1. GST Annual Return and Audit Service Sector perspective

2. Agenda Background Legal Provisions
Form 9, 9A & 9C in the context of service sector
Q & A

3. Background Reform vs disruption Role of technology
Focus on self compliance
Legal backing
Objective and importance of Annual Return & Reconciliation

4. Skipped GST Compliance process - then and now Due date Form Nature Who
10th of next month
GSTR-1
Invoice wise details for outward supply
Supplier
11th of the next month
GSTR-2A
Invoice wise details of inward supply
Recipient- Auto populated on GSTN
15th of next month
GSTR- 2
Invoice wise details of inward supply accounted in recipient books
Recipient- accept/reject/keep in abeyance or add details to GSTR- 2A
16th of next month
GSTR-1A
Correction/addition suggested by Recipient in GSTR-2
Supplier- changes proposed by recipient auto populated
17th of next month
Accept/reject the changes suggested by the recipient
20th of next month
GSTR-3
Monthly return
Supplier/Recipient
GSTR-3B
Summary Monthly return
31st Dec after end of FY
GSTR9/9A
Annual Return
GSTR 9C
Reconciliation and Certification by Chartered or Cost Accountant
Skipped

5. Legal Provisions
Section 44: Every registered person required to file before 31st Dec an Annual Return in Form GSTR9/ 9A ( composition payer) except
-Input service distributor
-TCS/TDS payer
-Casual taxable payer
-Non resident tax payer
Section 35 (5) & Section 44 (2)- Before 31st December every registered person having turnover more than Rs 2 Crs is required
-to get accounts audited by Chartered/Cost Accountant
- submit a reconciliation cum certification in Form GSTR 9C
Section 47: late fees of Rs 200 (per day CGST+SGST) and maximum upto 0.5% (CGST+SGST) of the turnover in the State

6. Prerequisites Consolidation of all GSTR-1 and 3 B returns filed
Matching of GSTR 2A with Input credit register
Break up inputs- inputs, input services and capital goods
Ineligible/blocked ITC and reversals including reclaims
TRAN- I and TRAN- II returns filed
Amendments, additions, deletions made to previous month returns during current FY and during Apr- Sept 18
HSN code wise – outward and inward supply
Breakup of purchases from – composition vendors, for job works and goods received on approval
Refunds filed, approved , rejected during July17 - Mar 18

7. Annual Return GSTR- 9 - decoded
Part I- Basic Details
- Financial Year, GSTIN etc
Part II - Details of outward and inward supply during the FY on which tax is payable
- Use GSTR-1 and 3B to populate Table 4 & 5
Part III – Details of ITC declared in return,
Table 6 –ITC declared
Use GSTR-3B
keep breakup of ITC availed into inputs, Input services & capital goods
Amount of ITC reclaimed under the Act
Keep TRAN-I & TRAN-II returns handy
Table 7 – Ineligible and reversed ITC
- Break up of ITC reversal due to non payment within 180 days, ISD, exempt/non business supply, reversal on Capital goods and negative list under section 17 (5)

8. Annual Return GSTR- 9 - decoded
Part III – ITC declared in returns
Table 8 – Other ITC related Info
- Exercise of matching of input credits availed with GSTR 2A must be carried out
- ITC availed need to be shown as gross (including availed and then reversed )
- ITC availed on invoices dated on or before 31st Mar 2018 booked during Apr- Sept 18
- Check carefully ITC available but not availed /not eligible
- Check IGST paid on import of goods and eligible credits availed.
Part IV- Tax paid as declared in return
Table 9- Paid through Cash and ITC credit
Part V- Transactions of previous FY declared during Apr-Sept 18
Table 10 – 13 - Additions, deletions and amendments
Table Differential tax paid due to 10-13

9. Annual Return GSTR- 9 - decoded
Part VI – Other Information
Table 15 - Information about refund applied/ approved ejected
Table 16 -Supplies received from Composition supplier, Principal for job work, goods sent on approval but not received.
Table 17 - HSN details outward supply
Table 18- HSN details Inward supply
Table 19 - Late fees payable and paid under Central and State tax

10. Reconciliation and certification in GSTR – 9C
Part I- Basic details
Financial year, GSTIN, info about audits carried under any other law
Part II – Reco. of TO as per financial statement with annual return
Table 5 Reconciliation of Gross Turnover (As per books to GSTR-9)
Adjustments due to unbilled revenue, unadjusted tax paid advances deemed supply, Credit notes issued, Forex fluctuations, difference due to valuation Rules etc.
Table 6 Reasons for unreconciled difference in Gross TO
Table 7 Reconciliation of Taxable TO
Need to consider Exempted, Nil rated, non GST, Zero rated supply also supplies on which tax is paid under reverse charge
Table 8 – Reasons for unreconciled difference in Taxable TO

11. Reconciliation and certification in GSTR – 9C
Part III- Reconciliation of tax paid
Table 9 Reco. of rate wise liability and amount payable,
both for forward and reverse charge
Interest, late fee, Penalties need to be considered
Table 10 Reasons for un-reconciled payment of amount
Table 11 Additional Amount payable but not paid
Part IV Reconciliation of Input credit
Table 12 Reco of net input tax credit
ITC of earlier FY claimed in Current FY, ITC booked in current FY to be claimed in Next FY
Table 13 Reasons for un-reconciled difference in ITC
Table 14 Reco of ITC declared in annual return with eligible ITC under expense heads of audited financial statement
Table 15 Reasons for un-reconciled difference in ITC
Table 16 Tax Payable on un-reconciled difference in ITC

12. Reconciliation and certification in GSTR – 9C
Part V Auditors recommendations on additional liability
On account of outward supply not reported, reverse charge not paid, excess/ineligible ITC claimed, excess refund claimed, interest, penalty, late fees and outstanding demands etc.
Part B- Certification
Where certification in GSTR 9C and audit of books of account is conducted by same auditor
Where certification in GSTR 9C and audit of books of account is not conducted by same auditor

13. Thank You