written by Khatabook | June 28, 2021

GSTR 9 Due Date Extended: Common issues faced by CAs while filing GSTR 9

What is the GSTR-9 due date?

For filing GSTR 9, last date is December 31 of the year following the particular FY, like for FY 2020-21, it is December 2021, and for FY 2021-22, it will be December 2022. But at taxpayer’s requests, the government gives some extensions to the due date as done for FY 2018-19 and FY 2019-20. 

For FY 2019-20, the government extended the due date to file GSTR 9 & GSTR 9C to 31st March 2021 from February 28, 2021. Again, due to the difficulties faced by CAs and taxpayers in filing GST returns for FY 2019-20, the government extended the deadline for the second time by a month till March 31, 2021. Similarly, the GSTR 9 due date for FY 2017-18 and 2018-19 has been extended several times.

Common challenges faced by CAs in Filing GSTR9

Before understanding the problems and challenges faced in filing GSTR 9 and the need for GSTR 9 extension, first, let us learn the basics of the GSTR 9, GSTR 9C, and the need of CAs for GST audit: 

What Do GSTR 9 And GSTR 9C Mean?

The GSTR 9 annual return is filed yearly by the taxpayers registered under the GST (Goods and Services Tax) Regime. Moreover, it has all details of outward and inward supplies delivered or collected under separate tax heads. It needs to be filed before the GST annual return last date. 

GSTR 9 form consists of 6 parts and 19 sections. The taxpayer must fill in each part with the details previously filled in its returns and books of accounts. It is a summarized copy of the taxpayer's monthly returns in simpler words.

On the other hand, GSTR 9C is a combined statement of the audited annual financial statement and GSTR 9.

Also Read: GST Return Late Fee & Interest Calculator Online

Who Should File GSTR 9 or GSTR 9C?

All taxpayers having an aggregate annual turnover of above INR 2 crore must file the annual return before the GST annual return due date. Whereas, taxpayers with an aggregate turnover of above INR 5 crore need to file GSTR 9C.

GST Audit and Requirement of CA

Every taxpayer with an annual turnover of over INR 2 crore needs to do the GST Audit either by a Chartered Accountant or a Cost Accountant. This GST Audit matches the Audited Financial Statements and turnover declared by the taxpayer in the annual return. The process is lengthy, inconvenient, and time-consuming.

2020 was a very difficult period for most businesses and industries due to the pandemic. This is why they requested the government for GST annual return extension. Both CAs and taxpayers faced challenges in filing the complex GSTR 9 form for FY 2019 -20. These due date extensions gave them some relief. Read on further to learn the issues faced by CAs that led to the GST annual return due date extension.

Common challenges faced by CAs

Mismatch In Input Tax Credits Of Table 8A of GSTR 9 and GSTR-2A 

What if there is a mismatch between the ITC appearing in the GSTR-2A return and the ITC in table 8A of the GSTR 9? There could be many reasons behind this mismatch in ITCs. These are points of concern for both CA and the taxpayer. They were a bit relieved when the GST annual return date extended. A few of the causes that can lead to this kind of mismatch are:

  • The gross (total) values appearing in the GSTR-2A and the final figures produced after taking care of the modification in GSTR 9.
  • ITC of supplies done in FY 2017-18 will not be auto-generated in GSTR 9, if these were declared after 30 April 2019.
  • ITCs that are related to invoices made during the period of the Composition Scheme do not get generated in GSTR 9.
  • Input tax credits for the invoices do not get generated in GSTR 9 when the supplier state and recipient’s state are different.

Detailed Division Needed For ITCs in GSTR 9 and GSTR 9C

GSTR 9 asks for a declaration of annual sales as well as annual purchases. These details have to be divided into inputs, input services, and capital goods. It also needs detailed ITC details, which is a complex process. This process is performed by a CA who performs thorough analysis and verification of the accounts books of the taxpayer to avoid any mismatches. But if the taxpayer has not kept a record of this, it gets really difficult to file the correct GSTR 9 form before the GSTR 9 due date.

GSTR-2A Not Reflecting Input Tax Credit Claimed

The GSTR-2A of FY 2017-18 of several taxpayers are not reflecting the ITCs claimed by them in their GSTR-3B. However, they are eligible under the CGST Act. This issue brings challenges for CAs in filing the annual returns before the GSTR 9C due date. They are uncertain whether these input tax credits will become ineligible and create more problems for the taxpayers in near future.

ITC is claimed in FY 18-19 for the goods imported in FY 17-18

However, table 6(E) of GSTR 9  is assigned for the input tax credits related to the imported purchases done between July 2017 and March 2019. There is still confusion regarding the input tax credits claimed in FY 2018-19 for the purchases of imported goods done in the previous FY 2017-18. 

If GSTR 9 form had a separate section for these kinds of declarations, it would be easier for CAs and taxpayers both to prepare a combined statement. That could be also done before the GST audit due date more accurately and easily. 

Confusion between Table 6(B) and 6(H)

Table 6(B) asks for the declaration of all inward supplies (purchases and expenses) and ITC availed during a particular financial year, excluding imports and inward supplies accountable for a reverse charge. 

On the other hand, Table 6(H) asks for the declaration of ITCs that were availed, reversed, or redeemed for the same financial year. 

At times these declarations result in the overlapping of figures between two tables of 6(B) and 6(H). Thus, more clarification is needed to sort out the challenges faced and fill the forms before the GSTR 9 due date.

