GSTR-9 Due Date Extended – Everything You Need To Know

If you are a Chartered Accountant hired for filing GSTR-9 for a particular business and/or individual, then here are certain things to consider with regard to the extension of the due date for filing GSTR-9 (annual return) and Reconciliation Statement (GSTR-9C) for the financial year 2019-20. The due date for filing GSTR-9 annual return has already been prolonged a number of times for various reasons inclusive of complexities in the form and filing, for instance. For both businesses and CAs, the previous year may have somewhat been quite a confusing and complicated period, trying to recognize the tricky GSTR-9 shape, whilst tallying their returns which are filed on a monthly and quarterly basis along with their books of accounts. In this post, we are going to share with you a list of possible reasons and/or issues behind the process of GSTR-9 Due Date Extended.

Due Date Extended for Filing GSTR-9

The CBIC has notified that the due date for filing GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2018-19 is extended to June 30, 2020.

For business entities such as enterprises, companies, and small and medium-sized organizations having an annual turnover of less than Rs. 5 crores, the filing of GSTR-9C for the financial year (FY) 2018-19 has been waived off.

On the other hand, for businesses with less than Rs. 2 crores aggregate turnover in the financial year ( FY) 2017-18 and FY 2018-19, there are no late fees charged for the delay in filing of GSTR-9.

Challenges Faced by CAs at the Time of Filing GSTR-9

A few reasons for the challenges or issues that could be faced by CAs are given as follows:

(a) ITC mismatch between GSTR-2A and Table 8A of GSTR-9

This is a part that has caused numerous challenges for taxpayers due to the mismatch between the input tax credit (ITC) being shown in the auto-generated GSTR-2A return and the input tax credit being auto-populated in Table 8A of Form GSTR-9.

This could be due to:

  • Input tax credit (ITC) on supplies in relation to the financial year 2017-18 will no longer get auto-populated in GSTR-9, in case the same has been declared after 30th April 2019.
  • The very last figures, after thinking about amendments have been mentioned in GSTR-9, as in opposition to the gross values being shown in Form GSTR-2A.
  • Input tax credit relating to invoices for such length the recipient taxpayer was under the Composition Scheme are not being shown in GSTR-9.
  • Input tax credit on invoices wherein the location of supply lies within the supplier taxpayer’s state rather than the recipient taxpayer’s state has been excluded in GSTR-9.

(b) Input Tax Credit bifurcation needed in GSTR-9 and GSTR-9C

Form GSTR-9 calls for the bifurcation of all input tax credit availed from inputs, input services, and capital goods. This, in turn, requires a complete and thorough analysis of the books of accounts of a taxpayer, with regard to verification by the concerned auditor. Not all taxpayers could have kept a record of this bifurcation leading to the undue hassle of acquiring these details now, to keep away from incorrectly reporting the same.

(c) Input Tax Credit claimed, however not reflecting in GSTR-2A

Over the period of the financial year 2017-18, while filing the GSTR-3B returns, taxpayers have claimed input tax credit as eligible under the CGST Act. However, there is a lot more of input tax credit that is still not reflecting in the GSTR-2A of several taxpayers. The question that arises right here is whether such input tax credit could be deemed ineligible, and would bring about taxpayers receiving notices from the Tax Department, without a fair opportunity to prove the genuineness of such credit.

(d) Goods imported in FY 2017-18, however, ITC claimed in only FY 2018-19

There is no separate area right now to record the input tax credit claimed in FY 2018-19 on items that had been imported within the preceding FY 2017-18. While the government has clarified that such enter input credit will be reported in Table 6(E) of GSTR-9, which is for the entire credit availed between July 2017 and March 2019. Since the auditors want to put together their reconciliation statement primarily based on these records as well, it might have been easier for taxpayers to document these facts one by one and more accurately.

(e) Overlapping of figures in Tables 6(B) and 6(H)

Table 6(B) requires the reporting of all inward supplies and input tax credit availed in the course of the financial year, apart from imports and inward supplies vulnerable to reverse charge. Table 6(H) on the other hand, requires the reporting of input tax credit which were availed, reversed, and later reclaimed for the duration of the same financial year. This has caused the overlapping of figures between Table 6(B) and Table 6(H) of the GSTR-9. Although clarification from the government has been issued for cautioning the taxpayers about what each the fields mean, greater clarity is needed with examples/redressal of the accounting challenges.

(f) Disclosure of RCM liability in GSTR-9

The clarification released through the CBIC on the disclosure of legal responsibility under RCM, due for the financial year 2017-18, however, paid in the financial year 2018-19, has been unclear. This is due to the fact that the press release on 4th June 2019 used the words ‘additional outward supply’, without having any mention of RCM, while the Central Tax notification launched on 28th June 2019 makes use of the words ‘additional liability’. While taxpayers are intended to report the overall of such undisclosed liability under Table 4(G) of GSTR-9, the corresponding tax part of such liability desires to be declared under ‘Tax Payable’ in Table 9.

(g) Declaration of HSN precis for outward and inward Supplies

The government has made it mandatory that the HSN summary details are required to be disclosed by all suppliers having a turnover of more than Rs.1.5 crores. This requirement is regulated for both inward and outward supplies. This has prompted unnecessary hassles for taxpayers who had not been maintaining their records in the past and will now have to spend a lot of extra effort and time to obtain and document this information.

(h) No clarity on filling Table 4F of GSTR-9

Table 4(F) of the GSTR-9 annual return is for disclosing all advances on which tax has been paid, but where invoices have no longer been issued. The clarification for filling up the Table 4F states that the source of information is to be the table in Table 11(A) of the GSTR-1 returns. This holds better for only a monthly level due to the fact, at an annual level, adjustments made throughout the year need to be considered. This means records should also be sourced from Table 11(B) of the GSTR-1 returns.

(i) Ardous system of upload of GSTR-9C

The procedure for uploading GSTR-9C is bulky and also requires many technical steps that auditors are finding to be very time-consuming as well as inconvenient. In addition to the procedure involved, there are other troubles while submitting GSTR-9C where the address information of the statutory auditor is not being captured accurately, nor can the auditor input his/her qualifications entirely because of the limitation of word input.

(j) Other challenges faced whilst filing GSTR-9

In addition to the various challenges that have been mentioned above, there are other problems as well, which the taxpayers have been facing whilst filing their GSTR-9. These include:

  • Negative values copy-pasted in GSTR-9 and GSTR-9C offline applications are allowed in Tables 5(M), 5(N), and 5(O) only. While negative values may be copied elsewhere, and the JSON gets generated, the GSTN, however, does not process the same.
  • Even although there is no error detected, the JSON document is not getting uploaded.
  • In some cases, there were two final PDF copies of the GSTR-9 return filed.
  • The set-off under DRC-03 has been done, however taxpayers are nevertheless unable to file the same.
  • The DRC-03 is not getting reflected on the common GST portal in a few cases.
  • The splitting/bifurcation of the expense ledger in GSTR-9C is a very time-consuming procedure and with no acknowledged relevance.

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