GST

ORGANISED BY
The Student Committee of the Chamber of Tax
Consultants
CA KARAN LODAYA
3 DAY WORKSHOP ON “GST, ROC AND INCOME TAX ANNUAL RETURNS -
RECENT CHANGES AND DO’S & DON’TS – STUDENTS' PERSPECTIVE”

Annual Return & Audit
AN INVESTMENT IN KNOWLEDGE PAYS THE BEST
RETURN……

Statutory Provisions – SECTION 37(1)
4
Furnishing details of outward supplies.
Every registered person, other than
• Input Service Distributor………………………. (GSTR 6)
• Non-resident Taxable Person…………………. (GSTR 5)
• Person paying tax u/s 10 ………………………..(GSTR 4)
• Person paying tax u/s. 51 or 52 (TDS & TCS provisions)……… (GSTR 7, 8)
shall furnish, electronically, in such form and manner as may be prescribed, the details of
outward supplies of goods or services or both effected during a tax period on or before
the tenth day of the month succeeding the said tax period and such details shall be
communicated to the recipient of the said supplies within such time and in such manner
as may be prescribed:

5
Explanation.––For the purposes of this Chapter, the expression “details of outward
supplies” shall include details of invoices, debit notes, credit notes and revised invoices
issued in relation to outward supplies made during any tax period.
• Rule 59 – Details of Outward supplies are required to be furnish in FORM GSTR 1
• It is mandatory to file GSTR 1 form.
• There are in all 13 tiles/table in FORM GSTR 1.
Provided further that the Commissioner may, for reasons to be recorded in writing, by
notification, extend the time limit for furnishing such details for such class of taxable
persons as may be specified therein:

DUE DATE – GSTR 1
6
Notification 83/2020-CT dated 10th November, 2020 extends the time limit for furnishing
the details of outward supplies in FORM GSTR-1 for each of the tax periods, till the
eleventh day of the month succeeding such tax period:
Notification 84/2020-CT dated 10th Nov, 2020…………..A person with turnover up to Rs. 5
crore in the preceding year and who have opted to furnish a return for every quarter,
under rule 61A (1) can file return on quarterly basis (QRMP) .
Due date for quarterly return shall be thirteen day of the month succeeding such tax
period.

8
Furnishing details of return.
Every registered person, other than an Input Service Distributor or a non-resident taxable
person or a person paying tax under the provisions of section 10 or section 51 or section
52 shall, for every calendar month or part thereof, furnish, a return, electronically, of
inward and outward supplies of goods or services or both, input tax credit availed, tax
payable, tax paid and such other particulars, in such form and manner, and within such
time, as may be prescribed
Rule 61 - Every registered person other than
• a person referred to in section 14 of IGST Act or
• an Input Service Distributor or a
• non-resident taxable person or
• a person paying tax under section 10 or section 51/52
furnish a return in FORM GSTR-3B

DUE DATE – GSTR 3B
9
Every registered person is required to file GSTR 3B on or before 20th of the month
succeeding such month
However, person who have eligible & opted for QRMP scheme (would be required to
furnish FORM GSTR-3B, for each quarter, on or before 22nd or 24th day of the month
succeeding such quarter
From January 1, 2022, taxpayers will not be permitted to file Form GSTR-1 if they have not
filed Form GSTR-3B in the preceding month.

Statutory Provisions
11
Section 44 of CGST Act, 2017:
Every registered person, other than
• Input Service Distributor
• Person paying tax u/s. 51 or 52 (TDS & TCS provisions)
• Casual Taxable Person
• Non-resident Taxable Person
shall furnish an annual return which may include a self-certified reconciliation statement,
reconciling the value of supplies declared in the return furnished for the financial year,
with the audited annual financial statement for every financial year electronically,
within such time and in such form and in such manner as may be prescribed:
Rule 80(1)- Annual Return to be furnished in Form GSTR 9
Rule 80(1) Proviso- Annual Return in Form GSTR 9A for composition dealers

Statutory Provision & Due-date
12
FORM GSTR-9 on or before the thirty-first day of December following the end of such
financial year
If aggregate turnover during a financial year exceeds Rs. 5 core, than registered
person shall also furnish a self-certified reconciliation statement in FORM GSTR-
9C along with the annual return on or before the thirty-first day of December
following the end of such financial year, electronically through the common portal
either directly or through a Facilitation Centre notified by the Commissioner.
Notification 31/2021-CT dated 30th July, 2021 exempts the registered person whose
aggregate turnover in the financial year 2020-21 is upto two crore rupees, from filing
annual return for the said financial year.

