What are we going to discuss?

Introduction

GSTR 9 clause by clause

analysis

Issues to be considered in
Annual Return

GSTR 9C Clause by clause

analysis
 GST Reconciliation
Annual Return statement

Form GSTR 9 Form GSTR 9A Form GSTR 9B

Form GSTR 9C

Applicable to
Composition Applicable to GST Applicable to
normal Registered
Dealer TCS Taxpayer taxpayers whose
Taxpayer.
turnover exceeds 5
crores
Who need not file:
5.Non
Exempted 3.Casual 4.Input
1.TDS 2.TCS Resident
from Filing Taxable Service
Deductor Collector Taxable
GSTR 9: Person Distributer
Person

Exempted through Notification:

1.As per CBIC’s CGST notification number 9/2020 dated 16th March 2020, all
foreign companies which are in the airline business and compliant with the
relevant provisions and rules of the Companies Act 2013 are exempted from the
GSTR-9C requirement.
2.As per CBIC’s notification number.30/2019 dated 28th June,2019 persons who
are non-residents and are providing OIDAR service in India to unregistered
persons have been exempted from submitting GSTR-9 and GSTR-9C.
• Casual taxable person: A person who occasionally undertakes transactions involving supply
of goods or services in a State or a Union territory where he has no fixed place of business.

• Input Service Distributor (ISD): A taxpayer who receives invoices for services used by its
branches and distributes ITC on a proportional basis.

• Non-resident Taxable Person: Any person who is non resident in india and occasionally
undertakes transactions involving supply of goods or services or both.

• TDS Deductor : TDS deductor as per Section 51

• TCS Collector : TCS Collector as per Section 52

Turnover Limit:
Particulars GSTR -9 GSTR- 9C

Turnover upto Rs.2Cr Exempted Exempted

Turnover more than Rs.2Cr Mandatory Exempted

and upto Rs.5Cr
Turnover more than Rs.5Cr Mandatory Mandatory
 Annual Aggregate Turnover

Includes Excludes

1.Taxable Supply 1.Supplies Covered

2.Exempt Supply Under RCM
3.Exports 2.Taxes(CGST,SGST,IGS
4.Interstate Supply T & Cess)
Question:
1. Ananth enterprises is a GST registered enterprise, having GST registration in Andhra
pradesh and Telangana and the possible turnover limits for the FY 2022-23 is given below:
Case 1: If turnover of AP is 1.5 crores and Telangana is 0.3 crores.
Case 2: If turnover of AP is 2.5 crores and Telangana is 1.5 crores.
Will GSTR 9 &
Case 3: If turnover of AP is 6 crores and Telangana is Rs.3crores. GSTR9C be applicable
for 2 states in all the
above mentioned
scenarios?
Answer:
Case 1: Both GSTR 9 & 9C are not applicable for both AP and TS
Case 2: GSTR 9 is applicable for both AP and TS whereas GSTR 9C is not applicable for AP
and TS.
Case 3: Both GSTR 9 & 9C are applicable for both AP and TS.
2. What if GST registration is cancelled in the financial year say FY 2022-23 on
1-9-2022. Is GSTR-9 required to be filed?

Answer: Yes, the annual return needs to be filed if you were registered as taxpayer even
for a single day. Hence, you must file the GSTR-9 even your registration has been
canceled.

3.What if GST registration is pending for surrender in the end of the financial year?
Answer: The annual return needs to be filed.
Due date and Penalties:

Due date for filing GSTR-9 and GSTR-9C for a financial year shall be 31st December of the next Financial year.

