1. June

2. Issues and Controversies in GSTR 9/9C

3. Why GSTR 9/9C?
There is no clarity if GSTR 1/3B are returns or just compliance documents
Only reconciliations can be asked from compliance documents
Assessments can only be done on returns
Hence GSTR 9/9C

4. How many have been filed?

5. Issue No 1
Annual return and Audit is being asked for the most volatile period in GST

6. Most common errors in GSTR 1/3B July 2017- March 2018
What is Supply?
B2B/B2C
Whether exports were exempt or tax refundable?
Wrong HSN
Arithmetical errors while filing forms
ITC had no checks and balances

7. Issue No 2
Why is this information being asked for 15 months after the end of the financial year?
Data, Data, Data

8. Most asked questions Will there be an extension?
Will the forms change?
We always live in hope.

9. GST?

10. Walk through of GSTR 9

11. Table 4

12. Table 4

13. Table 4

14. Table 5

15. Table 5

16. Table 6

17. Importance of Auto-population

18. Table 6

19. Table 6

20. Table 7/8

21. Table 8

22. Table 9

23. Other Tables

24. Issue No 3 The mystery form GSTR 2A
Counter-Party did not filed GSTR 1 yet
Counter-Party filed GSTR 1 with our Bill shown in B2C
Counter-Party filed GSTR 1 with our Bill shown with GSTN of other party
In GSTR 1 Counter Party wrongly clicked Composition tick on our Bill
Counter-Party filed GSTR 1 without our Bill etc
6B of GSTR 9

25. ITC Reporting of ITC for 2017-18 in GSTR 3B in next year i.e. 2018-19
8C and 13 of GSTR 9
Non-Reporting of ITC for in GSTR 3B till
ITC Lapsed- 8E of GSTR 9

26. ITC Wrong reporting of ITC in 2A 8F of GSTR 9
CGST – SGST wrongly shown as IGST in GSTR 3B, not rectified upto i.e. Correct ITC lapsed & Wrong ITC availed not rectified
8E of GSTR 9
DRC -03 challan

27. Classification
CGST – SGST wrongly shown as IGST in GSTR 3B, but rectified upto
6B of GSTR 9

28. Walk through of GSTR 9C

29. Reco

30. Reco

31. Reco

32. Reco

33. Reco

34. Reco

35. Reco

36. What can the auditor recommend in Part V?
Gross Negligence of GST laws

37. Responses to Questions sent

38. Questions
Whether ITC can be taken in respect of RCM relating to , paid after September 2018 in the light of Order No ?
Please claim it. 8C of GSTR 9
Where to show credit note raised after March 18, relating to 17-18? Whether it is to be shown in annual return for or 18-19?
4I of GSTR 9 for

39. Questions
Where to show RCM paid after March 2018 relating to in the Annual Return?
6M is a possible option
Whether Form 9C is in the true sense an audit report or a reconciliation statement to be certified by auditor?
In the true sense it is only a reconciliation statement

40. Questions
Is there any liability on the GST auditor to report about transactions (for example Schedule I transactions), which are neither included in the books of accounts nor reported in Annual return in the light of Part V of 9C?
There is no liability but it is always preferable to report since there will no tax liability
Further, what is responsibility, if the taxpayer has disclosed transactions liable to RCM in the books and not paid RCM tax under GST?
Report in Part V of 9C

41. Questions
Similarly, what is responsibility, if the HSN numbers provided in respect of outward & inward supplies are not accurate?
Input correct HSN in Table 17 of GSTR 1
Can Form 9 be filed individually without filing Form 9C in respect of persons liable to audit u/s 35(5)?
Definitely. But there will be a violation of 35(5)

42. Questions
Where do we show the RCM rectifications (inward supply against which tax is payable under Reverse Charge Mechanism) related to done in with payment of Tax in GSTR 9? If this can be shown in Table 4 or Table 10, where would the related tax payment find place in GSTR 9?
Table 10 – tax declared through amendments
Tax- Table 14

43. Questions
Where can the interest paid on reversal of ITC or on RCM (payable against inward supply) related to paid in can be shown in GSTR – 9.
Interest column – Table 14
Is GSTR 9C required for a State where GSTR 9 is Nil Return; however their PAN India Turnover exceeds the threshold and all other states where they have places of business are subject to audit under GST.
Unfortunately, Yes

44. Questions
What is the way out for dealer who lost all the records in flood occurred in Kerala last year for filing Form 9 and 9C? 
Write to the GST Council and local GST officer stating the inability to file before June 30, and also seeking exemption from filing.

45. Own Question What if a mistake is made in filing GSTR 9/9C?
Depending on the mistake
Defend the mistake
Rectify in June 1/3B

46. Simple Solution
Devise a Form 3BA to revise returns for

47. THANK YOU!