Amidst the chaos and hustle to file their first ever GST annual returns, taxpayers have been facing certain issues while filling form GSTR 9 and GSTR 9C. The CBIC has released a note in order to help taxpayers solve these issues. So, if you find yourself in any of these situations, please see what you need to check/edit or modify, to get proper GST reconciliation.
Issues in form GSTR 9
1) Mismatching ITC value between 2A and Table 8A of GSTR 9:
Some taxpayers have reported that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A.
The mismatch can be due to one of the following reasons:
a. Check if the supplier had ‘filed’ the said invoices or not:
Figures in GSTR-2A are auto-populated based on data filed/ saved / submitted by the suppliers in Form GSTR-1. On the other hand, the figures in table 8A of Form GSTR-9 are auto-populated on the basis of only the filed Form GSTR-1 data. Thus, if your supplier failed to file his Form GSTR -1, the credit related to those invoices will not appear in table 8A of your Form GSTR-9.
b. Check if the supplier filed ‘after’ the due date:
Figures in table 8A of Form GSTR 9 are auto-populated only for those Form GSTR-1, which were filed by the supplier before the due date of its filing i.e. 30th April 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April 2019, will not get auto-populated in table 8A of Form GSTR-9.
c. Check invoices across 2As to account for amendments in form GSTR 1
In table 8A of Form GSTR-9, only the latest values of invoices have been auto-populated based on filed Form GSTR-1, taking into account all the amendments made, if any. Suppose an invoice with a taxable value of Rs 100/- with a tax of Rs. 18/- was filed in Form GSTR-1 in the month of January 2018 and same was amended to Rs 90 as the taxable value in the month of March 2018, then
- the Form GSTR-2A of January 2018 will show ITC of Rs. 18
- the Form GSTR-2A of March 2018 will show ITC of Rs 16.20 &
- the table 8A of Form GSTR-9 will contain ITC of Rs 16.20.
d. Intra-state supplies of suppliers will be shown in 2A of recipient instead of Table 8A
In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in which place of supply lies in supplier’s state, instead of State of the recipient. These figures will be shown in Form GSTR-2A of the recipient. For example, if a taxpayer of State A visits State B and stays in a hotel in State B, the tax paid by him to the hotel in State B will appear in his Form GSTR-2A, but the same will not be reflected in table 8A of Form GSTR-9.
e. Composition Scheme
The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.
2) Disable ‘Proceed to File’ button
While filing Form GSTR 9 ‘Proceed to File’ button will be enabled only if ‘Compute Liability’ is clicked. This button is meant for computation of late fees only. Please note Form GSTR 9 once filed cannot be revised.
Issues in form GSTR 9C
1. Turnover for filing Form GSTR- 9C:
Form GSTR-9C is to be filed by all those taxpayers whose aggregate turnover has exceeded Rs 2 crore in a financial year. Turnover of the complete year i.e. from 1st April 2017 to 31st March 2018 has to be taken into account for calculating the turnover. For example, if a taxpayer has a turnover of Rs. 2.1 Cr for the period 1st April 2017 to 31st March 2018 and a turnover of Rs. 1.9 Cr for the period 1st July 2017 to 31st March 2018, then the taxpayer is required to file form GSTR- 9C.
Point to note here is that, GST filing only started from July 2017. Hence, there is no GSTR1 and 3B data for April 2017-May 2017.
However, GSTR 9 C has to be filed as per turnover from 1st April 2017 to 31st March 2018.
2. User getting an error message while using Excel version:
This may be attributed to lower version of Microsoft Excel. You are advised to use Microsoft excel version higher than 2007 while preparing Form GSTR 9C.
3. Providing Membership Number by Auditor:
While filing Part B of Form GSTR-9C, auditors are advised to give their membership number without prefixing ‘0’ in their membership number. If the membership number is ‘016’, then the auditor should enter ‘16’ on the aforesaid part in the membership number field & not ‘016’.
It is requested that all the taxpayers file their FORM GSTR 9 and GSTR 9C at the earliest, to avoid last minute rush and to avoid payment of a late fee. The due date to file form GSTR 9 and GSTR 9A is June 30, 2019.
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