We are running a series on GSTR 9 Preparation. And this article culminates the same.

The annual return is divided into 6 parts, Part I covers basic details while Part II is for outward supplies. Part III is important section covering ITC related reports in Table 6, Table 7 and Table 8.

Part IV is the actual tax paid during the financial year.

Part-V Particulars of the transactions for the FY 2017-18 declared in returns between April 2018 till March 2019

Table10: Supplies / tax declared through Amendments (+) (net of debit notes)

Items to be reported in Table 10 are:

(a)  Additional Invoices related to 2017-18 but reported in the GSTR 3B returns for the months April 2018 to March 2019 ;

(b) Debit notes dated before Mar 31, 2018 omitted in 2017-18 and reported in the returns for the months of April 2018 to March 2019

(c) Amendments to invoices related to 2017-18 and reported (with errors) in the GSTR 3B for 2017-18 but now reported (duly rectified) in the returns for the months of April 2018 to March 2019

While considering in this clause, data reported ‘for’ 2017-18 but in GSTR 3B ‘for’ 2018-19 alone is to be considered. Any data reported ‘for’ 2017-18 belatedly does not become GSTR 3B ‘for’ 2018-19.

All information reported here must flow from GSTR 3B filed after the financial year till the due date of filling returns for March 2019.

Information in 10 of GSTR 9 would be corrections of errors of omission or commission made during the year 2018-19 in GSTR 1 and taxes paid in 3B also in 2018-19 in respect of such supplies which increases the total value of supplies be reported in table 10.

Sl. No. 11: Supplies / tax reduced through Amendments (-) (net of credit notes)

Items to be reported in Table 11 are:

(a) Credit notes dated 2017-18 and reported in GSTR 1 ‘for’ 2017-18 but reported in the returns 3B for the months April 2018 to March 2019

(b) Amendments to invoices related to 2017-18 and reported (with errors) in the GSTR1 for 2017-18 but now reported (duly rectified) in the returns i.e 3B for the months April 2018 to March 2019

While considering in this clause, data reported ‘for’ 2017-18 but in GSTR 3B ‘for’ 2018-19 alone is to be considered. Any data reported ‘for’ 2017-18 belatedly does not become GSTR 1/3B ‘for’ 2018-19’.

All information reported here must flow from GSTR 3B filed after the financial year till the due date of filling returns for March 2019.

Information in Table 11 of GSTR 9 would be corrections of errors of omission or commission made during the 2018-19 in GSTR 3B in respect of such supplies which reduces the total value of supplies/tax.

Sl. No. 12: Reversal of ITC availed during previous financial year

Sl. No. 12 of Part V of the GSTR 9 contains the summary of the input tax credit to be reversed that was availed during the reporting financial year. The data to be tabulated relates to the input credit that was taken in the reporting financial year and reversed during the period April 2018 to March 2019. The reversal may be for various reasons like erroneously taken credit or failure to make payments within the stipulated time. The amount of credit that needs to be reversed is to be disclosed in this column.

The information to be disclosed in the column is linked to the GST returns filed between the month of April 2018 to March 2019 for the accounting transactions recorded in the books from July 2017 to the end of the financial year on 31st March 2018.The reference documents for the input credits would be the data from GSTR 3B and GSTR 2A along with the accounting records like the supplier’s invoices, debit notes etc.

The input credit availed between July 2017 to March 2018 may have to be reversed post the completion of the financial year due to various reasons ((recognised in the financial year ensuing year on the following reasons)):

Reversal of Transitional credit: During the implementation of the GST regime, the Government had provided for claiming of credits available in various forms in the Form TRAN-I and TRAN-II on a self-declaration basis. The transitional credit claimed may find a variance due to errors of omission and commission by a Registered Person. The same can be adjusted in this section.

Credit wrongly claimed on items covered under section 17(5)

Non-reversal under Rule 42/43

Sl. No. 13: ITC availed for the previous financial year

All credits claims are reported in a statement in GSTR 3B filed ‘for’ each month. For credit relating to inward supplies ‘for’ July 2017 to March 18, the same would be reported in GSTR 3B for each month. However, when inward supplies for July 2017 to March 2018 are not so claimed and reported in GSTR 3B ‘for’ the months April to March 2019, this information is to be reported in Sl.No.13. This information would be available in Table 4(A) of the said GSTR 3B.

Section 16(4) provides that credits relating to a particular financial year needs to be claimed within the due date of filing the returns for September of the subsequent financial year or the date of filing the annual return whichever is earlier. However proviso to section 16(4) is inserted by the Central Goods and Services Tax (Second Removal of Difficulties) Order, 2018, w.e.f. 31-12-2018 that the registered person shall be entitled to take input tax credit after the due date of furnishing of the return under section 39 for the month of September, 2018 till the due date of furnishing of the return under the said section for the month of March, 2019 in respect of any invoice or invoice relating to such debit note for supply of goods or services or both made during the financial year 2017-18, the details of which have been uploaded by the supplier under sub-section (1) of section 37 till the due date for furnishing the details under sub-section (1) of said section for the month of March, 2019.This Table requires the taxpayer to declare the details of ITC claimed by him in the subsequent year (April to March 2019 ) which relates to the reporting financial year.

Sl. No. 14. Differential tax paid on account of declaration in 10 and 11 above

Table 14 aims to capture the details of differential tax liability, either increase or decrease, as the case may be, arising out of such reporting by the person filing the Annual Return. The Table 14 also captures whether the relevant additional tax arising has been paid or not. The details of Interest in respect of any additional tax payable and paid in Table 14 is also required to be disclosed here.

Since amounts of tax payable in Sl. No. 14 arises from details in Sl. No. 10 and 11, details of tax payable should net total of what has been reported in Table 10 and 11.

For tax Payable

Since under Table 9 of Part IV, the details of tax payable for details of supplies on which person filing the Annual Return is reported through the details of tax as derived in 4N, hence in a similar manner, for details of tax payable to be reported in 14, the net amount of tax reported in 10 and 11 should be considered. In case where the net effect of tax disclosed in 10 and 11 is negative i.e. where the amount of tax in Credit Note or reduction in taxable value reported in GSTR 1 of April 2018 to March 2019 is more than amount of tax in Debit Note or amount of taxable value to be increased then such amount shall be disclosed as negative amount in tax payable.

For tax paid through Cash

In case, the amount of tax disclosed in 10 and 11 is positive or an increase in liability of tax and such tax has been also paid in GSTR 3B filed for months from April 2018 to March 2019, the amount of tax paid should be mentioned.

For Interest Payable and Paid

For reporting the amount of interest under the given column, the person filing an Annual Return needs to calculate the interest applicable under section 50 of the CGST Act. The said interest needs to be calculated by identifying the exact months in which the additional tax liability should have been paid up to the month in which it is actually paid.

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