Simplification of Annual Return GSTR – 9, 9C and extension of filing date
In a welcome move, although bit late, the Central Board of Indirect Taxes and Customs (‘CBIC’) has relaxed many of the challenges faced by the taxpayers while filing the annual return and reconciliation form, vide Notification no. 56/2019 - Central Tax dated 14 November 2019.
Further, the CBIC have issued order no. 8/2019 - Central Tax dated 14 November 2019 for extending the due date of filing Annual Return (GSTR - 9) and Reconciliation Statement (GSTR - 9C). The due date for filing of annual return and audit report has been extended for Financial Year (‘FY’) 2017-2018 from 30 November 2019 to 31 December 2019. Separately, for FY 2018-2019, the due date has been extended from 31 December 2019 to 31 March 2020.
With respect to certification requirement (GSTR - 9C), auditor is now required to provide a ‘true and fair’ view of the reconciliation statement as against the previous requirement to provide ‘true and correct’ certification.
Given below is gist of the simplification announced by the CBIC vide Notification no. 56/2019:
Part I - Annual Return (GSTR - 9)
Sr. No. | Particulars | Table Nos. | Relaxation / Simplification |
1 | Outward supplies on which tax is payable |
| Option to declare details net of debit notes, credit notes and amendments |
2 | Outward supplies on which tax is not payable |
| Option to declare details net of debit notes, credit notes and amendments |
| Option to declare consolidated details in Table 5D | ||
3 | Input Tax Credit (‘ITC’) availed |
| Consolidated information with respect to ITC availed on inputs, capital goods and input services can now be reported under a common heading - ‘Inputs’ |
| Consolidated ITC availed under RCM can be reported in a single row i.e. Table 6D | ||
4 | ITC reversed and ineligible ITC |
| Consolidated ITC reversals can now be reported under a single row i.e. Table 7H - Other reversals Reversal on account of TRAN-1 credit (Table 7F) and TRAN-2 (Table 7G) to be mandatorily reported |
5 | Other ITC related information |
| Option available to registered person to upload details of the entries in pdf format, in Form GSTR 9C |
6 | Others |
| Option available to registered person to not fill details |
Part II - Reconciliation Statement (GSTR - 9C)
Sr. No. | Particulars | Table Nos. | Relaxation / Simplification |
1 | Reconciliation of Gross Turnover |
| It has been made optional. However, in case adjustment is required to be reported, the same may be reported in Table 5O - Adjustments in turnover due to reasons not listed above |
2 | Reconciliation of Net ITC |
| It has been made optional |
3 | Reconciliation of ITC declared in Annual Return with ITC availed vis-a-vis expenses as per audited financial statement |
| It has been made optional |
Based on the above, it will be noticed that most of the reconciliation requirements have been made optional, however it is better that the taxpayer continues to maintain the required reconciliations as the same may be required during the audit, if any, conducted by the Revenue Authorities.
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