1. Annual Returns Data Flow in GSTR 9 and 9C
Demystified
Data Flow in GSTR 9 and 9C
GST & Indirect Taxes Committee
Hosted by : EIRC - ICAI
CA Venugopal Gella
Venu and Vinay
Chartered Accountants

2. Investments into Mutual funds are subject to Market Risk
Disclaimer
Investments into Mutual funds are subject to Market Risk
So is Preparation of GSTR 9 with some Auto populated Number
GSTR 9 is both Science and an Art

3. Different Members
Different Views
Different Speakers
Different Views

4. GSTR 9
Annual Return

5. Annual Return & Annual Audit
Section 44(1) requires every registered person,
other than an Input Service Distributor, TDS /TCS / CTP / NRTP
shall furnish an annual return for every financial year electronically
in such form and manner as may be prescribed
on or before the thirty-first day of December following the end of such financial year.
Notification 39/2018 on 4th Sept Notification 74/2018 on 31st Dec
Section 35 (5) Every registered person whose turnover during a financial year exceeds the prescribed limit(2crores) shall get his accounts audited by a chartered accountant or a cost accountant and shall submit
a copy of the audited annual accounts,
the reconciliation statement under sub-section (2) of section 44 and
such other documents in such form and manner as may be prescribed

6. Annual Return – GSTR-9ABC
Registered Person: Rule 80(1)
GSTR 9
Composition Dealer : Rule 80(1)
GSTR 9A
TCS : Rule 80(2)
GSTR 9B
Audit TO > 2 crores : : Rule 80(3)
+ GSTR 9C
Annual Returns
Not Applicable
ISD /TDS
CTP /NRTP
For FY ; file by 30 Jun 2019 – Order No.03/2018
Rule 21 of Return rules talk about annual return

7. Points to Note on Annual Returns
Period Coverage : 1st July 2017 to 31st March 2018
Mandatory Filing of : FORM GSTR-1 and FORM GSTR-3B for the FY
Late Filing Fees : Rs. 100/- per day per Act (CGST + SGST/UTGST), subject to a maximum amount of (0.25% CGST % SGST/UTGST) of the turnover in the State.
Notice for Non filer : Sec 46 read with Rule 68, A notice in FORM GSTR-3A shall be issued with in fifteen days, electronically, to a registered person who fails to furnish return under section 44.
Thresh hold Limit : All Registered Tax payers even if the turnover is NIL shall file.
PAN / GSTIN : This is not an Entity Level reporting, its GSTIN based filing.
Revision of GSTR 9 : Once Filed this form cannot be revised

8. NIL GSTR 9 NIL GSTR 9 can be filed, if you have
Not made any outward supply (commonly known as sale); AND
Not received any inward supplies (commonly known as purchase) of goods/services; AND
No liability of any kind; AND
Not claimed any Credit during the Financial Year; AND
Not received any order creating demand; AND
Not claimed any refund during the Financial Year

9. Annual Return – Informative
The Annual return is an informative return in which one has to furnish information of what happened in the past and cannot be used for taking an action on account of :-
Payment of Taxes
Claiming of Refunds
Availment of ITC
Reversal of ITC
Post filing of Annual returns there will be NO impact on
Electronic Liability Ledger
Electronic Cash Ledger
Electronic Credit Ledger

10. Understanding ROD 02/2018 Time Limit Sec 16(4) ITC Sep 2018 Mar 2019
Sec 37(3) GSTR 1
Sec 39(9) ~ GSTR 3B
Note: Sec 39(9) : Amendments to Monthly Returns. GSTR3 further made as GSTR3B is not amended. Any Changes in liability for last date to correct thru 3B is only Sept Circular 26/2017 stops by Sept 2018 subsequent correction cannot be thru GSTR 3B
Option Available
1) Short Paid: Pay thru DRC 03
2) Excess Paid : File Refund
Original Provision>>>
After ROD 02/2018>>

11. Changes after ROD 02/2018 Due dates have changed for
Availment of ITC extended till March 2019
Reporting of any missed out transaction in GSTR 1 is extended till March 2019
Due dates did not change for
Corrections permitted through 3B
Issue of Credit Note u/s 34 is still Sept
Payment of Any missed out tax liability is Sept 2019
Missed deadlines pay through DRC 03
Taxes Not Paid or Short Paid
Reversal of ineligible ITC

