1. Faculty:-CMA L. Rajesh B.Com., ACMA Practicing Cost Accountant
The Institute of Cost Accountants of India Erode Chapter GSTR -- 9C An overview Friday -- Time 6-9 pm.
Faculty:-CMA L. Rajesh B.Com., ACMA
Practicing Cost Accountant

2. What is GSTR-9C?
Every registered person whose turnover during a financial year exceeds the prescribed limit of rupees two crores shall get his accounts audited by a chartered accountant or a cost accountant.
GSTR-9C is a statement of reconciliation between:
the Annual Returns in GSTR-9 filed for a FY,  and
the figures as per the audited annual Financial Statements of the taxpayer.
It can be considered to be similar to that of a tax audit report furnished under the Income tax act. It will consist of gross and taxable turnover as per the Books reconciled with the respective figures as per the consolidation of all the GST returns for an FY. Hence, any differences arising from this reconciliation exercise will be reported here along with the reasons for the same.
The certified statement shall be issued for every GSTIN. Hence, for a PAN there can be several GSTR-9C forms to be filed.

3. Who must prepare & submit GSTR-9C?
GSTR-9C must be prepared and certified by a Chartered Accountant or Cost Accountant. It must be filed on the GST portal or through a facilitation centre by the taxpayer, along with other documents such as the copy of the Audited Accounts and Annual Return in form GSTR-9.
This statement is applicable to all those taxpayers who must get their Annual Accounts audited under the GST laws. Audit under GST applies to those registered persons whose Annual aggregate turnover exceeds rupees two crores in that FY.

4. due date for GSTR-9C
The due date for submitting the Annual returns in GSTR-9 is the same deadline for submission of GSTR-9C. Hence, the GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant FY under audit. The due date can be extended by the Government if deemed necessary.
For example, for the FY , the due date for filing GSTR-9C is 30th June 2019*.

5. importance of GSTR-9C
A Chartered Accountant or Cost Accountant must prepare this GST Reconciliation statement. Any differences between the details reported in all the GST returns and the Audited Accounts must be reported by the CA therein with the reasons for the differences. This statement acts as a base for the GST authorities to verify the correctness of the GST returns filed by the taxpayers. This is because the CA has to certify any additional liability arising out of the reconciliation exercise and GST audit in GSTR-9C

6. contents of form GSTR-9C?
The GSTR-9C consists of two main parts:
Part-A: Reconciliation Statement Part-B: Certification

7. Part-A: Reconciliation Statement
Part-I: Basic details
Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9):
Part-III: Reconciliation of tax paid:
Part-IV: Reconciliation of Input Tax Credit (ITC):
Part-V: Auditor’s recommendation on additional Liability due to non-reconciliation:

8. Amount paid for supplies not included in the Annual Returns(GSTR-9)
Erroneous Refund to be paid back
Other Outstanding demands to be settled

9. Part-B: Certification
The GSTR-9C can be certified by the same CA who conducted the GST audit or it can be also certified by any other CA who did not conduct the GST Audit for that particular GSTIN.
The difference between the both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format of Part-B for certification report will vary depending on who the certifier is.

10. changed in GSTR-9C format & filing
Following are the changes made to the format and filing procedure as on 31st Dec 2018:
Verification by Registered Taxpayers:
Taxpayers need to file the GST returns for all the months of FY in GSTR-1, GSTR-3B and GSTR – 9.
At the end of this return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ―’Reconciliation Statement’ in the drop-down provided in FORM DRC-03. It may be noted that such liability shall be paid through electronic cash ledger only

11. Late fees & penalty
No specific provision, Hence, subject to a general penalty of Rs 25,000

12. Turnover-based Audit under Section 35(5) of CGST Act
If the annual turnover of a registered taxpayer is more than Rs. 2 crores in a financial year , he is required to get his accounts audited by a Chartered Accountant or Cost Accountant every year.
A financial year covers the 12-month period beginning from April of a calendar year to March of the next calendar year.
Special Note: For the purpose of finding out the turnover limit for Financial Year , it includes the first quarter of i.e. 1st April 2017 to 30th June 2017, before GST was implemented.
If the annual turnover of a registered taxpayer is more than Rs. 2 crores in a financial year, he is required to get his accounts audited by a Chartered Accountant or Cost Accountant every year.