REGISTERED PERSON – HINDUSTAN UNILEVER LTD
Gujarat
Located
Maharashtra Andhra Pradesh Rajasthan
• Selling only
Exempted goods
• Turnover – 5 Cr
• Selling only
Taxable Goods
• Turnover – 1 Cr
• Export sales
• Turnover – 3 cr
• Making Export as well
as local sales
• Turnover – NIL
• In which all state will HUL require to file GSTR 9C?
GSTR 9C applicability

 Aggregate Turnover- Section 2(6)
“Aggregate Turnover” means the aggregate value of all taxable supplies
(excluding the value of inward supplies on which tax is payable by a person
on reverse charge basis), exempt supplies, exports of goods or services or
both and inter-State supplies of persons having the same Permanent Account
Number, to be computed on all India basis but excludes central tax, State tax,
Union territory tax, Integrated tax and cess
P r o v i s i o n s

Tu r n o v e r
Aggregate Turnover
TAXABLE
SUPPLIES
INTER STATE
SUPPLIES (Branch
Transfer)
EXEMPTED
SUPPLIES
EXPORT
TAXES
(CG,SG,IG)
Aggregate Turnover does not include value of inward supplies on which tax is payable under RCM

Mr. A Sells a piece of Land for Rs. 10 crore
during F.Y 2020-21
Mr. A (Registered Person) has received Rent of Rs. 80 Lakh during F.Y 2020-21 for shop. Therefore
His P&L account shows receipt of Rs. 10.80 crore.
Whether Mr. A would require to file GSTR 9C?
Issue – 2

 Aggregate Turnover- Section 2(6) - “Aggregate Turnover” means the aggregate value of all taxable
supplies (excluding the value of inward supplies on which tax is payable by a person on reverse
charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of
persons having the same Permanent Account Number, to be computed on all India basis but
excludes central tax, State tax, Union territory tax, Integrated tax and cess
 Exempt supplies – Section 2(47) - “Exempt supply” means supply of any goods or services or both
which attracts nil rate of tax or which may be wholly exempt from tax under section 11, or under
section 6 of the Integrated Goods and Services Tax Act, and includes non-taxable supply;
 Non Taxable supply – Section 2(78) - “non-taxable supply” means a supply of goods or services or
both which is not leviable to tax under this Act or under the Integrated Goods and Services Tax
Act…..E.G. Petrol, Diesel etc.
P r o v i s i o n s

Mr. A would not require to get is Accounts audited under GST since Sale of Land is
covered under Schedule III – Items which are neither supply of goods nor supply of
service.
P r o v i s i o n s

CONSEQUENCES OF LATE FILING
19
Section 47(2) of CGST Act, 2017:
Late fees
 Rs. 200/- (CGST + SGST) per day subject to 0.25% of turnover in state wise/UT
Form Number Particular
Form GSTR 9 Annual Return for Normal Tax payer
Form GSTR 9A Annual Return for composite dealer
Form GSTR 9C
Part A Reconciliation

GSTR 9- Overview
20
Part Description
I Basic Details
II Details of outward and inward supplies declared during the financial year
III Details of ITC as declared in returns filed during the financial year
IV Details of tax paid as declared in returns filed during the financial year
V Particulars of the transaction for the previous FY declared in returns of April to September of
current FY or upto date of filing of annual return of previous FY whichever is earlier
VI Other Information
• Pre-work
• It is advisable before initiating the filing of GSTR 9 / 9A to first tally Outward
supplies, advances received and tax paid for inward supplies under RCM
declared in GST-3B, GSTR-1 with Financial Statements
• Input Tax credits with GSTR-2A

Preparatory Work for Annual Return
21
• It is mandatory to file all FORM GSTR 1 & GSTR 3B before filing GSTR 9
• Additional liability Not declared in GSTR 1 & GSTR 3B may be declared in this
return.
• Annual return gives Opportunity of rectify certain errors committed while filing
GSTR 1 & GSTR 3B
• Reconcile Input Tax credits with GSTR-2A
• Taxpayers cannot claim input tax credit through this return. ITC can be claimed
only through FORM GSTR 3B

Part I- Basic Details
22
• The above details will be auto filled once tax payer login-in to GST portal

PART II : DETAILS OF OUTWARD SUPPLIES
• Part II consist of 2 tables Viz. 4 & 5
23
Table Taxability Contents to be filled
4 Tax Payable a. Details of all taxable outward supplies
b. Advance received on which tax payable
c. Inwards supplies on which tax payable under RCM
5 Tax Not Payable a. Zero rated supplies
b. Exempted/NIL Rated/ Non GST supplies
• Details have to be compiled on the basis of GSTR-1 filed in the return

OUTWARD SUPPLIES – TAX PAYABLE
24
Pt. II
Taxable
Value
Central
Tax
StateTax
/UTTax
Integrate
d Tax
Cess
2 3 4 5 6
4
A
B
C
D
E
Suppliesmadeto un-registered
persons(B2C)
Suppliesmadeto registered
persons(B2B)
Zero rated supply(Export)on
paymentoftax(except
suppliesto SEZs)
Supplyto SEZsonpaymentof
tax
Deemed Exports
Details ofadvances, inwardandoutwardsupplies made during the financial
yearonwhichtax is payable
DetailsofOutward and inward suppliesmadeduringthefinancialyear
NatureofSupplies
(Amountin₹ inalltables)
1
B2C supplies Includes:
• Supplies to URD along with amendments
• DN/CN & its amendment to be adjusted here itself
• Table 5A, 5B, 7, 9B, 9A , 9C, 10 of GSTR 1 to be
used for mapping
B2B supplies Includes:
• Supplies to RD
• Table 4A & 4C of GSTR 1 to be used for Mapping
Zero rated supplies (Except supplies to SEZ):
• Export with payment of Tax (Table 6A to be used)