12. In eligible ITC claimed
Payment through DRC 03
Additional Liability
Short Payment of Taxes
Pay thru Cash
Excess ITC claimed
Pay thru ITC
In eligible ITC claimed

13. Understanding Form GSTR 9
Annual Return

14. Annual Return – GSTR 9 :: 6 Parts 19 Tables
Part I
Basic Info
Table 1-3
Part II
Liability
Table 4-5
Part III
Input Tax Credit
Table 6-8
Part IV
Tax paid details
Table 9
Part V
Circular 26/2017
Adjustments
Table 10-14
Part VI
Other info
Table 15-19
Rule 21 of Return rules talk about annual return
CA.Venugopal Gella

15. Source of the data for GSTR 9 : Turnover
GSTR 3B
Books
Turnover on which taxes have been paid
GSR 3B
DRC 03

16. Reconciliation of Books Turnover
PAN Based Turnover
Apr-17 to Jun-17
Jul-17 to Mar-18
GSTIN 1
GSTIN 2
GSTIN 3…n
+ GST Adjustments

17. Book Turnover to GST Turnover

18. Adjusted Books Turnover Reporting
GST Turnover Reported in
Tax paid in 3B till Mar 2018
Part II Table 4
Tax paid in 3B till Sept 2018*
Part V : Table 10 n 11
Balance Tax Payable
DRC 03
DRC 03:[Instruction No.9]
Additional Tax liability not discharged through GSTR 3B can be paid through DRC-03.
Taxpayers shall select "Annual return" in Drop down for DRC-03.
Payment to be made only through electronic cash ledger.
*Provided taxes are paid during that period

19. Reporting of DRC 03 - Turnover & Taxes
Amended form neither gave place for reporting nor instructions for the same, hence the user can choose any of the following 3 options
Option 1 : Conservative Approach
Do Not report in GSTR 9
Adjustment to be done by the officer during Assessment
Option 2 : Aggressive Approach Violation of Instructions
Add the Additional Turnover n Liability in Table 4
Increase the Tax liability in Table 9
Option 3 : Practical
Do Not change or Report in either Table 4 or Table 10
Increase only Tax Payable in Table 9

20. Reconciliation of Books Turnover
GSTIN 1
GSTIN 2
GSTIN n
GSTIN Wise
Taxable
Table 4
Table 101
Table 11
Exempt
Table 52
Table 10
1. Provided taxes are paid during that April to Sept 2018
2.Consider Actual amount as per Books irrespective of whatever is considered in GSTR 1 and GSTR 3B. As there is no tax implication, Table 10 and 11 is not applicable

21. Internal Workings to be Maintained
As per Books FY
Taxable value
IGST
CGST
SGST
Cess
Outward Supply – Taxable 5%
12%
18%
28%....
Outward Supply – NOT Taxable
Zero rated
Exempted
Nil rated
Non GST
RCM on outward supply
Total turnover
xxxxx

22. Examples

23. Liability and Turnover Matching with GSTR 1

24. Liability and Turnover Matching with GSTR 3B

25. Wrong Turnover in 3B but correct Taxes
*Even though 3B turnover is 1,000/-; since the taxes are paid for Rs.100; what gets reported in GSTR 9 is 100.
So, In GSTR 9, we only report Turnover on which Tax has been paid for.

26. Excess in GSTR 3B - Taxes adjusted Subsequently

27. Excess in GSTR 3B - Taxes NOT adjusted Subsequently
*There will be difference between Table 4 and Table9 taxes paid , difference to claim as refund with in 2 years

28. Taxes paid thru DRC 03 Issues in
Option 1: There will be reason for Difference in Table 6 , Table 8 and Table 10 of GSTR 9C
Option 2: No option for GST Auditor to disclose liability. If Assesse do not pay tax in DRC 03 after filing GSTR unintentionally also this would become the case of fraud. Auditor cannot also recommend Additional Liability
Option 3: Most Recommended, Difference in Table 6 and 8, Auditor can recommend liability in Table 11 and DRC 03 will naturally follow.

