Form GSTR 9A - Due dates, Format and Online Filing

The GSTR-9A is an annual return that must be filed by small business owners who adopt the simplified composition system under the Goods and Services Tax (GST) regime. This return will include all of the composite dealers' data in their quarterly returns throughout the fiscal year. Such details normally consist of total supplies (sales) made by the business entity and total purchases during the year. It consists of tax payable on outward supplies and net tax paid after claiming the benefit of the Input Tax credit on purchases. It also comprises any refund of GST claimed by the business entity or GST paid for any demand raised by the GST department. However, GSTR-9A has been replaced with GSTR-4 from the financial year 2019-20.

Applicability and Conditions for filing Annual Return GSTR-9A

Annual Return GSTR-9A is applicable up to FY 2018-19. The GSTR-9A form has been phased out with effect from FY 2019-20 due to the introduction of GSTR-4 (Annual Return for Composition Tax Payers). But you must fulfill the following conditions to be eligible to file the Annual Return GSTR-9A: 

1. You must be a registered business owner who is a composition dealer, or in other words, you should have opted for a composition scheme, even if it is for a single day in a financial year.
2. Your business entity must have annual sales of less than Rs 75 lakhs or less than Rs 50 lakhs if you are doing business in the North-Eastern states.
3. You must keep account of all your business transactions, i.e., sales, purchase, export & import, etc., based on which you have filed your quarterly Returns.
4. You should have filed all quarterly Returns in Form GSTR-4 for the financial year before filing GSTR-9A.

Who all are not required to file GSTR-9A?

 The following persons are not required to file Annual Return GSTR-9A:

•  A regular taxpayer/business owner who has not opted for the composition scheme at any time during the financial year
• A non-resident taxpayer
• A person deducting TDS u/s 51
• An e-Commerce Operator who pays TCS u/s 52 
• A casual taxpayer
• An input service distributor  

If a person opts for two schemes in a financial year (i.e. regular as well as under composition scheme)

Suppose a person was a regular taxpayer for 3 months of a financial year, for instance, until June 2018 during FY 2018-19. And they opt for the composition scheme from July 2018. Then they are required to file two types of Annual returns, i.e. GSTR-9 for 3 months (April to June 2018) and GSTR-9A for the balance period of 9 months (July 2018 to March 2019). 

When is GSTR-9A Due Date?

• The business entity who has opted for the Composition Scheme must file an Annual Return in GSTR-9A by 31^st December for the financial year ended on 31^st March, i.e. FY 2017-18.
• The last date for filing GSTR-9A is 31.12.2018. 
• There is a late penalty of Rs. 100/- per day for Central Goods and Services Tax (CGST) and Rs. 100/- per day under SGST or UTGST as well.
• For State Goods and Services Tax (SGST), the total penalty is Rs. 200/- per day. 
• However, the maximum late fee cannot exceed 0.25% of Turnover in the State or Union territory under CGST/SGST/UTGST. 
• GSTR-9A has been discontinued from FY 2019-20 after introducing the Annual return in form GSTR-4 . Now, GSTR-4 needs to be filed up to 30^th April after the close of the financial year.

Revision of GSTR-9A after filing

Form 9A GST cannot be revised after filing. Hence the taxpayer should file it carefully and must preview it thoroughly before submitting it on GST Portal. 

Format of GSTR-9A

The GSTR-9 is divided into five parts containing the following details:-

Part I: The first part requires the taxpayer to fill in the basic data like Goods and Services Tax Identification Number (GSTIN), legal name, and trade name, auto-generated. It also contains the Previous Year Turnover and period for business entities that have adopted composition schemes.

Part II: These parts contain a thorough listing of inward and outward supplies that have already been reported in GSTR 4 for the current fiscal year. It acts as a blueprint for all of the information included in the quarterly reports (GSTR-4 / CMP-08); or other words, it can be said that it is a summary of quarterly returns filed earlier.

Part III: It covers all information on the tax amount reported on taxpayers' returns during the fiscal year. This comprises the amount of tax paid under several headings, such as CGST, IGST, SGST, penalty, late fee, additional demand, etc.

Part IV: The purpose of this section is to know the details about the last year’s transaction reported between April to September in the immediately succeeding year or up to the date of filing of Annual Return of last year, whichever is earlier. Since many additions, deletions, or rectifications relating to the previous year’s transactions are reported during this period. Hence, the GST authorities want to know the exact details of the same through this section.

Part V: This section covers information on taxes paid, and refunds claimed in great depth. It also contains information about how much tax was due and paid after adjustment of Input Tax Credit (ITC) and the balance amount of tax still payable by a taxpayer. The taxpayer needs to disclose the amount of GST refund claimed and received and the pending amount of refund. Input Tax Credit (ITC) must be changed if a taxpayer switches from a composition scheme to a normal plan. This information needs to be disclosed as a part of the ITC statement. 

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

When to file NIL GSTR-9A?

Any taxpayer can file NIL GSTR-9A if the following conditions are fulfilled:-

1. Has not made any sales (outward supplies), and thus there is no GST payable.
2. Has not made any purchases (inward supplies), and thus no Input Tax Credit is available.
3. Has not claimed any refund of GST.
4. Has not paid any GST by means of late fees or penalties or any other demand of the GST department.
5. Has not received any order from the GST department asking for a deposit of any amount of Tax or Penalty or Late Fees or Interest etc. In other words, no demand of any type has been made by the GST department from him, and nothing is payable by him to the GST department.

Important Steps after filing GSTR-9A on GST Portal

Once the Annual return in Form 9A of GST has been submitted on the GST portal (www.gst.gov.in), the following steps should be followed as they are quite important for every taxpayer:-

1. Acknowledgement Registration Number (ARN) is generated by the GST Portal after submission of GSTR-9A successfully on the official website. It needs to be saved/stored or kept by the Taxpayer in hard copy by taking a printout of the same.
2. A system-generated email is sent to the registered email id of the Taxpayer, which should be saved in soft copy or hard copy by the Taxpayer.
3. Similarly, a system-generated SMS is also sent to the Registered Mobile No. of the Taxpayer, which again should be saved by the taxpayer.
4. The Annual Return form GSTR-9A, thus filed by the Taxpayer, is available for view/download in PDF and Excel format.
5. The Electronic Cash Ledger is also updated if any demand, like late fees etc., has been adjusted/paid through it at the time of filing of GSTR-9A.

Filing of GSTR-9A is made optional for certain Tax Payers

The filing of Annual Return Form GSTR-9A has been made optional by the GST Council in its 37^th Meeting for the following categories of Taxpayers:-

1. For FY 2017-18 and 2018-19, small taxpayers with turnover up to Rs. 2 crores, may or may not file Annual Return GSTR 9A. Kindly read GST Notification no. 47/2019-Central Tax, dt. 09-10-2019.
2. It is pertinent to mention the optional filing of Annual return GSTR-9A by small taxpayers as clarified by the Govt. through circular no. 124/2019 dt.18.11.2019. If the composition dealer opts to file GSTR 9A for the above period, they must file it before the due date. The Govt. Website (www.gst.gov.in) or GST portal does not allow filing this return GSTR-9A after its due date. 
3. This notification can mean that if the return is not filed on or before the due date, it will be considered to have been filed.

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

Conclusion

Although GSTR 9A has been replaced with GSTR 4, it's important to know about the fundamentals of this annual returns form. Hope this article serves the purpose of clarifying the Annual Return GSTR-9A and its applicability on the Composite Dealers, along with the information regarding GSTR 9A Due Date and GSTR 9A Format.

Download the Khatabook App for regular updates regarding GST.