Also Read: Types of GST Returns: Forms, Due Dates & Penalties

Confusions Regarding The Declaration of RCM Liability in GSTR 9

CBIC issued a press release on 4th June 2019 regarding the disclosure of liability under RCM and used the term ‘additional outward supply’. Whereas, the Central Tax Department released an advisory on 28th June 2019 using the term ‘additional liability’ for the same RCM liability. 

These differences created troubles for CAs as taxpayers needed to declare the sum of such undisclosed liabilities under table 4(G) of GSTR 9. However, the corresponding tax portion of such liabilities needs to be disclosed under ‘Tax Payable’ in table 9. Thus, the GSTR 9 due date extension notification brought relief for both as they got more time for solving the issues.

HSN summary details for all outward and inward supplies

Every supplier with a turnover of over INR 1.5 crore has to declare a detailed HSN “Harmonized System of Nomenclature” wise summary in GSTR 9 for both inward and outward supplies. This is indeed a tedious task for the suppliers who were not habitual in maintaining such kinds of records and caused unnecessary hassles for them. It is time-consuming and requires additional effort and IT skilled manpower. This is one of the major reasons why CAs wanted the GSTR 9 date extended.

Confusions regarding Table 4F of GSTR 9

However, Table 4(F) of the GSTR 9 asks for the declaration of all transactions for which the taxpayer does not have invoice records but has paid the taxes. As per the instructions given by the government, the information in this table should be from table 11(A) of GSTR-1

But this is possible for monthly level entries only. For annual level declarations, adjustments made during the whole year had to be counted. That means the information for table 4(F) should also be taken from table 11(B) of GSTR-1.   

A Time-consuming And Difficult Process of GSTR 9C

GSTR 9C is a reconciliation (combined) statement summarising the Audited Financial Statements and turnover declared in the annual return. This reconciliation process is challenging as it may need multiple items to be added. 

Additionally, uploading GSTR 9C is again a difficult process as it needs several technical and time-consuming steps. Other than this, the word limit in the address and qualification columns of the statutory auditor does not let them enter their details accurately.  

Other Common Issues Faced By CAs While Filing GSTR 9

  • While negative values are allowed in tables 5(M), 5(N), and 5(O) of GSTR 9/9C, these do not affect generating the JSON file. But, GSTN does not accept the same and creates a problem for the CA.
  • However, if JSON gets generated and no error message is reflected, the file does not get uploaded.
  • Many times, 2 final PDF copies of the GSTR 9 filed return get generated, which is an issue yet to be resolved by the GSTN portal.
  • The DRC-03 form formalities are completed but are not reflecting on its portal.
  • The expense ledger in GSTR 9C requires splitting of details which is a very time-consuming process and seems irrelevant in most cases.

Also Read: 

Conclusion

The Government of India introduced the Goods and Services Tax Act (GST) across India on 1st July 2017 to bring about regularity in the indirect tax laws. The regular taxpayer must file the annual GST return form GSTR 9. It includes combined details of all inward plus outward supplies, taxes, refunds, and ITCs availed during a particular fiscal year. 

Although, filing a GSTR 9 or GSTR 9C form is an online process but not an easy one for taxpayers and their CAs. They face multiple challenges while using the online system and even while tallying the books of accounts and records. Due to these issues, the government has given GSTR 9 date extension twice to ease their pressure and get the error-free return filing.

Also Read: GST Number Search: 15 Digits Every Business Needs

Frequently Asked Questions

1. What is GSTR 9? 

GSTR 9 is the annual return that has to be filed by all registered taxpayers under the GST Regime. It is an online form that requires the declaration of sales, purchases, taxes paid, refunds and ITC availed during a relevant financial year. It includes transactions done under different tax heads, including CGST, SGST, IGST, and HSN codes. 

2. Who needs to file GSTR 9?

All registered taxpayers under the GST Regime are required to file GSTR 9 leaving a few, including

  • Casual taxpayers
  • Non-resident taxpayers
  • Input Service Distributors
  • Taxpayers who deduct/collect tax at source (under Section 51 or Section 52)

Hence, irrespective of the annual turnover, every registered individual under the GST must complete the formalities of the annual GSTR 9 Return Filing before the due date to avoid penalties

3. What is the difference between GSTR 9 & GSTR 9C?  

GSTR 9 is an annual return needed to be filed by the registered taxpayers with a turnover of over INR 2 crore. On the other hand, GSTR 9C is a reconciliation statement comprising GSTR 9 and the audited account books. GSTR 9C has to be filed by those registered taxpayers who have a turnover of over INR 5 crore.

4. What is the due date to file GSTR 9 & GSTR 9C for the FY 2020-21?

The due date to file GSTR 9 & GSTR 9C for the FY 2020-21 is 31st December 2021. But the government can give some extensions due to Covid 19 and on the requests of the taxpayers or CAs as GSTR 9 due date extended by the government twice for FY 2019-20.

5. Why was the due date extended?

The due date for GSTR 9 filing for FY 2019-20 is extended by the government on the requests of the taxpayers and CAs. It was done based on the difficulties faced by them in business because of the pandemic.

6. What if the return is not filed on or before the due date?

If a taxpayer does not file the return before the last date of GSTR 9, he has to pay INR 200 per day as a penalty out of which INR 100 goes for SGST and INR 100 goes for CGST. 

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