25
Pt.II
Taxable
Value
Central
Tax
StateTax
/UTTax
Integrate
dTax
Cess
2 3 4 5 6
4
A
B
C
D
E
Suppliesmadetoun-registered
Suppliesmadetoregistered
Zeroratedsupply(Export)on
SupplytoSEZsonpaymentof
DeemedExports
Details ofadvances,inwardandoutwardsupplies made duringthe financial
yearonwhichtaxis payable
DetailsofOutwardandinwardsuppliesmadeduringthefinancialyear
NatureofSupplies
(Amountin₹inalltables)
1
SEZ Supplies:
• SEZ supplies with payment of Tax (Table 6B of GSTR
1 to be used)
Deemed Exports: (Notification 48/2017-CT dated 18th
Oct.,2017)
• Supply of goods by a registered person against
Advance Authorization
• Supply of capital goods by a registered person
against Export Promotion Capital Goods
Authorisation
• Supply of goods by a registered person to Export
Oriented Unit
• Supply of gold by a bank or Public Sector
Undertaking specified in the notification No.
50/2017-Customs, against Advance Authorisation.
• Table 6C of GSTR -1 to be used.

26
Tax on Advance supplies :
• Details are to be filed only when advance received but
no Invoice has been issued as on 31st March, 2021
• Table 11A of GSTR1
• Exemption provided to tax on advances on supply of
goods (N.No.40/2017 – dt.13th Oct,17 & N.No.
66/2017-dt. 15th Nov,17)
Inward Supplies on which tax paid under RCM:
• Amount to be shown net of Debit/Credit note
received from supplier
• Table 3.1(d) of GSTR- 3B to be used
F
G
H
Advancesonwhichtaxhas
beenpaidbutinvoicehasnot
beenissued(notcovered
under(A)to(E)above)
Inwardsuppliesonwhichtax
istobepaidonreversecharge
basis
Sub-total(AtoGabove)

27
Credit Notes Section 34(2):
• Credit Notes in respect of B2B, zero rated supplies and
deemed exports
• Goods return, rate difference, deficiency ins supply of
goods/services etc
• Table 9B of GSTR1 to be used
Debit Notes Section 34(4):
• Debit Notes in respect of B2B, zero rated supplies
and deemed exports
• Rate difference
I
J
K
L
M
- - - - -
N
- - - - -
CreditNotesissuedinrespectoftransactions
specifiedin(B)to(E)above(-)
Suppliesandadvancesonwhichtaxistobe
paid(H+M)above
Sub-total(ItoLabove)
Supplies/taxreducedthroughAmendments(-)
Supplies/taxdeclaredthroughAmendments
(+)
DebitNotesissuedinrespectoftransactions
specifiedin(B)to(E)above(+)

28
Supplies declared through amendments (ADD) :
• This clause is now redundant since the data of supply
as per the books of accounts is already been given in
the above columns. Hence, not an effective
amendment.
Supplies declared through amendments (LESS) :
• This clause is now redundant since the data of
supply as per the books of accounts is already
been given in the above columns. Hence, not an
effective amendment.
I
J
K
L
M
- - - - -
N
- - - - -
specifiedin(B)to(E)above(-)
Suppliesandadvancesonwhichtaxistobe
paid(H+M)above
Sub-total(ItoLabove)
Supplies/taxreducedthroughAmendments(-)
Supplies/taxdeclaredthroughAmendments
(+)
specifiedin(B)to(E)above(+)

OUTWARD SUPPLIES – TAX NOT PAYABLE
29
Zero rated supply (without payment of tax) :
• Table 6A of GSTR1 to be used
• GSTR 1 does not provide ready made data w.r.t with
payment of tax & without payment of tax.
Supplies to SEZ (without payment of tax) :
• GSTR 1 does not provide ready made data w.r.t with
payment of tax & without payment of tax.
5
A
B
C
D
E
F
G - - - - -
DetailsofOutwardsuppliesmadeduringthefinancialyearonwhichtaxisnot
payable
Sub-total(AtoFabove)
Non-GSTsupply
Zeroratedsupply(Export)withoutpaymentof
tax
SupplytoSEZswithoutpaymentoftax
Suppliesonwhichtaxistobepaidbythe
recipientonreversechargebasis
Exempted
NilRated
Supplies on which tax is paid by recipient :
• Eg : GTA , Advocate
• GSTR 1 does not provide readymade data w.r.t with
supplies on which tax is paid by supplier or by
recipient.

30
Exempted / NIL RATED / NON-GST SUPPLIES :
• Table 8A , 8B, 8C, 8D of GSTR 1
• Instruction sheet provides value of “NO SUPPLY” shall
include here ????????????????
• Schedule III – Sale of building, Sale of Land,
Actionable claims etc,
• Transactions in securities, petroleum products,
Alcoholic liquor
5
A
B
C
D
E
F
G - - - - -
DetailsofOutwardsuppliesmadeduringthefinancialyearonwhichtaxisnot
payable
Sub-total(AtoFabove)
Non-GSTsupply
Zeroratedsupply(Export)withoutpaymentof
tax
SupplytoSEZswithoutpaymentoftax
Suppliesonwhichtaxistobepaidbythe
recipientonreversechargebasis
Exempted
NilRated