29. Data Flow of Input Tax Credit

30. Credits to Electronic Credit Ledger(ECrL)
Credit flow
Credits to Electronic Credit Ledger(ECrL)
Reported thru GSTR 3B
4A-4B=4C
Direct Entry to ECrL
Trans I
Trans II
ITC 01
ITC 02
Table 6B to 6H >>
<< Table 6K- 6M

31. Electronic Credit Ledger – Basis Tax Period

32. Reconciliation of GSTR 9 ITC
Net ITC Availed = 7J
Utilised During the Year
Table 9
Unused ITC
ECL Balance for March 2018

33. ITC Reconciliation with Books & GSTR 9
Net ITC available
Table 7J
ITC availed for the Previous FY
Table 13
Reversal of ITC availed during previous FY
Table 12
ITC as per Books

34. Total Reporting of INPUT TAX CREDIT
ITC
Availed
In 17-18
Table 6
In 18-19
Table 13
Reversed
Table 7
Table 12
Ensure Table 13 is greater 8C

35. Credit Flow of GSTR 3B into GSTR 9
Matching Credits
GSTR 9
GSTR 3B
6B + 6H
4A5
Forward Charge Credit
6C + 6D
4A3
Reverse Charge Credit 6E
4A1
Import of Goods 6F
4A2
Import of Services 6G
4A4
ISD Credit

36. Detection of Erroneous Credit
Table Number
Remarks
Detection by GSTN System
6B /6H
No Inward Supply, but reported as Forward Charge Credit
Since there is no Counter Party Submission 2A would be lower 8D will be Negative
6C / 6D / 6F
Reported as Reverse Charge Credit
RCM Credit is available only payment of tax , hence should have got reported in 4G 6E
No Imports, but extra credit added in this section
No Tax payment in ICE Gate portal; 8I would be negative 6G
If reported as ISD
Part B of GSTR 2A would be Less
6K /6L
Credit reported is higher than Trans Credit
Different Value in the Line Entry in Electronic Credit Ledger 6M
Any Other ITC
Respective ITC forms ITC 01, ITC 02 etc should have filed

37. Match the Net Credits Availed through 3B
Table 4C of GSTR 3B
(Net ITC available after deducting reversals)
Table 6I of GSTR 9
6B to 6H
Table 7I of GSTR 9
ITC reversed
minus
Difference can be only if
Erroneous Credit reported in GSTR9, either excess or short
Reversal of Credits now done in GSTR9

38. Reconciliation of RCM liability with RCM ITC
Table 4G of GSTR 9
ITC
URP / URD
Table 6C of
GSTR 9 RD
Table 6D of GSTR9
Import of Service
Table 6F of GSTR9

39. Control Check for RCM from Registered Person
Table 4 of GSTR 2A
Table 4G of
GSTR 9
(RCM Liability)
Table 4 of GSTR 2A
Table 6D of
GSTR 9
(RCM ITC)

40. Table 8D : Un reported GSTR 2A Line Items
GSTR 2A Credits 8A = 200
Reported in 3B /ECL = 120
Eligible & Availed 60 8B
Ineligible but availed 20
Availed in 40 8C
Not Reported 3B /ECL = 80
Missed out Taking credit in 3B 35 8E
Ineligible & Not availed 45 8F
Eligible =155
Ineligible = 45

41. Summary Points for Discussion
Practical Issues
Possible Resolutions
INPUT TAX CREDIT AVAILED
Excess availed in 3B / Trans Returns
DO NOT Correct in GSTR 9
Ineligible Credit Availed
Still Report as ITC Availed
Excess availed Reversed in itself
Show net availment in Table 6 ( Offset only erroneous excess availment and not other reversal)
Credit Short Availed in GSTR 3B of and balance availed in
Actual Availed in Table 6B to 6H
Actual Availed in Table 8C and 13
Credit Short Availed in GSTR 3B of and balance NOT availed in
Unaviled credit to reported 8E
INPUT TAX CREDIT REVERSED
Ineligible credit not Reversed
Reversed in
Report in Table 12 not in Table 7
Not reversed in also
DO not Report

