written by khatabook | April 14, 2021

Form GSTR-9 Simplified: List of Changes Made As Per CBIC Notification

GSTR 9 is a return consisting of details of outward supplies made and inward supplies received during the relevant financial year. GSTR 9 is to be filed by a registered person every year electronically.  

As per the provisions of Section 44 of the CGST Act, 2017, every person registered under the Act is required to file the Annual Return ( Form GSTR-9) for every financial year, on or before the 31st day of December, following the end of such financial year. Registered persons whose total turnover is up to Rs. 2 Crores in the financial year 2017-18, 2018-19, and 2019-20, and have an option for filing the annual return as per notification No.  77/2020 – Central Tax dated 15-10-2020.

Also Read: GST FAQ – Search Your GST Queries | GST Frequently Asked Questions

Who should file GSTR 9 Annual return?

Every registered person is required to file a GSTR 9 annual return electronically every financial year on or before the 31st day of December following the end of the financial year. However, the following persons are not needed to furnish an annual return:

  • Input Service Distributor
  • Person paying tax under section 51 or section 52
  • Casual taxable person (CTP)
  • Non-resident taxable person (NRTP)

The turnover limit for the financial year 2019-20 for filing of GSTR 9 (Annual Return) and GSTR 9C (Reconciliation Statement) are mentioned below:

S. No. Turnover  GSTR 9 GSTR 9C
1 Turnover up to 2 crores Optional Not Applicable
2 Turnover more than 2 crores but up to 5 crores Applicable Not Applicable  
3 Turnover more than 5 Crores Applicable Applicable

Due Date, Late Fee, And Penalty

The due date for filing GST Annual Return (GSTR 9) for a financial year is the 31st of December of the year following the financial year. For instance, the due date to file GSTR-9 for FY 2019-20 is 31st December 2020. However, the due date of GSTR-9 & GSTR-9C for FY 2019-20 has been extended up to 31st March 2021.

Non-filing of the GSTR 9 within the due date can attract a late fee of Rs. 100 per day, per Act. In other words, if GST annual return is not filed within the prescribed period, a late fee of Rs. 100 may be charged under the CGST Act. Also Rs. 100 under SGST Act will be charged amounting to a total liability of Rs. 200 per day subject to a maximum of 0.25% of the turnover of the taxpayer in the relevant State or UT.

CBIC Notification

Considering the problems being faced by the taxpayers in meeting the filing and after continuous demand from industry experts and business enterprises, the government has finally accepted the request to simplify the form. Now a simplified form is used for filing annual GST return GSTR 9 and GSTR 9C and provides further time to the taxpayers for furnishing of GST annual return. 

Update as of 28th February 2021

The due date of GSTR 9 and GSTR 9C for the financial year 2019-20 has further been extended by the government from 28th February 2021 to 31st March 2021. Also, several parts of the form have been simplified or have been made optional to provide relief to taxpayers.

Update as of 1st February 2021: Budget 2021

Section 35 and 44 of the CGST Act, 2017 has been amended by the government to remove the audit requirement mandated under the CGST Act by certain specified professionals such as Cost Accountants and Chartered Accountants. According to this amendment, now the taxpayer needs to file GSTR 9 annual return on a self-certification basis through the GST common portal, removing the requirement of GST audit (GSTR-9C) entirely. 

However, the government is yet to clarify the date of applicability of this amendment.

Update as of 30th December 2020

The due date for GSTR 9 and GSTR 9C for the financial year 2019-20 has further been extended by the government to 28th February 2021 from 31st December 2020.

All About Simplification Of GSTR 9 (Annual Return) And GSTR 9C (Reconciliation Statement)

The taxpayers were facing several issues in filing the GST annual return (GSTR 9), and after the outbreak of the COVID 19 pandemic, it became even more difficult for the taxpayer to meet the requirements. Also, representations were made from the industry and professionals about simplification of the filing of GST annual returns. So, to provide relief to the registered taxpayer, the government has simplified the filing of Form GSTR 9 and GSTR 9C.

This write-up is an endeavour to explain the CBIC notification regarding the simplification of the annual return and reconciliation statement forms vide Notification No. 56/2019 – Central Tax dated 14th November 2019, in a simple and easy way. The government has simplified and brought the following changes in form GSTR 9 (Annual Return) and GSTR 9C (Reconciliation statement).

Let’s have a quick overview of the simplification and changes in GSTR 9 (Annual return) and GSTR 9C (Reconciliation Statement) through a summarized table.