For FY.2022-23: Due date to file GSTR 9 & 9C shall be 31st December 2023

• Penalty for late filing of GSTR 9:

S.no Turnover limit Late fee per day Maximum late fee
Rs 50 (Rs 25 each under 0.04% of turnover in state/UT (0.02% each
1 Up to Rs 5 crore
CGST and SGST Act) under CGST and SGST Act)
More than Rs 5 crore and Rs 100 (Rs 50 each under 0.04% of turnover in state/UT (0.02% each
2
less than Rs 20 crore CGST and SGST Act) under CGST and SGST Act)
Rs 200 (Rs 100 each under 0.50% of turnover in state/UT (0.25% each
3 More than Rs 20 crore
CGST and SGST Act) under CGST and SGST Act)
Overview of Form GSTR 9:

• Table 4 • Table 6
• Table 5 • Table 7
• Table 8

Outward Input Tax

supply and credit
Tax Liability eligible

Refunds,
Demands & Tax payable
HSN wise and paid
summary
• Table 15 to 18 • Table 9
• Table 10 to 14
Part 1: Basic Details:

Financial
GSTIN
Year

Legal name Trade name

of the of the
registered registered
person person
Form GSTR 1:
Table 4: Details of advances, Inward and outward supplies made during the Financial Year on which tax is payable
 Table 4 of GSTR 9:
• Outward supplies on which tax is being paid on RCM basis
shall not be included in Table 4 of GSTR 9
• Debit & Credit notes issued with no GST Impact are not Things to Remember
considered here
• B2C Turnover- reflects after netting off the credit & debit
notes, amendments made etc.
• B2B Turnover – without netting off of Credit and Debit
notes and also consideration of amendments.
• Sez Supplies- shall be admitted by the SEZ Officer
• Deemed Exports – u/s 147 of CGST Act,2017
• Advances – applicable for the advance received for supply
of services.
 Outward Register

Document issued
Bundling of activity
Ex: Tax Invoice,
Ex: Regular,
Debit/Credit note etc.
Composite, Mixed
Type of Supply Rate adopted
Ex: B2B, B2C, Exports for HSN of the
with/without payment supply
of IGST etc.
Table 5: Details of outward supplies made during the Financial Year on which tax is not payable:
Table 5 of GSTR 9:

• RCM supplies shall be separately reported in 5C

• Export of goods and services shall be considered as supply
with satisfaction of few conditions specified in Section 9(3). Things to remember
• SEZ supply shall only be authorised operations
• Non GST Supply: Supply that does not come under the
purview of GST. Reporting of such non GST Supply is
mandatory.
• Non GST Supply shall have an impact with Rule 42 & 43
• Exempted Supply and Nil rated supply can be shown
separately or shall be combined with the Exempted Supply
 Zero rated supplies

Exports SEZ

With payment Without payment With Payment

of IGST of IGST of IGST
Form GSTR 3B:
Table 6: Details of ITC availed during the Financial year:

INPUTS

RECALIMED
INPUT SERVICES CREDITS

TOTAL OF INPUTS AS
REPORTED IN GSTR 3B

INPUT CAPITAL
ISD CREDITS
GOODS

IMPORT ITC
Table 6: Details of ITC availed during the Financial year
Table 6 of GSTR 9:

• Table 6A is auto-populated from the ITC claimed in GSTR 3B.

Things to remember
It is just the classification that is required

• Reporting of ITC on Capital Goods is mandatory. ITC on Inputs

and Input services can be combined whereas the ITC on
Capital goods shall be shown separately.
Table 7: Details of ITC reversed & ineligible ITC for the financial Year

Due date to claim/reverse ITC pertaining to F.Y 2022-23 is 30th November 2023.

ITC of FY 2022-23

ITC Claimed in FY ITC reversed in FY

ITC not Claimed 2023-24 relating to ITC not reversed 2023-24 relating to
F.Y 2022-23 F.Y 2022-23

LAPSED TABLE 13 TABLE 7 TABLE 12

DRC-03
Table 7: Details of ITC reversed & ineligible ITC for the financial Year:
 As per Rule 37: ITC claimed in respect of supplies for which invoice payment has not been done within 180
days from the date of issuance of Invoice shall be reversed and the same shall be reclaimed once the
payment is done.

 As per Rule 39: Defines how the Input service distributor distributes the input tax credit as a result.

 As per Rule 42: Reversal of ITC becomes mandatory if the ITC claimed on the supplies is being used for the
personal purposes.

 As per Rule 43: Reversal of ITC is mandatory if the entity claims input tax credit on the capital goods.