42. Liability & Tax Payments Data flow
Table 4
Add: Table 10
Less: Table 11
Liability 2
Table 9(2)
Add: Table 14(2)
Taxes Paid
Table 9(3-7)
Add: Table 14(3)
Difference represents paid through DRC-03
Liability 1
Liability 2
Liability 3

43. Validation with HSN Wise Reporting
Table 17 HSN
Table 4
Advances r
RCM
Table 5
Non GST
Table 10
Table 11
<<<< Items to be Excluded for HSN

44. GSTR 9C
GST Annual Audit

45. Computation of Liability
Net Tax Payment = Taxable Turnover x Rate of Tax – ITC
Taxable Turnover = Gross Turnover – Exempt Turnover
GST Auditor would Check, Correctness of
Gross Turnover
Exemptions Claimed
Tax Rates adopted
Input Tax credits Availed
Recommend for Additional Lability, if any

46. Reconciliation Statement – GSTR 9C Broad View 5 Parts 16 Tables
Part I
Basic details
Table 1 - 4
Part II
Turnover Recon
Table 5 - 8
Part III
Recon of Tax paid
Table
Part IV
Input Tax credit Recon
Table
Part V
Auditor’s Recommendation
Table x
Rule 21 of Return rules talk about annual return
CA.Venugopal Gella

47. Data Source Derived From Prepared using Audit Report 9C GSTR 9 GSTR 3B
GSTR 1 +2 A
Adjustments
Audited Financials
Books of Accounts
Part A of 9C is NOT mere compilation of Books / Returns
Its an Audit between 9 and Books
Values to report not Actual but Expected as per Law.

48. Turnover Reconciliation
Parts II
Table 5
Gross Turnover Recon
Table 6
Difference in Gross Turnover
Table 7
Taxable Turn over Recon
Table8
Diff in Taxable Turnover

49. Derive GST Turnover from GSTIN Based Books

50. Compare with GSTR 9 – Gross Turnover
Table 5N of GSTR 9
(Taxable + Exempted)
Table 10 of GSTR 9
(Upward Amendments till Sept 2018)
Table 11 of GSTR 9
(Downward Amendments till Sept 2018)

51. Table 7 : Reconciliation of Taxable Turnover
Pt. II
Details of Outward and inward supplies declared during the financial year
(Amount in ₹ in all tables)
Nature of Supplies
Taxable Value
Central Tax
State
Tax /
Tax UT
Integrated Tax
Cess 1 2 3 4 5 6
Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the financial year A
Supplies made to un-registered persons (B2C)
Aggregate value of supplies made to consumers and unregistered persons on which tax has been paid shall be declared here. These will include details of supplies made through E-Commerce operators and are to be declared as net of credit notes or debit notes issued in this regard. Table 5, Table 7 along with respective amendments in Table 9 and Table 10 of FORM GSTR-1 may be used for filling up these details. B
Supplies made to registered persons (B2B)
Aggregate value of supplies made to registered persons (including supplies made to UINs) on which tax has been paid shall be declared here. These will include supplies made through E-Commerce operators but shall not include supplies on which tax is to be paid by the recipient on reverse charge basis. Details of debit and credit notes are to be mentioned separately. Table 4A and Table 4C of FORM GSTR-1 may be used for filling up these details. C
Zero rated supply (Export) on payment of tax (except supplies to SEZs)
Aggregate value of exports (except supplies to SEZs) on which tax has been paid shall be declared here. Table 6A of FORM GSTR-1 may be used for filling up these details.
Table 7 : Reconciliation of Taxable Turnover
CA.Venugopal Gella

52. Compare with GSTR 9 – Taxable Turnover
Table 4N of
(Total Taxable supplies & advances)
Table 4G of
GSTR 9
(Inward RCM)
Table 10 of
(Upward Amendments till Sept 2018)
Table 11 of
(Downward Amendments till Sept 2018)