Also Read: A Guide to Filing GST Annual Returns (GSTR-9)

FORM GSTR 9

      Table Particulars Changes in F. Y. 2019-20
         4 Details of inward supplies, outward supplies, and advances made during the financial year by a registered taxable person The option has been provided to registered taxpayer to fill the details in Table 4B to 4E, net of credit/ debit notes and amendments, rather than reporting separately
         5 Details of Outward supplies made during the financial year without payment of tax             instead of reporting separately, in table 5D the taxpayer is provided with an option to declare a total figure under “exempted” supplies, 
         6 Details of ITC availed during the financial year.             The taxpayer is provided with an option to disclose input tax credit under the “input” row only, no separate break up for input and input services is needed. However, input tax credit on Capital goods is required to be disclosed separately.
         7 Details of ITC Reversal during the financial year         Option to disclose details of tables 7A to 7E under 7H (Other reversal). However, ITC reversals because of TRAN-I (Table 7F) and TRAN-II (Table 7G) shall be mandatorily disclosed.
         8 Other information related to ITC In table 8A to 8D, the taxpayer has provided an option to report the details of ITC availed in PDF format in GSTR 9C without certification by a CA. However, no such option is available in F.Y. 2019-20
         9 Details of taxes paid during the financial year as reported in returns filed        Reported mandatorily
        10  Supplies/tax disclosed through Amendments ( ) ( net of dr. notes )           Transactions pertained to the previous year but were declared in the following FY (within a specified time) required to be disclosed here.
        11 Supplies/tax deducted through Amendments (-) ( net of Cr. notes )    Transactions pertained to the previous year but were declared in the following FY (within a specified time) required to be disclosed here.
        12  Reversal of ITC availed  Optional
        13 ITC availed for the previous financial year      Optional
        14 Differential tax paid due to declaration in 10 & 11 above No change
        15 Particulars of Refunds and  Demands           Optional
        16 Deemed supply under section 143, details of supplies received from composition taxpayers u/s 10 and goods sent on approval basis Optional
        17 Details of outward supplies (HSN Wise) Optional
        18 Details of inward supplies (HSN Wise) Optional

FORM GSTR 9C

The following table is made to summarise the changes made in simplified form GSTR 9C.

    Table Particulars Changes
       5 Turnover adjustments Optional adjustments, if any, to be made by a taxpayer in table 5O  
  12 & 14 Reconciliation of ITC         Optional

Here’s a detailed explanation of the changes brought by the government in simplified Form GSTR 9 (Annual Return) and GSTR 9C (Reconciliation Statement). Let’s discuss it in more detail: 

Simplified GSTR 9 And GSTR 9C With Optional Tables

FORM - GSTR 9

Part II - Table 4 and Table 5

Table 4 and Table 5 contain the particulars of details concerning the outward supply of the registered person.

Instead of reporting separately in tables 4I to 4L and 5H to 5K, the registered persons now have an option to disclose the details in Table 4B to 4E, net of debit and credit notes and amendments, if any.

The registered persons now have an option to declare a total figure under “exempted” supplies in table 5D, instead of reporting exempt, nil rated, and non- GST supplies separately.

Part III – Table 6, 7 and 8

Part III contains the particulars of details concerning Input Tax Credit (ITC) availed during the financial year.

Table 6: Input tax credit availed during the year

The registered persons are given an option to declare the amount of input tax credit under the “input” row only, no separate break up into inputs and input services is needed. However, input tax credit on Capital Goods is required to be reported separately.

The registered persons shall have an option to report details of both tables 6C and 6D under table 6D only, which implies no break up is required for the inward supplies received from registered and unregistered persons on which ITC is availed, and liability is discharged on a reverse charge basis.

Table 7: ITC Reversal

The registered persons shall have an option to declare the details of tables 7A to 7E under table 7H, which means now, the taxpayer, can report the total amount of ITC reversed under “other reversal” in table 7H. 

However, details of table 7F and 7G regarding reversals of ITC because of TRAN-I and TRAN-II shall be compulsorily required to be reported separately.

Also Read: A Brief Guide To Reverse Charge Under GST

Table 8: Other Information Related to ITC

The amount of ITC will be auto-populated based on GSTR 2A filed by the supplier of the taxpayer. The registered person can get invoice–wise details by clicking on table 8A. 