13. Aggregate turnover is calculated as follows
= Value of all taxable (inter-state and intra-state) supplies
+ exempt supplies
+ export supplies of all goods and services

14. Items included while calculating turnover:
All taxable (inter-state and intra-state) supplies other than supplies on which reverse charge is applicable
Supplies between separate business verticals.
Goods supplied to/received from job worker on principal to principal basis.
Value of all export/zero-rated supplies.
Supplies of agents/ job worker on behalf of the principal.
All exempt supplies. E.g. Agricultural produce supplied along with branded ready-to-eat food.
All taxes other than those covered under GST Eg: Entertainment Tax paid on the sale of movie tickets.

15. Items excluded while calculating turnover:
Inward supplies on which tax is paid under reverse charge.
All taxes and cess charged under Goods and Service Tax like CGST, SGST or IGST, Compensation Cess.
Goods supplied to or received back from a Job Worker.
Activities which are neither supply of goods nor service under schedule III of CGST Act.

16. Points to Note:
An internal auditor cannot parallelly be appointed as a GST Auditor.
The GST Act does not allow a GST practitioner to perform the audit. The power to audit is granted only to a Chartered Accountant or Cost Accountant who is in practice or is an employee of a firm of Chartered Accountants or Cost Accountants. Therefore, a Chartered Accountant must not be registered as a GST practitioner for the purpose of issuing the Audit Report.
Where an organization or an entity has multiple branches registered under GST in different states/UTs, the total aggregate turnover of all such branches is considered while calculating the threshold limit of Rs. 2 crores.So, if the cumulative turnover of all the branches exceeds Rs. 2 crores, then the GST audit is applicable to each of these branches, irrespective of whether the turnover of a particular branch is less than the threshold.In such cases, one can appoint either one dedicated auditor for all branches or separate auditor for each branch. Where multiple branches have different auditors, the Standards on Auditing: SA 299 — Responsibility of the Joint Auditors may apply for the purpose of reporting GST Audit observations & Reporting.

17. Appointment of GST Auditor:
A proprietor, partner or Board of Directors in case of a Company should appoint a GST Auditor at the beginning of the financial year.

18. Accounts to be to be reviewed by GST Auditor
Sales Register
Stock Register
Purchase Register and Expenses ledgers
Input tax credit availed and utilized
Output tax payable and paid
E-way bills generated during the period under Audit, if in compliance with rules.
Any documents that record communications from the GST department relating to the year

19. Documents Audited financial statements (which is PAN-based)
Annual return in form GSTR-9 (for every GSTIN)
Certified reconciliation statement in Form GSTR-9C, reflecting reconciled values of supplies and tax amounts declared in GSTR-9 compared to audited financials in Part-A, along with the Audit report in Part-B.

20. Forms A Regular taxpayer filing GSTR 1 and GSTR 3B-----GSTR-9
A Taxpayer under Composition Scheme--GSTR-9A
E-commerce operator---GSTR-9B
Taxpayers whose turnover exceeds Rs. 2 crores in FY----GSTR-9C

21. Review of comments
The Auditor must report any tax liability pending for payment by the taxpayer, identified through the reconciliation exercise and observations made on GST audit. Taxpayers can settle taxes as recommended by the auditor in Form DRC-03.

22. Submission
The finalized GSTR-9C can be certified by the same CA who conducted the GST audit or it can also be certified by any other CA who did not conduct the GST Audit for that particular GSTIN.
The following must be reported and certified by the GST Auditor or the certifier:
Whether or not all the requisite accounts or records are maintained.
Whether or not the Financial Statements are prepared as per the books of accounts maintained at the principal place of business or additional place of business of the taxpayer.
Certify the accuracy of information in GSTR-9C.
To list down the audit observations or reservations or comments, if any.

23. GSTR 9C Part-A: Reconciliation Statement Format
1. Financial Year
2. GSTIN of the taxpayer
3A. Legal Name of the registered person
3B. Trade Name (if any) of the registered business
4. If the taxpayer is liable for any audit under this act?

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