31
Credit Notes (LESS) / DEBIT Notes (ADD) :
• Credit / Debit Notes (RD & URD ) in respect of zero
rates, SEZ supplies, exempted , NON GST etc
Supplies declared through Amendments (ADD) :
H
I
J
K
L - - - - -
M
- - - - -
N
- - - - -
specifiedinAtoFabove(+)
specifiedinAtoFabove(-)
TotalTurnover(includingadvances)(4N+5M-
4Gabove)
Turnoveronwhichtaxisnottobepaid (G+L
above)
Sub-Total(HtoKabove)
SuppliesreducedthroughAmendments(-)
SuppliesdeclaredthroughAmendments(+)
Supplies declared through Amendments (LESS) :

OUTWARD SUPPLIES – SUCCESSFULLY COMPILED !!!!
32

PART-III : Details of ITC availed
33
CHALLENGE :
• No separate bifurcation
available under GSTR-3B
for Inputs, Input Services
& CG…
• This table should not
include details of ITC
which was availed, then
reverse & against
reclaimed on payment. It
is to be separately
mentioned in other
column of Point III (6H)
Pt. III
Type Central
Tax
State
Tax/UT
Tax
Integrate
d Tax
Cess
2 3 4 5 6
6
A
Inputs
Capital
Goods
Input
Services
Inputs
Capital
Goods
Input
Services
Inputs
Capital
Goods
Input
Services
Inputs
Capital
Goods
Details of ITC for the financial year
Description
Details of ITC availed during the financial year
Inward supplies (other than imports and inward
supplies liable to reverse charge but includes
services received from SEZs)
Inward supplies received from unregistered
persons liable to reverse charge (other than B
above) on which tax is paid & ITC availed
Total amount of input tax credit availed through FORM
GSTR-3B (sum total of Table 4A of FORM GSTR-3B)
E
D
C
1
B
Inward supplies received from registered
persons liable to reverse charge (other than B
above) on which tax is paid and ITC availed
Import of goods (including supplies from SEZs)
AUTO
Table 4(A)(5) of
GSTR-3B
Table 4(A)(3) of
GSTR-3B
Table 4(A)(1) of
GSTR-3B

34
• Import of Service (Excluding
Inwards supply from SEZ) : Table
4A(2) of GSTR-3B to be used
• ITC received from ISD - Table 4A
(4) of GSTR 3B
F
G
H
I - - - -
J - - - -
K
L
M
N - - - -
O - - - -
Importofservices (excludinginward supplies fromSEZs)
InputTaxcreditreceived fromISD
AmountofITC reclaimed (other thanBabove) under the
provisions ofthe Act
Sub-total(Bto Habove)
Difference (I - Aabove)
TransitionCreditthroughTRAN-I (includingrevisions if
any)
TransitionCreditthroughTRAN-II
Anyother ITC availed butnotspecified above
Sub-total(K to M above)
TotalITC availed (I + N above)
• Amount of ITC reclaimed :
• ITC received from ISD - Table 4A &
4B of GSTR 3B

35
TRANSITION CREDIT :
• Reporting of transitional credit
through TRAN –I & TRAN-II
• Details to be compiled from
Electronic Credit Ledger
F
G
H
I - - - -
J - - - -
K
L
M
N - - - -
O - - - -
Importofservices (excludinginward supplies fromSEZs)
InputTaxcreditreceived fromISD
AmountofITC reclaimed (other thanBabove) under the
provisions ofthe Act
Sub-total(Bto Habove)
Difference (I - Aabove)
TransitionCreditthroughTRAN-I (includingrevisions if
any)
TransitionCreditthroughTRAN-II
Anyother ITC availed butnotspecified above
Sub-total(K to M above)
TotalITC availed (I + N above)
• ANY OTHER ITC AVAILED :
• Section 18 of CGST Act :
• Eg: ITC of stock held on
conversion of URD to RD, transfer
of business by way of merger, de
merger etc.

PART-III : Details of ITC reversed and ineligible ITC
36
ITC Reversed :
• Table 4(B) of GSTR-3B to be used
• Rule 37 : Non payment of
consideration
• Rule 39 : Distribution of credit to ISD
• Rule 42 / 43 : Reversal of common
input credit of goods, services, CG
proportionate to exempted /
personal use
• Section 17(5) : Blocked credit
7
A
B -
C
D
E
F
G
H
I - - - -
J - - - -
Details ofITCReversedandIneligible ITCforthe financialyear
AsperRule37
TotalITC Reversed(AtoHabove)
NetITC AvailableforUtilization(6O - 7I)
Otherreversals(pl.specify)
AsperRule39
AsperRule42
AsperRule43
Aspersection17(5)
ReversalofTRAN-Icredit
ReversalofTRAN-IIcredit

PART-III : Other ITC related information
37
• Reporting of ITC not availed by
tax payer but reflecting in GSTR-
2A , to be reported in 8E
• Reporting of ITC reflecting in
GSTR-2A but not availed by tax
payer as the same being
ineligible …Eg : Invoice not
available, Goods/ Services not
received etc
8
A
B
- - - -
C
D - - - -
E
F
G
H
- -
I - - - -
J
- - - -
K
- - - -
TotalITC to be lapsed in current financialyear (E + F + J)
ITC available but ineligible (out ofD)
IGST paid on import ofgoods (including supplies from
SEZ)
IGST credit availed on import ofgoods (as per 6(E)
above)
Difference (G-H)
OtherITC related information
ITC available but not availed on import ofgoods (Equalto
I)
ITC as per GSTR-2A (Table 3 & 5 thereof)
ITC as per sumtotalof6(B) and 6(H) above
ITC on inward supplies (other than imports and inward
supplies liable to reverse charge but includes services
received fromSEZs) received during 2017-18 but availed
during Aprilto September, 2018
Difference [A-(B+C)]
ITC available but not availed (out ofD)