53. Rate Wise Tax Payable as per Auditor
Pt. II
Details of Outward and inward supplies declared during the financial year
(Amount in ₹ in all tables)
Nature of Supplies
Taxable Value
Central Tax
State
Tax /
Tax UT
Integrated Tax
Cess 1 2 3 4 5 6
Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the financial year A
Supplies made to un-registered persons (B2C)
Aggregate value of supplies made to consumers and unregistered persons on which tax has been paid shall be declared here. These will include details of supplies made through E-Commerce operators and are to be declared as net of credit notes or debit notes issued in this regard. Table 5, Table 7 along with respective amendments in Table 9 and Table 10 of FORM GSTR-1 may be used for filling up these details. B
Supplies made to registered persons (B2B)
Aggregate value of supplies made to registered persons (including supplies made to UINs) on which tax has been paid shall be declared here. These will include supplies made through E-Commerce operators but shall not include supplies on which tax is to be paid by the recipient on reverse charge basis. Details of debit and credit notes are to be mentioned separately. Table 4A and Table 4C of FORM GSTR-1 may be used for filling up these details. C
Zero rated supply (Export) on payment of tax (except supplies to SEZs)
Aggregate value of exports (except supplies to SEZs) on which tax has been paid shall be declared here. Table 6A of FORM GSTR-1 may be used for filling up these details.
Rate Wise Tax Payable as per Auditor
CA.Venugopal Gella

54. Compare with GSTR 9 – Tax Liabity
Tax Payable
Table 9
Table 10
Table 11

55. ITC as per Books vs GSTR 9 Table 7J of GSTR 9
Unreconciled ITC
Table 12F of GSTR 9C
ITC claimed as per GSTR 9
Table 12E of GSTR 9C
Table 7J of GSTR 9
(Net ITC available for utilisation)
ITC availed as per Signed Financials
Table 12D of GSTR 9C
ITC booked in PY claimed in current FY
ITC booked in current FY claimed in subsequent FY

56. Expense Wise ITC Reconciliation
Purchases
With payment of tax
Forward charge
Reverse charge
Without payment of tax
Exempt
Composition
URD RCM
(Not taxable)
Table 14 of GSTR 9C
Total ITC availed
(Table 14(3))
ITC eligible availed
(Table 14(4))

57. Adjustments to Books of AccountsFY

58. Transfer to Liability Ledger
Dr Output CGST A/c
Dr Output SGST A/c
Dr Output IGST A/c
Cr Liability Ledger CGST A/c
Cr Liability Ledger SGST A/c
Cr Liability Ledger IGST A/c
Include
Forward Charge Liability
Reverse Charge Liability
Table 3 of GSTR 3B

59. Recording Electronic Credit Ledger Entries
Dr ITC CGST Dr Ledger A/c
Dr ITC SGST Dr Ledger A/c
Dr ITC IGST Dr Ledger A/c
Dr P&L/Exp – A/c {T1+T2+T3 }
Cr Input CGST A/c
Cr Input SGST A/c
Cr Input IGST A/c
Include
Regular and RCM Credits
Proper Accounting for Rule 42 n 43 Reversal
Tracking of Re-available reversal Rule 37
Table 4 of GSTR 3B

60. On Payment of Taxes – Transfer to Cash Ledger
Cash Payment Dr Electronic Cash Ledger IGST Dr Electronic Cash Ledger CGST Dr Electronic Cash Ledger SGST Cr Bank TDS / TCS Dr Electronic Cash Ledger { I / C + S } Cr Govt / eCom Operator
FORM GST PMT –06
FORM GST PMT –06
[See rule 87(2)]

61. Off Set Liability
Dr Liability Ledger CGST A/c Dr Liability Ledger SGST A/c Dr Liability Ledger IGST A/c Cr ITC CGST Dr Ledger A/c Cr ITC SGST Dr Ledger A/c Cr ITC IGST Dr Ledger A/c Cr Electronic Cash Ledger { I + C + S}
Table 6.1 of GSTR 3B

62. Transactions of 17-18 in 18-19 Books
Past Liabilities
Table 10 & 11
Past ITC
Table 12 : ITC reversed in 18-19
Table 13 : ITC availed in ( Ref Table 8C )
Parked Credits
Table 6H : Reversed and Re-availed Credits
Additional Tax Liability
Payments made thru DRC 03
Deemed Supply – Table 16
Goods Sent for Job Work + Good Sent on Sale or Approval

63. Thank
You
For Clarifications, mail to