignment between returns and payments.

E. Optional Reporting for Certain Tables

  • Sales Adjustments for Future Periods (Tables 10 & 11):
    Reporting of sales adjustments made in FY 2024-25 for transactions of FY 2023-24 is optional.
  • ITC Adjustments (Tables 12 & 13):
    Tables related to ITC reversals and availment for transactions spanning FY 2023-24 and FY 2024-25 are optional.
  • Demand and Refund (Table 15):
    Details of demands raised and refunds claimed during the year are not mandatory to report.
  • Composition and Job Work Supplies (Table 16):
    Reporting supplies from composition taxpayers, deemed supplies by job workers, and goods sent on approval can be skipped.
  • HSN Codes for Supplies (Tables 17 & 18):
    Simplified HSN/SAC reporting:
    • For businesses with a turnover > ₹5 Crores, report 6-digit HSN codes.
    • Others can report 4-digit HSN codes for B2B transactions.

2. Relaxations in GSTR-9C

A. Optional Table

  • Table 14 (Differential Tax):
    Reporting of differential tax paid on adjustments made in Tables 10 and 11 is optional.

B. Mandatory Tables

All other tables in GSTR-9C remain mandatory for taxpayers.

3. Simplified Reporting for Small Businesses

For businesses with a turnover of less than ₹5 Crores, simplified compliance includes:

  • Optional HSN reporting at the 4-digit level.
  • Consolidation of multiple ITC categories and reversals, reducing the complexity of reporting.

Read More: GST Amnesty 2024: Waiver of Interest and Penalties Under Section 128A

These relaxations for FY 2023-24 aim to provide greater flexibility to taxpayers, reducing compliance time and effort. By allowing consolidated reporting and optional tables, the CBIC continues to streamline GST compliance processes.

Taxpayers are encouraged to review these changes carefully and consult professionals for efficient filing to avoid penalties or errors.

Stay updated with Certicom Consulting for expert GST advisory and compliance assistance.

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GST Amnesty 2024: Waiver of Interest and Penalties Under Section 128A

  • 21 Nov 2024
  • GST
  • Comments Off on GST Amnesty 2024: Waiver of Interest and Penalties Under Section 128A

GST Amnesty 2024: Waiver of Interest and Penalties Under Section 128A

Section 128A

The Goods and Services Tax (GST) Amnesty Scheme 2024, governed by Section 128A of the CGST Act, 2017, and Rule 164, offers taxpayers an opportunity to seek relief from interest and penalties for specific tax defaults. This initiative provides a structured process for closing proceedings related to tax obligations from July 1, 2017, to March 31, 2020. Here’s a comprehensive guide to understanding its provisions, eligibility criteria, application process, and benefits.

What is the GST Amnesty Scheme 2024?

The scheme, introduced via Section 146 of the Finance (No. 2) Act, 2024, and notified under Notification No. 20/2024 – Central Tax (October 8, 2024), facilitates the waiver of interest and penalties for eligible taxpayers. It aims to support those who inadvertently defaulted on tax obligations during the specified period, helping them resolve issues and comply without excessive financial burden.

Key Provisions of Section 128A and Rule 164

1. Eligibility for Waiver

Taxpayers eligible for a waiver under Section 128A include those who have:

  • Notices or Statements (Sec 128A(1)(a)): Received a notice or statement under Section 73(1) of the CGST Act for the specified period.
  • Orders (Sec 128A(1)(b) & (c)): Received:
    • Orders from a Proper Officer under Section 73(9),
    • Orders from an Appellate Authority under Section 107(11), or
    • Orders from a Revisional Authority under Section 108, for the specified period.

2. Application Process

Eligible taxpayers must apply using designated forms:

  • Form GST SPL-01: For notices or statements under Sec 128A(1)(a), applications must be submitted within three months of the notified payment date (March 31, 2025), making the deadline June 30, 2025.
  • Form GST SPL-02: For orders under Sec 128A(1)(b) or (c), applications must be filed within three months of the notified payment date, with an exception allowing six months in certain cases.

3. Payment Requirements

  • Full Tax Payment: Applicants must settle all tax dues, excluding amounts related to Input Tax Credit (ITC) disallowance under Sections 16(5) and 16(6).
  • Payment Mode: Payments must be made through Form DRC-03, or Form DRC-03A if already filed before the order was passed.

4. Time Limits

  • General Time Limit: Applications are to be filed within three months of the notified date under Sec 128A(1)(a).
  • Exception: For cases falling under the first proviso to Sec 128A(1), applications may be filed within six months from the order communication date.

5. Documentation

Applicants must submit evidence of withdrawing appeals or petitions filed with appellate authorities, tribunals, or courts.

Processing and Approval

1. Application Review

  • Notice (GST SPL-03): If ineligible, a notice may be issued within three months of receiving the application.
  • Applicant’s Reply (GST SPL-04): Applicants must respond to notices within one month.

2. Orders

  • Approval (GST SPL-05): If eligible, the waiver is granted.
  • Rejection (GST SPL-07): If rejected, the applicant may appeal or restore the original appeal.

3. Deemed Approval

If no order is issued within:

  • Three months of application submission (if no notice is served), or
  • Four months from notice issuance (if no reply is provided),
    the waiver application is considered approved.

Appeals and Restorations

If a waiver is rejected:

  • Restoration of Appeals: Withdrawn appeals are reinstated if no further appeal is filed.
  • Filing an Appeal: Rejected orders can be contested. Upon approval, the waiver is granted via Form GST SPL-06.

Voiding of Waiver

The waiver stands void if:

  1. Additional tax dues are not paid.
  2. Interest or penalties are not cleared within three months of the order.

Read More: A Guide to Income Tax Scrutiny Assessments Under Section 143(3)

The GST Amnesty Scheme 2024 offers a golden opportunity for taxpayers to rectify past defaults and comply without the heavy burden of penalties and interest. By simplifying procedures and providing structured timelines, the scheme facilitates compliance while promoting goodwill among taxpayers.

Taxpayers are encouraged to act promptly, adhere to deadlines, and consult professionals to ensure their applications are accurate and complete.

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