The Central Board of Indirect Taxes and Customs (CBIC) on Jan 27th made the much needed simplification in GSTR 9 and GSTR-9C. This decision works as a boon ahead of its filing deadline.
Changes in Filing Requirements for Form GSTR 9 and GSTR 9C
- The GST filing of GSTR 9 and 9C was made optional for aggregate turnover (PAN based) of more than 2 cores calculated from July 2017 to 31st March 2018 for FY 2017-18.
- The simplifications notified in Form GSTR-9 and Form GSTR-9C effective only for FY 2017-18 and 2018-19.
- For FY 2017-18, the last date for filing GSTR-9 and GSTR-9C extended to 31st Jan 2020.
Simplification of GSTR 9C
- From now on, it is not mandatory to attach the cash flow statement.
- Instead of – ‘True and Correct’ opinion, the auditor is required to give ‘True and Fair’ opinion.
- Henceforth, the Table 14 is made optional.
- Option is also provided to not tqo fill the ‘ITC booked in previous Financial Year claimed in current Financial Year; and, ITC booked in current Financial Year to be claimed in next Financial Year’ in Table 12.
- Also, filing of unbilled revenue, unadjusted advances and other entries in Table 5 have been made optional now. Any adjustments requiring reporting can be entered in Table 50.
Query: Where is the provision to upload PDF regarding ITC for Table 8 (GSTR 9) as mentioned in notification on the portal?
Ans: Notification 56/2019 – Central Tax, dated 14th Nov, 20119 (Para 2 {iii} (C) {F}) provides this provision.
Earlier on Jan 24th, CBIC had issued advisory on error while uploading Balance sheet and Profit & loss statement while filing GSTR 9-C. CBIC suggested that ‘Balance sheet’, ‘Profit & loss statement’, ‘Income & Expenditure Statement’ keywords are blocked in office network firewall/content security filter as these contain sensitive information.
Hence the office firewall deny upload of such files/content .If these keywords will be used on open network all such mentioned documents can be uploaded successfully.
Next day on Jan 25th, CBIC also issued an advisory on error shown while uploading GSTR-9C JSON file. The error shown is, “Error occurred’ while there is no error report.
CBIC suggested that this error was due to use of’0’.User should not put ‘0’ (Zero) in the format of the membership number.
Issue Reported: Unable to upload Balance Sheet and P and LA/c (Form GSTR -9C)
Reason: One of the possible reasons could be that key words i.e. Balance Sheet/Profit and Loss Account/Income and Expenditure statement, if uploaded in your office network, may be denied upload by firewall/content security filter, as these contain sensitive information. An open network can also be used to upload these documents.
Issue reported: ITC auto populated in Table 8A does not match figures of Form GSTR 2A in Form GSTR 9
Reason: Figures in GSTR 2A flow from GSTR1 filed by your supplier taxpayer. If it has not been filed by supplier taxpayer till 30th April, 2019, for FY 2017-18, this amount will not flow into Table 8A Form GSTR-9.
Figures for FY 2017-18, reported by supplier taxpayers in GSTR1 after 30th April, 2019, will reflect in your GSTR2A but will not be auto populated in Table 8A of GSTR-9.
Please note that after recent changes taxpayers are also given an option to upload ITC related information in Tables 8A to 8D of GSTR 9, duly signed in PDF format in GSTR-9C without CA Certification.
Simplification of GSTR 9 (1)
In Table 4b to 4E and 5A to 5F, taxpayers are given an option to fill details net of CN, DN and amendments.
Option to fill exempt, NIL rated and Non GST supplies on consolidated basis in Table 5D
ITC bifurcation into inputs, capital goods and input services made optional. It can be reported in inputs row only.
ITC related to CRM goods from registered and unregistered can be merged and reported in Table 6D.
Simplifications made in Form GSTR 9(2)
Entire ITC reversal as per rule 37,39,42,43 and sec 17 (5) can be reported in Table 7H
Reversal on a/c of TRAN1 (Table 7F) and TRAN 2 (Table 7G) to be reported separately in respective tables.
Tables 12,13,15 to 18 now made optional.
Option to upload other ITC related information in Tables 8A to 8D, duly signed in pdf format in GSTR9C without CA certification.
Issue: Unable to delete data relating to Table 17 mistakenly entered in Table 18
Ans: Download JSON of this data from the portal and import into ofline tool. Thereafter make corrections, generate a new JSON and upload on Portal.
Query: Where to show undeclared GST Turnover in GSTR 9?
Ans: If tax is payable on that turnover, please declare it in Table 4 of GSTR9. If tax is not payable, then declare it in Table 5 of GSTR9
One of the possible reasons for non matching of ITC pre-populated in Table 8A of Form GSTR 9 with figure appearing in Form GSTR 2A is:
- Figures in table 8A of Form GSTR 9 are Auto Populated only for GSTR 1 filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019.
- ITC on supplies of the financial year 2017-18, if reported after 30th April 2019, will not get auto populated in Table 8A of Form GSTR9 but will appear in Form GSTR2A.
Other Clarifications:
Query: Government extended date for filing of GSTR1 up to 17/01/2020 but portal allows the ITC shown in GSTR 2A up to 30/04/2019.
Ans: Figures in Table 8A of form GSTR9 are auto populated only for GSTR1 filed by the supplier tax payer by due date of its filing i.e. 30th April, 2019.
ITC on supplies of the financial year 2017-18, if reported after 30th April 2019, will not get auto-populated in table 8A of form GSTR 9 but will appear in form GSTR 2A.