PART-III : Other ITC related information
38
• Reporting of ITC not availed by
tax payer but reflecting in GSTR-
2A , to be reported in 8E
• Reporting of ITC reflecting in
GSTR-2A but not availed by tax
payer as the same being
ineligible …Eg : Invoice not
available, Goods/ Services not
received etc
8
A
B
- - - -
C
D - - - -
E
F
G
H
- -
I - - - -
J
- - - -
K
- - - -
TotalITC to be lapsed in current financialyear (E + F + J)
ITC available but ineligible (out ofD)
IGST paid on import ofgoods (including supplies from
SEZ)
IGST credit availed on import ofgoods (as per 6(E)
above)
Difference (G-H)
OtherITC related information
ITC available but not availed on import ofgoods (Equalto
I)
ITC as per GSTR-2A (Table 3 & 5 thereof)
ITC as per sumtotalof6(B) and 6(H) above
ITC on inward supplies (other than imports and inward
supplies liable to reverse charge but includes services
received fromSEZs) received during 2017-18 but availed
during Aprilto September, 2018
Difference [A-(B+C)]
ITC available but not availed (out ofD)

PART –IV, V & VI OF ANNUAL
RETURN

Part IV- Details of tax paid in returns
40
• Table 6.1 of GSTR-3B to be used

PART-V : Transactions of Previous reported in current F.Y. from April to Sept, return
41
• Table 9A, 9B, 9C of GSTR-1 to
be used of Current F.Y. from
April to Sept.
Pt. V
Taxable
Value
Central
Tax
State
Tax/UT
Tax
Integrate
d Tax
Cess
2 3 4 5 6
10
11
12
13
Supplies /taxreduced throughAmendments (-)
(netofcreditnotes)
ReversalofITC availed duringprevious
financialyear
ITC availed for the previous financialyear
Particulars ofthe transactions for the previous FYdeclared inreturns ofAprilto
September ofcurrentFYor upto date offilingofannualreturnofprevious FY
whichever is earlier
Description
1
Supplies /taxdeclared throughAmendments
(+) (netofdebitnotes)
UNDER REPORTING OF SUPPLY
IN P.F.Y. OR AMENDMENT IN
SUPPLY, net of debit notes
OVER REPORTING OF SUPPLY IN
P.F.Y. OR AMENDMENT IN SUPPLY,
net of Credit notes
• Point.12,
• Eg : reversal of ITC on account
of Rule 42/43 derived on
consolidation of ITC reversed at
the end of the year.
• Point. 13,
• ITC on goods/ services received
in PFY, but availed in CFY. Table
4A of GSTR 3B to be used.
• It would be total of point 8C +
imports + inward supplies on
which tax paid under RCM in
CFY for PFY

Part V- Particulars of previous FY declared in
returns of April-September 2018
42

Part VI- Other Information
43
RFD -01 – Exports WPOT, SEZ, Inverted Rate duty, Shipping bill for Export WPT
RFD -04 – Sanction of Refund amount, RFD -05 – Payment advice, RFD 06 – Order
Sanctioning refund amount
RFD -08 – Issuance of Notice in respect of Refund not admissible
View Notices & Order or verify liability register to get details of all type of
demand raised

44
16
Taxable
Value
Central
Tax
State
Tax/UT
Tax
Integrate
d Tax
Cess
2 3 4 5 6
A
B
C
Goods sentonapprovalbasis
butnotreturned
Informationonsupplies received fromcompositiontaxpayers, deemed supplyunder
section143 and goods sentonapprovalbasis
Details
1
Supplies received from
Compositiontaxpayers
Deemed supply underSection
143
• Table 5 of GSTR 3B to be used
for point 16A
• Point 16B--Deemed supply –
When Input & CG from
principal & job worker and not
returned within stipulated time
period shall be reported here.
• Point 16C– Details of deemed
supplies for goods which are
sent on approval basis, but not
returned within 180 days of
such supply shall be declared
here.

46
Verification:
I hereby solemnly affirm and declare that the information given herein above is true and correct to the
best of my knowledge and belief and nothing has been concealed there from and in case of any
reduction in output tax liability the benefit thereof has been/will be passed on to the recipient of
supply.
Signature
ANNUAL RETURN
LATE FEES

