CA. Ritesh Mittal, Bcom, FCA, LLB, DISA(ICAI), Insolvency Professional Nellore Branch of SIRC of ICAI - 15th August 2018 CA. Ritesh Mittal, Bcom, FCA, LLB, DISA(ICAI), Insolvency Professional

  AUDIT UNDER GST

GST AUDIT Sec 35 (5) of CGST Act 2017 : Every registered taxable person whose turnover during a financial year exceeds the prescribed limit [Rs 2 crore] shall get his accounts audited by a chartered accountant or a cost accountant.

Return forms still not notified Sr. No Form No Nature of Return Due Date 16 GSTR 09 Annual Return 31st Dec of next F.Y 17 GSTR 09A Annual return by Compounding taxable persons registered under section 10 18 GSTR -9B Annual statement by Every electronic commerce operator required to collect tax at source under section 52 19 GSTR-9C Reconciliation statement

Annual Return – GSTR 9 & 9A Reconciliation Statement in 9C Due date is 31st December of following year. GSTR 9A is for compounding dealers and GSTR 9 is for other dealers.

Annual Return – GSTR 9 & 9A Reconciliation Statement in 9C Reconciliation Statement duly certified by Chartered Accountant or Cost Accountant – GSTR 9C As per section 42, every registered shall get his accounts audited by CA or CMA and submit reconciliation statement in GSTR 9C. Due date is 31st December of subsequent financial year. Every registered person whose aggregate turnover during a FY exceeds two crore rupees shall get his accounts audited as specified under section 35 (5) and he shall furnish a copy of audited annual accounts and a reconciliation statement, duly certified, in FORM GSTR-9C, electronically through the Common Portal

Audit as per cgst act Section 2 (13) “audit” means the examination of records, returns and other documents maintained or furnished by the registered person under this Act or the rules made thereunder or under any other law for the time being in force to verify the correctness of turnover declared, taxes paid, refund claimed and input tax credit availed, and to assess his compliance with the provisions of this Act or the rules made thereunder;

Monthly Return under GST regime GSTR 2A sec 38(1) GSTR-2 – Sec 38 (2) GSTR-1 Sec 37(1) 15th of next month(Inward Supply) 1.Accept/reject/modifying details from GSTR-2 2. Add missing purchase invoices 10th of next month details of outward supply Auto-populated based on details from GSTR-1 filed by supplier  Sec 43 (2) Reduction in output tax liability of Supplier Sec42 (2) Finalization of ITC in Recipient's ledger GSTR-3 Sec 39 (1) GSTR-1A - Sec 37(2) Matched transactions 20th of next month Generate net tax payable or c/f Approve or reject the modification done by Receiver – 16th and 17th Sec 42 & 43 Matched Matched Unmatched Sec 37 (3) & 38 (5) to be added in outward Liability of Recipient with interest in GSTR 3 of the Month Succeeding in which discrepancy is made available Reconciliation of unmatched transactions in succeeding Month of Discrepancy available Unmatched Sec 42 Discrepancies not rectified Reduction in output tax liability by credit Notes not rectified - to be added in outward Liability of Supplier with interest in GSTR 3 of the Month Succeeding in which discrepancy is made available Unmatched Sec 43 Discrepancy is made available by Month end

rectification of 3B Circular No. 26/26/2017-GST It is clarified that as return in FORM GSTR-3B do not contain provisions for reporting of differential figures for past month(s), the said figures may be reported on net basis alongwith the values for current month itself in appropriate tables i.e. Table No. 3.1, 2, 4 and 5, as the case may be. It may be noted that while making adjustment in the output tax liability or input tax credit, there can be no negative entries in the FORM GSTR-3B.  The amount remaining for adjustment, if any, may be adjusted in the return(s) in FORM GSTR­3B of subsequent month(s) and, in cases where such adjustment is not feasible, refund may be claimed. Where adjustments have been made in FORM GSTR-3B of multiple months, corresponding adjustments in FORM GSTR-1 should also preferably be made in the corresponding months

CBIC Notification dated 10.08.18 GSTR1 and GSTR3B continues till 31.03.2019 Due dates Monthly GSTR1 - by 11th of next month (from July 18 to Mar 19) Quarterly - 31Oct/31Jan/30Apr GSTR3B - 20th of next month

difference between gstr 3b, gstr 1 & GSTR 2A Outward Supply (Sale) Sale Amount Difference More in GSTR 1 and less in 3B or vice versa Input Tax Credit Input Tax Credit amount Difference More in 3B and Less in GSTR 2A or vice versa

Audit of Outward supplies

turnover declared Reconciling the total summary figures as per GSTR 3B with the total of the Outward Invoices as per GSTR 1 for a particular month. Outward supplies (other than zero-rated, nil rated and exempted),  Zero-rated outward supplies, Nil rated and exempted outward supplies And Turnover as per Books of Accounts

ITR – 4 receipts as per gst Information relating to the GST Number and the Turnover/Gross Receipt as per GST return filed. It should be ensured that the details provided are verified correspondingly with GST Returns, if applicable and also with Form 26AS.