 Section 17(5): In case input tax credit of goods or services listed down under provisions of Section 17(5) of
CGST Act,2017, then such ITC availed shall be reversed.
Table 8: Other ITC related Information:

ITC Availed Matched u/s

ITC Eligible Not Blocked
in Returns 38 and Rule
u/s 16 u/s 17
(GSTR 3B) 36(4)

ITC
available in Eligible Ineligible Blocked
GSTR 2A
Table 8: Other ITC related information:
Table 9: Details of tax paid as declared in the returns filed during the financial year:
Table 10,11,12&13: Details of previous financial year’s transactions reported in the
next financial year:

Outward Tax Liability relating to FY 2022-23

Paid in GSTR 3B Paid through DRC Paid in GSTR 3B of

Not paid
of FY 2022-23 03 in FY 22-23 FY 2023-24

TABLE TABLE TABLE TABLE

4 4 10 4
Table 10,11,12&13: Details of previous financial year’s transactions reported in the next
financial year:

 Table 10 & Table 11- Amendments for Output

 Table 12 & Table13- Amendments for Input

Table 14: Differential tax paid on account of declaration in table no.10&11
Table 15: Particulars of Demands and refunds received during the financial year:
Table 16: Supplies received from composition tax payer, deemed supply ,Job worker
& goods sent on approval basis:
Table 17:HSN wise summary of Outward supplies:

 6 - digit HSN code shall be given if Turnover exceeds 5 crores

 4- digit HSN code shall be given if Turnover is less than 5 crores for B2B only
Table 18: HSN wise summary of Inward supplies:
 Why Reconciliation?

• GSTR 9C – Journey from Financial statements to Annual Return is true and

correct.
• Turnover as per GST is as per Time of supply provisions.
• Time of supply for services is earlier of invoice or payment.
• Time of supply for goods is issuance of invoice.
• Turnover in Financial Statement is as per IND AS or AS.
• GST Reconciliation is a reconciliation between turnover as per time of supply and
turnover as per financial statement.
Reconciliations Required:
• 1. Turnover – Audited Financial Statements (AFS/Books) vs Table 5A (consider all
GSTINs)
• 2. Outward taxes – Liability as per Books Vs Liability as per GSTR 3B + DRC-03 (if
any) [ensure RCM liability is included]
• 3.Inward taxes – Credit as per books Vs Credit as per GSTR 3B to identify excess
claim of ITC, if any and missed out ITC to claim before 30th November 2023
through October 3B returns.
• 4.Closing balance [Cash + Credit] – Books Vs GST portal (consider all GSTINs)
• 5.Verify and provide for Spill over transactions of previous FY and maintain
tracker for next FY
Part A- Pt 1: Basic Details:

Financial
GSTIN
Year

Legal name Trade name

of the of the
registered registered
person person
 Pt-II-Reconciliation

Table 5 of GSTR 9C:

• Have an option not to fill the table 5B, whereas it is mandatory to fill from Table 5C to 5N
(Relaxation was provided till FY 2021-22)
• 5Q is auto populated from table 4N of GSTR 9.
Special Notes for above table
• Whether turnover as per financial statements to include income
otherthan revenue from Operations ?
• Discounts not permissible under GST to be added and Discounts
shown in face of invoice are not to be added
• Due to turnover limit, if assessee shifted to normal from composition,
turnover of composition period to be reduced from the above table.
Table 6 of GSTR 9C:
Table 7 of GSTR 9C:

Table 7F:Taxable turnover as declared in Table(4N-4G)+(10-11) of the Annual Return (form GSTR-9)shall be
declared here.
Table 8 of GSTR 9C:
Table 9 of GSTR 9C:

• New rate of 6% was included in the respective tables (applicable for brick manufacturing)
• Table 9Q the amount payable as declared in Table 9 of the annual return(Form GSTR-9)shall be declared here.It
should also contain any deferential tax paid on Table-10 or 11 of the annual return (Form GSTR-9).
Table 10 of GSTR 9C:
Table 11 of GSTR 9C:
Table 12 of GSTR 9C:
Table 13 of GSTR 9C:
Table 14 of GSTR 9C:
Table 15 of GSTR 9C:
Table 16 of GSTR 9C:
Reference:

 Key changes in GSTR 9 & GSTR 9C applicable for FY 2022-23

 GSTR 9 and 9C Offline utilities