Relaxation in FORM GSTR 9
Table Particulars Relaxation
4B to 4E Outward Taxable Supply Optional to fill Net of Cr./Dr./ notes & amendment
5D, 5E & 5F Exempted, NIL rated & Non-
GST
Option to fill all details pertain to Exempted, NIL Rated & Non GST
Supply in “Exempted” column
5A to 5F Outward supply on which Tax is
not paid
Optional to fill Net of Cr./Dr./ notes & amendment
6A to 6E Bifurcation of Input Credit The registered shall report the breakup of input tax credit as
capital goods and have an option to either report the breakup of
the remaining amount as inputs and input services or report the
entire remaining amount under the “inputs” row only
6C & 6D RCM ITC Option to fill details of both in Table 6D only
7A to 7H Credit Reversal Except reversal pertaining to Tran 1 (7F) & Tran 2 (7G) option to fill
all details in Table 7H (Other Reversal)
12 & 13 Amendment in Next Year Optional
15A to 15D Details of Refund Optional
16A Supplies received from
composition dealer
Optional
47

Major Changes in FORM GSTR 9
Table Particulars Relaxation
16B Deemed supplies from principal
to job worker
Optional
16C Deemed supplies for goods
which were send on approval
basis
Optional
17 HSN wise details of Outward
Supplies
Optional
18 HSN Wise details of Inward
Supplies
Optional
48

Issue - 3
• Mr. X, while Filing GSTR 1 & GSTR 3B made errors & did not disclose
certain outward supply. The same are disclosed during F.Y 2021-22
• Whether they are required to disclose the same in Annual return
for F.Y 2020-21
• Yes, Declare in table 10 & 11 of Annual return.
• Tax liability thereon to be declared in Table 14
49

Issue - 3
• In case, if the same is not declared in F.Y 2020-21, then where
to disclosed.
• Declare in Table 4. Additional Tax to be paid through DRC 03.
50

Issue - 4
• Educational institution is registered for payment of Tax under
RCM. There entire outward supply is exempt.
• Are they require to file annual return??
51

Issue - 5
• ABC exporter Issue GST invoice as per custom rate & book the
transaction in books of accounts as per Accounting standard
i.e. RBI Reference Rate
• This has resulted into foreign exchange fluctuation. Whether
same is required to be reported in GSTR 9.
52

Issue - 4
• Confused Limited while filing annual return for F.Y 2020-21 has
following issues
• ITC as per GSTR 3B is Rs. 10 Lakhs where as per GSTR 2A is 8 Lakhs. On enquiry it
was found that the vendor has declared corresponding Turnover in B2C
• Whether confused Limited should reverse the ITC?
53

 Section 35(5) of CGST Act, 2017: (GST Audit)-------------------------OMITTED 1st August, 2021
Every registered person whose turnover during a financial year exceeds the prescribed limit shall get his
accounts audited by a CA or a CWA and shall submit
• A copy of audited accounts,
• The reconciliation statement u/s. 44(2) and
• such other documents in such form and manner as may be prescribed
 Ingredients of GST Audit
• Audit By CA/CWA
• File copy of Audited Accounts
• Certify & File Reconciliation Statement in Form GSTR 9C
P ro v i s i o n s

G S T R 9 C GSTR 9C - Overview
Part A - Reconciliation Statement
Part I - Basic details
Part II - Reconciliation of turnover declared in the audited Financial
Statements with the turnover declared in Annual Return (GSTR-9)
Part III - Reconciliation of tax paid
Part IV - Reconciliation of Input Tax Credit
Part V - Additional liability due to non-reconciliation

Pt. I Basic Details
1
Financial
Year
April, 2020 to March, 2021
2 GSTIN 27AAAPL1267C1ZD
3A Legal Name < Auto>
3B
Trade Name
(if any)
<Auto>
4 Are you liable to audit under any Act?
<<Please
specify>>
“FORM GSTR-9C”
PART – A – Reconciliation Statement

Pt. II
Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in
Annual Return (GSTR9)
5 Reconciliation of Gross Turnover
A
Turnover (including exports) as per
audited financial statements for the
State / UT (For multi-GSTIN units
under same PAN the turnover shall
be derived from the audited Annual
Financial Statement)
• Turnover for April, 2020 to March, 2021 to be
mentioned
• Do no include supply transaction or any other
transaction except turnover in state
E.g. Sale of Fixed Asset, Donation of Asset on which
ITC was claimed
• Do not included income from other source Such as
dividend income, Recovery of bad Debts etc.
“FORM GSTR-9C”

5B
Unbilled revenue at the
beginning of Financial Year
(+)
Example
• Rental of Commercial Premises for 16th March, 2020
to 15th April, 2020 – Rs. 1 Lac
• In the books of F.Y 2019-20, rent income is disclosed
Rs. 50,000/- based on periodicity
• On 16th April, 2020, Invoice raised for 1 lac
• Here, Rs. 50,000/- is unbilled revenue
5C
Unadjusted advances at the
end of the Financial Year
(+)
• Declare here advance received on which GST is paid
but not recognised as revenue in Financial Statement
“FORM GSTR-9C”

5D
Deemed Supply under
Schedule I
(+)
• As per Instruction annexed to audit report……Any “Deemed supply”
which is already part of “Audited Financial Statement” is not to be
included here.
• “Deemed supply” means supply without consideration which will never
appear in audited financial statement
• Stock transfer (without consideration) between 2 branches having
separate GSTN
• Cross charge
• Gift to employee
E.g. Sony Ltd selling TV at Rs. 40,000/- to employee whose selling price to
Distributor is Rs. 1,00,000/-. Here Rs. 60,000/- is gift which will not appear
in Financial Statement.
“FORM GSTR-9C”