Outward Supply Reconciliation Statement Comparison Between GSTR 3B, GSTR 1 & Books of Outward Supplies

Outward Supplies - taxable sample reconciliation statement APRIL MONTH INVOICES S.No Date Invoice No Party Name GSTN No Amount GSTR 1 Status GSTR 3B Status    April

Outward Supplies sample reconciliation statement monthwise summary Description Jul 2017 Aug 2017 Sep 2017 Oct 2017 Nov 2017 Dec 2017 Jan 2018 Feb 2018 Mar 2018 Total Taxable Value GSTR 1 (1)   0.00 Taxable Value (3B) Taxable Value - Books Taxable Value (Diff.) 1 & 3B Taxable Value (Diff.) 3B & books Taxable Value (Diff.) 1 & books

Similar Tables can be prepared for Zero Rated, Nil Rated and Exempted supplies

Outward Supplies Other Areas Check the invoice format is as per GST Rules – Sample Check Verify the e-way bills, if any issued with invoices. Ensure that the assessee complies with e-way bill provisions Match e-way Bills with Purchases and Sales

Audit of Inward supplies (ITC)

Tran 1 & Tran 2 Credit Review of TRAN-1, TRAN-2 filed This is to be confirmed with what was eligible and if any excess availed to be reversed. If short availed disclosure could be made as last date is over.

Invoice Validity All invoices where credit has been taken are available for verification and preserved properly. Invoices Should be in Original

Review GSTR 3B and GSTR 2A. [Reconciliation to be provided by Auditee]

Details of inward supplies GSTR 2

Details of inward supplies GSTR – 3B

Schedule GST To be filled up by the assessee who is not liable to get accounts audited u/s 44AB in ITR 6 – and in New Tax Audit Report

But since GSTR – 2 was not filed and 3B Required Consolidated data getting the data for the table is a challenge

Inward Reconciliation Statement Comparison Between GSTR 2A, GSTR 3B & Books of Inward Supplies

inward Supplies sample reconciliation statement APRIL MONTH INVOICES S.No Date Invoice No Party Name GSTN No Amount GSTR 2A Status GSTR 3B Status  

Outward Supplies sample reconciliation statement monthly summary Description Jul 2017 Aug 2017 Sep 2017 Oct 2017 Nov 2017 Dec 2017 Jan 2018 Feb 2018 Mar 2018 Total Taxable Value GSTR (2A)   0.00 Taxable Value (3B) Taxable Value – Books Taxable Value (Diff.) 2A & 3B Taxable Value (Diff.) 3B & books Taxable Value (Diff.) 2A & books

Similar Tables can be prepared for Composition Scheme, Nil Rated, Exempted and Non-GST supplies

Audit of ITC Reversal

Details of inward supplies GSTR 2 Till Column 11 , Data is auto Populated from GSTR 2A

From the Total ITC Available Remove Ineligible credits or Blocked Credits under section 17(5) Available ITC

GSTR 2

Reversal of input tax credit due to non-payment in 180 days A recipient has to pay the invoice amount and GST to the supplier within 180 days from issuance of the invoice. If he fails to make the payment, the input tax credit will be reversed and added to the output tax liability Points to check Difference between invoice date and payment date – It shouldn’t be more than 180 days Payment amount should be equal to invoice amount plus GST. If the payment amount is less than invoice amount plus GST, then input tax credit to the extent of short payment has to be reversed.

37. Reversal of input tax credit in the case of non-payment of consideration 39 (i) (j) (ii). Procedure for distribution of input tax credit by Input Service Distributor Rule 42. (1) as per Sec 17 (2) (1) : Partly used for the purposes of business and partly for other purposes,

Review of credit apportionment in case of supply of taxable and exempted supplies: The capture of credit specific to each and only the common credits being allocated is a preferred way forward. Review of credit availment in case of assets put partially for non-business /non-taxable use: The reversal for personal use needs to be confirmed.

Chartered Accountant and Insolvency Professional THANK YOU CA. Ritesh Mittal Chartered Accountant and Insolvency Professional 09885377421 mrriteshmittal@gmail.com