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Changes in GST Annual Return Form GSTR 9

Annual Return Form GSTR 9 filing under GST has seen lot of issues recently especially regarding finalisation of the format itself! With over 6 parts and 19 sections, it is not an easy feat to fill each and every section when the data required for the same was not maintained from the inception.

With only less than 25% of the taxpayers being able to file the annual returns as on date, the GST Council, as a relief in its 38th meeting held on 18 December 2019 recommended extension of due date for GST Annual return to 31st January 2020 for Financial year 2017-2018 which was earlier extended multiple times, recent extension being to 31st December 2019 vide order 08/2019 dated 14th November 2019.

Also the Council has taken necessary steps to simplify the Annual returns by giving option to the tax payer for filling data for some of the sections. The proposed simplifications, section-wise, which are expected to come soon in the portal, are briefly discussed here. We suggest you keep ready the format of GSTR 9 for better understanding while going through this article.

a) Part II Section 4: Details of Advances, inward and outward supplies made during the financial year on which tax is payable

The figures in this section are auto populated from the monthly returns filed from July 2017 to March 2018. But these are editable. The simplification brought in here is that the turnover figures can be entered net of credit notes/debit notes instead of showing them separately under Clause I and J of Section. Also there is the option to ignore disclosure of amendments to supplies as required under Clause K and L and instead merge the same in Clause B to E of the Section.

b) Part II Section 5: Details of Outward Supplies made during the financial year on which tax is not payable

Option given under Section 4 is also given under Section 5 for Credit notes and Debit notes. Also there is the option to ignore disclosure of amendments to supplies as required under Clause J and K and instead merge the same in Clause A to F of the Section.

Also if bifurcation is not possible for Clause D, E and F for Exempted, Nil-rated and Non GST Supply respectively, the same can be directly disclosed under Clause D Exempted Supply.

c) Part III Section 6: Details of ITC Availed during the financial year

Bifurcation of the Input GST Credit for the period July 2017- March 18 to “Inputs-Capital Goods-Input Services” was one of the difficulties faced by taxpayers as none of the monthly forms (GSTR 1 or GSTR 3B) had this requirement. To remove this struggle, the taxpayers have been given the option to enter the whole of credit availed on inward supplies (other than imports and RCM) under “inputs” for clause B and C of Section 6.

Also, if bifurcation of the RCM paid is not possible between registered and unregistered dealers as required under clause C and D of Section, the same can be shown directly under Clause D instead. Relaxation is given for Import Credit bifurcation also and same need not be separate disclosed as Inputs and Capital Goods.

d) Part III Section 7: Details of ITC reversed and ineligible ITC for the Financial Year

Consolidated reporting of the reversals of ITC has been allowed under Clause H of Section 7 instead of separate disclosure under Clause A to E.

e) Part III Section 8: Other ITC related Information

Option to give the details required under this section as a separate attachment along with Form GSTR 9C without CA Certification.

f) Part V Section 12 and 13: Reversal of ITC and ITC Availed in FY 2018-19 relating to period July 2017 to March 2018

It is optional to fill the ITC claimed and ITC reversed subsequently in FY 2018-19 pertaining to FY 2017-18.

g) Part VI is fully optional

Taxpayer at his option may fill particulars of Demand and Refunds under Section 15, Supplies received from Composite, Deemed Supply and Goods sent on approval basis under section 16 and also the HSN summary Outward and Inward Supplies under Section 17 and 18 respectively.

Annual return form GSTR 9 is to be filled by the tax payer but it will be ideal to get it reviewed by a GST practitioner or a Chartered Accountant to ensure the disclosures are correct so as to ensure proper filing of Reconciliation Statement GSTR 9C. For Annual return filing services in Bangalore or any further clarifications required on above, feel free to contact us at contact@msassociates.pro or call us on 080-41633750 or 9880542668.