5E
Credit Notes issued after the end of the
financial year but reflected in the
annual return
(-)
• Credit Note issued after end of the financial year
corresponding to supply made during the year & not
accounted in financial year is required to be mentioned
here.
5F
Trade Discounts accounted for in the
audited Annual Financial Statement but
are not permissible under GST
(+
)
• Trade discount accounted in books but not eligible under
section 15(3) of CGST for deduction to be added here
5G Turnover from April 2017 to June 2017 (-) • Not applicable for F. Y 2020-21
“FORM GSTR-9C”

5H
Unbilled revenue at the end of Financial
Year
(-)
• Reduce the Unbilled revenue at end of Financial year
• E.G. Rental income of commercial Premises for 16th
March, 2021 to 15th April, 2022 is Rs. 1 Lakh. In books of
accounts for F.Y 2020-21, rental income was disclosed as
Rs. 50,000/- as unbilled revenue based on periodicity. On
16th April, 2021 Invoice was raised for Rs. 1 lakh. In such
case, Rs. 50,000/- to be disclosed as an unbilled revenue
for F.Y 2020-21
5I
Unadjusted Advances at the beginning
of the Financial Year
(-)
• E.g. Rs. 5 lac received as fees on 10th March, 2020 on
which GST was paid for which invoice raised & revenue
was booked raised on 1st April, 2020
“FORM GSTR-9C”

5J
Credit notes accounted for in the
audited Annual Financial Statement
but are not permissible under GST
(+)
• This clause should contain the figure that of credit notes
issued & accounted for in the audited financial statement of
the year but same is not permissible u/s 34 of CGST Act,
2017
• E.g. Credit note for Cash discount, Credit note for goods
return beyond the month of September following end of
financial year in which supply was made or date of
furnishing annual return which every is earlier.
“FORM GSTR-9C”

5K
Adjustments on account of supply of
goods by SEZ units to DTA Units
(-)
• This clause will be applicable only when reconciliation of
SEZ is being made
• Aggregate value of all goods supplied by SEZ to DTA units
for which the DTA units have filed bill of entry shall be
declared here.
• DTA units places order for purchase of Goods to unit of
SEZ with instruction to deliver the goods out of India. In
this scenario Bill of entry in not require to be filed.
5L
Turnover for the period under
composition scheme
(-)
• Turnover for period under composition scheme to be
mentioned here.
“FORM GSTR-9C”

5M
Adjustments in turnover under
section 15 and rules thereunder
(+ /-)
• This clause contains the data resulting on account of
difference in turnover as per Invoice raised during the
year & valuation thereof as per section 15 of CGST Act.
Section 15(2) provide for inclusion of various items for
purpose of computing value of Turnover
Example
• Goods sold to related party (B2C) at price lower than
Market price.
5N
Adjustments in turnover due to
foreign exchange fluctuations
(+ /-)
• Adjustment of Foreign exchange fluctuations to be made
here only when you have included the foreign exchange
fluctuation in computing Turnover over as per Clause 5A
5O
Adjustments in turnover due to
reasons not listed above
(+ /-)
“FORM GSTR-9C”

5P
Annual turnover after adjustments as
above
<AUTO>
5Q
Turnover as declared in Annual
Return (GSTR 9)
• As mentioned in FORM GSTR 9
5R Un-Reconciled turnover (Q – P)
“FORM GSTR-9C”

6 Reasons for Un – Reconciled difference in Annual Gross Turnover
A Reason 1 <<TEXT>>
B Reason 2 <<TEXT>>
C Reason 3 <<TEXT>>
“FORM GSTR-9C”

7 Reconciliation of Taxable Turnover
7A
Annual turnover after adjustments (from 5P
above)
<<AUTO>>
7B
Value of Exempted, Nil Rated, Non-GST
supplies, No-Supply turnover
Example
• Petrol/Diesel
• Services by a hotel, inn, guest house, club or
campsite, by whatever name called, for residential
or lodging purposes, having declared tariff of a unit
of accommodation less than ` 1000/- per day”.
• sale of shares
7C Zero rated supplies without payment of tax
Example
• Supply to SEZ
• Export of Goods /Service
“FORM GSTR-9C”

7D
Supplies on which tax is to be paid by the recipient on reverse charge
basis
E.g. GST on Sponsorship
service received by
corporate.
7E Taxable turnover as per adjustments above (A-B-C-D) <<Auto>>
7F Taxable turnover as per liability declared in Annual Return (GSTR9)
G Unreconciled taxable turnover (F-E) AT2
“FORM GSTR-9C”

“FORM GSTR-9C”
8 Reasons for Un - Reconciled difference in taxable turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
This part of GSTR 9C identifies the taxable turnover differences to be placed on
record for explaining the differences between the GST annual Returns and the
Audited Financials.

