1. GSTANNUAL RETURN
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2. RELEVANT FORMS FORTHE PURPOSEOFANNUAL RETURN AND RECONCILIATION FORMAT
GSTR-9 - Annual Return
GSTR-9A - Annual Return for (Composition Tax Payers)
GSTR-9C - Reconciliation Statement
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3. Issue 1: What all data do we need to refer for taking up GSTR 9?
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4. Keep in Hand…
GSTR 1 of all the tax periods in the financial year OR Summary of GSTR 1 from GSTN.
GSTR 3B of all the tax periods in the financial year OR Summary of GSTR 3B from GSTN.
Final Books of Accounts
Audited Financial Statements
26 AS of the entity
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5. Issue 2: Where to begin from and where to head towards?
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6. Pre-Treatment Diagnosis
Process Flow
Pre-Treatment Diagnosis
Analysis of GSTR 1 & 3B
Reconciling BOA with R1 & 3B
Treatment
Filling the GSTR 9
Computing additional liability if any
Postmortem
GSTR 9C – ITC on expenses
Reasons of differences
Reporting
GST Audit Report Part II of 9C
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7. Issue 3: Who is not liable for filing Annual Return?
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8. PERSONS NOT REQUIRED TO FILEANNUAL RETURN
Input Service Distributor,
A person paying tax under section 51 or section 52,
A casual taxable person and
A non-resident taxable person
Department of Central Government or State Government or local authority, whose books of account are subject to audit by the Comptroller and Auditor-General of India or an auditor appointed for auditing the accounts of local authorities under any law for the time being in force.
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9. Issue 4: Which form is to be filed if the taxpayer was under Composition scheme for some part of the year and was under regular mechanism for the rest part?
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10. ANNUAL RETURN Question Answer
How would Annual Return be filed by a person who was under composition scheme for part of year and under regular scheme for remaining part of the Year
Such persons would have to file GSTR-9 for the period under which they were under Regular Scheme and GSTR-9A for the period under which they were composition scheme.
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11. Issue 5: Mismatches- GSTR 3B vs. GSTR 1 vs. BOA vs. GST Law
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12. Issue 6: Nil GSTR 9- Is this for real?
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13. WHO CAN FILE “NIL” ANNUAL RETURN
NOT made any outward supply (commonly known as sale); AND
NOT received any goods/services (commonly known as purchase); AND
NO other liability to report; AND
NOT claimed any credit; AND
NOT claimed any refund; AND
NOT received any order creating demand
There is no late fee to be paid etc.
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14. Issue 7: What to do with differences in GSTR 1 and GSTR 3B
Issue 7: What to do with differences in GSTR 1 and GSTR 3B? Which table to be used for which data?
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15. Issue 8: Table 4 vs. Table 5?
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16. Reference ofAnnual Return inAudit Report
Table 7
Reconciliation of Taxable Turnover
Tabl e 7F
Taxable turnover as per liability declared in Annual Return (GSTR9)
Instruction 7F: Taxable turnover as declared in Table (4N – 4G) + (10-11 i.e., Amendments in supplies declared in returns of April to Sept) of the Annual Return (GSTR9) shall be declared here.
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17. Reference ofAnnual Return inAudit Report
Table 5
Reconciliation of Gross Turnover with Turnover reported in Annual Return
Table 5Q
Turnover as declared in Annual Return (GSTR9)
Instruction 5Q: Annual turnover as declared in the Annual Return (GSTR 9) shall be declared here. This turnover may be derived from Sr. No. 5N, 10 and 11 of Annual Return (GSTR 9).
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18. SuggestiveTreatment of Supplies andTax thereon inGSTR-9
Tax Paid between July to March 2018 by 3B:- Table 4
Tax paid between April to September 2018 by 3B: Table 10 and 11
Tax paid through Annual Return: Table 4 and Use of DRC-03 64

19. Issue 9: What about supplies for FY 17-18 disclosed after September 2018 and tax paid thereon?
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20. ROD Order - 2
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21. Issue 10: Classification of ITC on Input goods, services and Cap goods?
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22. Issue 11: Tran 2 filed after March 2018 – Treatment in GSTR 9 for 17-18?
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23. Issue 12: Auto-populated data from GSTR 2A is not correct?
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24. CA PULKIT KHANDELWAL

25. Issue 13: :Lapse of ITC – A reality?
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26. SuggestiveTreatment of Inward Supplies andTax thereon in GSTR-9
ITC Claimed or reversed between July 2017 to March 2018 in 3B:- Table 6/Table 7
ITC Claimed between April 2018 to March 2019 in 3B: Table 13 (Although Form would have to
be amended in view of ROD No. 2/2018 from “April to Sep 18” to “April to March 19”)
ITC Reversed between April 2018 to September 2018: Table 12
ITC Reversed between October 2018 to March 2019: (Clarification required) If allowed to
reversed by 3B :-Table 12
ITC Reversed in Annual Return: Table 7 and pay by DRC-03
ITC cannot be claimed in Annual Return
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27. Issue 16: IGST refund receivable on IGST paid shipping bills to be shown in refunds table?
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28. Issue 16: HSN / SAC ??
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29. O: 303, Soni Paris Point, Collectorate Circle, Jaipur
CA. Pulkit Khandelwal
O: 303, Soni Paris Point, Collectorate Circle, Jaipur M: E:
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