Relaxations given under Form GSTR 9 and GSTR 9C by CBIC

On 18th Dec, 2019 GST Council in its 38th meeting extended the last date to file Form GSTR-9 (Annual Return) and Form GSTR-9C (Reconciliation Statement) for Financial Year 2017-18 to 31st January 2019, whereas earlier in its Press Release dated 14.11.2019, for Financial Year 2017-18 it was extended to 31st December 2019 and for Financial Year 2018-19 to 31st March 2020. In Nutshell for FY 2017-18 and FY 2018-19 now due dates are 31st January 2020 and 31st March 2020 respectively.

GSTR 9 & GSTR 9C Relaxations

But before filling these Forms, Registered Person must know about the various relaxations or clarifications that Central Board of Indirect Taxes and Customs (CBIC) have given vide Press Release dated 3rd July 2019 and 14th November 2019, which are as follows: 

  • To not to provide split of input tax credit availed on inputs, input services and capital goods, which means now there is no need to give breakup of total ITC in four parts as IGST, CGST, SGST/UTGST and Cess in Table 6 of GSTR 9. 
  • To not to provide HSN level information of outputs or inputs, etc. in Table 17 and 18 respectively of GSTR 9 for the financial year 2017-18 and 2018-19. 
  • If tax was short paid then pay along with interest @18% p.a though Form DRC-03, but if paid in excess then claim the refund though RFD-01A. 
  • Figures in Table 8A of FORM GSTR-9 are auto-populated only for those FORM GSTR-1 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-1 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. The input tax credit which is declared / computed in Table 8D is basically credit that was available to a taxpayer in his FORM GSTR-2A but was not availed by him between July 2017 to March 2019. There is no question of lapsing of any such credit, since this credit never entered the electronic credit ledger of any taxpayer. Therefore, taxpayers need not be concerned about the values reflected in this table. 
  • Just like above clarification, taxpayers need not be concerned about the values reflected in Table 8J of GSTR 9, which shows ITC available but not availed on import of goods. 
  • Table 16A in which information about Supplies received from Composite taxpayers need to given now made optional. 
  • In Table 5F information about outward Non-GST Supply need to be given, now clarified that it also includes supplies which are not covered under the definition of Supply as per CGST Act, 2017. 
  • 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). 
  • Aggregate turnover i.e. the turnover of all the registrations having the same Permanent Account Number is to be used for determining the requirement of filing of reconciliation statement. Therefore, if there are two registrations in two different States on the same PAN, say State A (with turnover of Rs. 1.8 Crore) and State B (with turnover of Rs. 40 lacs) they are both required to file reconciliation statements individually for their registrations since their aggregate turnover is greater than Rs. 2 Crore. The aggregate turnover for this purpose shall be reckoned for the period July, 2017 to March, 2018. 
  • For adjustment in turnover in lieu of debit notes issued during FY 2018-19 although provision for the same was made in the books of accounts for FY 2017-18. In such cases, they may adjust the same in Table 5O of the reconciliation statement in FORM GSTR-9C. If the credit or debit note for any supply was issued and declared in returns of FY 2018- 19 and the provision for the same has been made in the books of accounts for FY 2017- 18, the same shall be declared in Pt. V of the GSTR 9. 
  • Now in Table 14 of GSTR 9C only those expenses are to be reconciled where input tax credit has been availed, the list of expenses given in Table 14 is a representative list of heads. The taxpayer has the option to add any head of expenses. 

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