PT
III
Reconciliation of tax paid
9 Reconciliation of rate wise liability and amount payable thereon
Description Taxable Value
Central
tax
State tax
/ UT tax
Integrated Tax
Cess, if
applicabl
e
5%
5% (RC)
“FORM GSTR-9C”

Central
tax
State tax
/ UT tax
Integrated Tax
Cess, if
applicabl
e
12%
12% (RC)
18%
18% (RC)
28%
28% (RC)
3%
0.25%
0.1%
“FORM GSTR-9C”

Description
Taxable
Value
Central
tax
State tax
/ UT tax
Integrated Tax
Cess, if
applicabl
e
Interest
Late Fees
Penalty
Others ???
Total amount to be paid as per tables
above
<Auto> <Auto> <Auto> <Auto>
Total amount paid as declared in Annual
Return (GSTR 9)
“FORM GSTR-9C”

• After reconciling the turnover declared and reported in the Audited Financial
Statement with turnover declared in Annual Return along with reasons for
reconciliation if any, the relevant Part III of Form 9C requires an taxpayer is required to
reconcile the rate-wise liability of tax, total amount payable thereon with tax actually
paid as declared in the Annual Return additional tax payable due to non-reconciliation
of the taxable value.
• The details of any liability of Interest under Section 50 of the GST Acts accounted for in
the books of accounts or any Late Fees for Late filing of GSTR 3B or penalty leviable
under any relevant sections of the Act needs to be reported here.
Point 9 - Reconciliation of tax paid

10 Reasons for un-reconciled payment of amount
A Reason 1 <<TEXT>>
B Reason 2 <<TEXT>>
C Reason 3 <<TEXT>>
“FORM GSTR-9C”

11 Additional amount payable but not paid (due to reasons specified under Tables 6,8 and10 above)
Central
tax
State tax
/ UT tax
Integrated Tax
Cess, if
applicabl
e
5%
12%
18%
28%
3%
0.25%
0.10%
“FORM GSTR-9C”

Description
Taxable
Value
Central
tax
State tax
/ UT tax
Integrated Tax
Cess, if
applicabl
e
Interest
Late Fees
Penalty
Others
“FORM GSTR-9C”

“FORM GSTR-9C”
Pt. IV Reconciliation of Input Tax Credit (ITC)
12 Reconciliation of Net Input Tax Credit (ITC)
A
ITC availed as per audited Annual Financial Statement for the State/ UT (For
multi-GSTIN units under same PAN this should be derived from books of
accounts)
ITC Suspense is also
ITC availed
B
ITC booked in earlier Financial Years claimed in current
Financial Year
(+)
C.
ITC booked in current Financial Year to be claimed in
subsequent Financial Years
(-) ITC Suspense
D
ITC availed as per audited financial statements or books of
account
<<AUTO>>
E ITC claimed in Annual Return (GSTR9)
F Un-reconciled ITC ITC 1

13 Reasons for un-reconciled payment of amount
A Reason 1 <<TEXT>>
B Reason 2 <<TEXT>>
C Reason 3 <<TEXT>>
“FORM GSTR-9C”

“FORM GSTR-9C”
14
Reconciliation of ITC declared in Annual Return (GSTR 9) with ITC availed on expenses as per audited
Annual Financial Statement or books of account
Description Value Amount of Total ITC
Amount of eligible
ITC availed
A Purchases
B Freight/Carriage
C Power/Fuel….Coal
D
Imported Goods (incl.
received from SEZs)
E Rent & Insurance
F
Goods lost, stolen, destroyed,
written off or disposed of by way
of gift or free samples???

“FORM GSTR-9C”
Amount of eligible
ITC availed
G Royalties
H
Employees’ Cost (Salaries,
wages, Bonus etc.)
I Conveyance charges
J Bank Charges
K Entertainment charges
L
Stationery Expenses (including
postage etc.)
M
Repair and
Maintenance
N Other Miscellaneous expenses

“FORM GSTR-9C”
Amount of eligible
ITC availed
O Capital goods
P Any other expense 1
Q Any other expense 2
R Total amount of eligible ITC availed <<Auto>>
S ITC claimed in Annual Return (GSTR9)
T Un-reconciled ITC
15 Reasons for un – reconciled difference in ITC
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>

“FORM GSTR-9C”
16 Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)
Description Amount Payable
Central Tax
State/UT Tax
Integrated Tax
Cess
Interest
Penalty

“FORM GSTR-9C”
PT V Additional Liability due to non-reconciliation
Description Value CGST SGST/UGST IGST CESS
5%
12%
18%
28%
3%
0.25%
0.1%
Input Tax credit
Interest
Late fees

“FORM GSTR-9C”
Description Value CGST SGST/UGST IGST CESS
Penalty
Any other amount
paid for supplies
not included in
Annual Return
Erroneous refund
to be paid back
Outstanding
demands to be
settled
Other (Pl.
specify)

I hereby solemnly affirm and declare that the information given herein above is true and
correct to the best of my knowledge and belief and nothing has been concealed there from.
I am uploading this self-certified reconciliation statement in FORM GSTR-9C. I am also
uploading other statements, as applicable, including financial statement, profit and loss
account and balance sheet, etc.
VERIFICATION

WITH KNOWLEDGE……… WE KNOW THE WORDS,
BUT WITH EXPERIENCE……... WE KNOW THE MEANING
CA. KARAN LODAYA
KARAN LODAYAAND ASSOCIATES
CHARTERED ACCOUNTANTS
610/611, Parmeshwari Centre, Above FedEx, Dalmia Estate,
Off. LBS Marg, Mulund (West), Mumbai-400 080.
Tel : 2564 1553/2569 4989 Mobile : 9821163532
Email: karan@rjl.co.in

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