For the financial year 2017-18 and 2018-19, the option has been given to the registered person to upload the details of ITC availed in PDF format in GSTR 9C in table 8A to 8D, without certification by a Chartered Accountant. Table 8A to Table 8D aims to compare the detail of ITC availed as per books of accounts and ITC available as per GSTR 2A.

However, no such option is available for the financial year 2019-20.

Part IV – Table 10 to 14

Part V contains details for the previous financial year disclosed in returns of the succeeding financial year shall be reported under Tables 10 to 14.

In Part V, where details of transactions pertained to the previous year for which tax was paid in Form GSTR 3B, are required to be disclosed, for FY 19-20, the transactions between April 2020 and September 2020 are to be declared.

In addition to that, the government has made the following tables optional for the registered taxpayer:

Part V Particulars of the transactions for the previous Financial year reported in the current FY
Table 12 Reversal of ITC availed during the previous financial year
Table 13 ITC availed for the previous financial year
Table 14 Differential tax paid on because of declaration in 10 & 11 above

Part VI – Table 15 to 18

The government has made tables 15 to 18 optional for the registered taxpayer. The registered taxpayer has now an option to not report the details in tables 15 to 18 for the financial year 2019-20.

Part VI Particulars of details
Table 15 Particulars of Demands and Refunds
Table 16 Deemed supply under section 143, details of supplies received from composition taxpayers u/s 10 and goods sent on approval basis.
Table 17 Details of outward supplies (HSN Wise)
Table 18 Details of inward supplies (HSN Wise)

Also Read: GSTR 9: Annual Return Filing, Format, Eligibility and Rules

FORM - GSTR 9C

The following changes made in form GSTR 9C:

It has been made optional for the registered taxpayer to not fill the particulars of details of turnover adjustments that were required to be made in tables 5B to 5N. A registered person can make adjustments, if any, in Table 5O.

The registered person is provided with the option not to report the details in tables 12 and 14, which is about the reconciliation of the input tax credit of the taxpayer.

There is a minor change in the declaration portion of form GSTR 9 where the word “true and correct” has been substituted by the word “true and fair” before signature and seal /stamp.

Now, it is not mandatory to upload the Cash Flow Statement. It has now been made optional for the registered taxpayer.

A registered person has an option to not report the particulars of details under table 14 – the reconciliation of input tax credit in GSTR 9 with input tax credit availed on expenses as per books of accounts or audited financial statement.

Also Read: A Guide to Filing GST Annual Returns (GSTR-9)

Conclusion

In this write-up, we have discussed the provision in CGST Act, 2017 regarding GST annual return, the turnover limit of complying with the provisions, filing of GSTR annual return, and recent changes made by the Ministry of finance in Form GSTR 9 and GSTR 9C to provide relief to registered taxpayers. We have tried to explain the provisions and amendments in the easiest way possible. We hope the article will be useful for you to understand the basic provisions regarding GST annual return and recent amendments by the government in Form GSTR 9 and GSTR 9C.  

Frequently asked questions:

Who is liable to file GSTR 9?

Ans. All registered taxpayers are required to file GSTR 9 irrespective of turnover except:

  1. Casual Taxable Person
  2. Non- resident taxable person
  3. Input Service Distributors
  4. Taxpayers registered under section 51 or 52 for deducting/ collecting tax at source.

What is the eligibility criteria to file a “NIL” GSTR-9?

Ans. Assessee can file NIL GSTR-9 annual return only if the criteria stated below are met for    that financial year:

  1. No outward supply
  2. No receipt of goods/services
  3. No other liability to report
  4. No ITC claimed
  5. No refund claimed
  6. No demand order received
  7. No late fees to be paid  

A sales figure that was originally reported as B2C sales in GSTR- 1, was later corrected to B2B sales, how should the reporting be done?

Ans. Details of both B2B and B2C supplies are required to be reported in Table 4. In this case, the assessee has to report the correct classification in GSTR-9 even though it was wrongly reported earlier.

Are stock transfers within the same PAN included in aggregate turnover?

Ans. As per Section 2(6) of the CGST Act, the term aggregate turnover includes inter-state supplies of persons having the same PAN. So, Yes stock transfers under the same PAN will be included in aggregate turnover.

How to reverse the ITC while filing GSTR-9 when we have not done any reversal of ITC in GSTR-3B in the past?

Ans. If the assessee has missed any reversal of ITC in the past months GSTR 3B, the same can be done in subsequent months GSTR-3B. It should be correctly reported in GSTR-9 in Table 7 and excess liability created due to such reversal should be paid off. 

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