Taxation - Indirect Tax
Filing of Annual Returns – GSTR - 9 & 9C
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Filing of Annual Returns – GSTR-9
GSTR-9 is the annual return to be filed by taxpayers registered under GST. It is due by 31st December of the year following the relevant financial year, as per the GST law.
It contains the details of all outward supplies made, inward supplies received during the relevant financial year under different tax heads i.e. CGST, SGST & IGST and a summary value of supplies reported under every HSN code, along with details of taxes payable and paid.
It is a consolidation of all the monthly or quarterly returns (GSTR-1, GSTR-2A, GSTR-3B) filed during that financial year. GSTR-9 is required to be filed by all taxpayers registered under GST.
However, there are few exceptions such as taxpayers who have opted for the composition scheme, casual taxable persons, input service distributors, non-resident taxable persons and persons paying TDS under section 51 of the CGST Act.
Note: As per the CGST notification no. 47/2019, later amended, the annual return under GST for taxpayers having an aggregate turnover that does not exceed Rs.2 crore has been made optional for FY 2017-18, FY 2018-19 and FY 2019-20.
GSTR-9A
GSTR-9A is currently a suspended annual return earlier required to be filed by composition taxpayers. It had a consolidation of all the quarterly returns filed during that financial year.
Ever since GSTR-4 (annual return) was introduced from FY 2019-20, this return stands scrapped. Prior to that, GSTR-9A filing for composition taxpayers had been waived off for FY 2017-18 and FY 2018-19.
Filing of Annual Returns – GSTR-9C
GSTR-9C is the reconciliation statement to be filed by all taxpayers registered under GST whose turnover exceeds Rs.2 crore in a financial year, as per the GST law.
It must be certified by a Chartered Accountant/Cost & Management Accountant after conducting a thorough GST audit of the books of accounts and comparing the figures with the GSTR-9.
The deadline to file this statement is the same as the due date prescribed for GSTR-9, i.e., 31st December of the year following the relevant financial year.
GSTR-9C is to be filed for every GSTIN, hence, one PAN can have multiple GSTR-9C forms being filed.
As per the Union Budget 2021 outcome, the GST audit requirement by professionals such as CAs and CMAs has been removed from the GST law. Sections 35 and 44 were amended for this but yet to be notified by CBIC. Accordingly, GSTR-9 needs to be filed on the GST portal by taxpayers on a self-certification basis, completely removing the requirement for GSTR-9C. However, the financial year and date of applicability of this removal are yet to be clarified by the government.
Note: As per the CBIC notification 16/2020, which was further amended, GSTR-9C is waived off for the taxpayers with an aggregate turnover of more than Rs.5 crore for the financial year 2018-19 and 2019-20.
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