Journey of filing  GST Annual Return so far………….

Contributed by CS Payal Kataria

Under GST, it’s not all about filing of monthly/quarterly returns, don’t forget to file GST Annual return

As per provisions of section 44 of CGST Act 2017

  1. Every registered person, other than an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person, 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.
  2. Every registered person who is required to get his accounts audited in accordance with the provisions of sub-section (5) of section 35 shall furnish, electronically, the annual return under sub-section (1) along with a copy of the audited annual accounts and a reconciliation statement, reconciling the value of supplies declared in the return furnished for the financial year with the audited annual financial statement, and such other particulars as may be prescribed.

To meet the deadline of  31st December, Annual Return Form 9 and  Form 9A have been notified on dated 04.09.2018 and Form 9C Reconciliation Statement has been notified dated 13.09.2018 but till time these forms are not available at portal.

Due to various practical difficulties due date to file GST Annual Return was extended till 31st March 2019

Government well understand the current challenges and to address various issues and difficulties GST council made following recommendations in it’s 31st GST Council Meeting held on 22.12.2018

Highlights of 31st GST Council Meeting related to Annual Return

The due date for furnishing the annual returns in FORM GSTR-9, FORM GSTR-9A and reconciliation statement in FORM GSTR-9C for the Financial Year 2017 – 2018 shall be further extended till 30.06.2019.  

The following clarificatory changes, inter-alia, shall be carried out in the formats/instructions according to which the annual return / reconciliation statement is to be submitted by the taxpayers:

i) Amendment of headings in the forms to specify that the return in FORM GSTR-9 &FORM GSTR-9A would be in respect of supplies etc. ‘made during the year’ and not ‘as declared in returns filed during the year’;

 ii) All returns in FORM GSTR-1&FORM GSTR-3B have to be filed before filing of FORM GSTR-9&FORM GSTR-9C;

iii) All returns in FORM GSTR-4 have to be filed before filing of FORM GSTR9A;

 iv) HSN code may be declared only for those inward supplies whose value independently accounts for 10% or more of the total value of inward supplies;

 v) Additional payments, if any, required to be paid can be done through FORM GST DRC-03 only in cash;

vi) ITC cannot be availed through FORM GSTR-9 &FORM GSTR-9C;

vii) All invoices pertaining to previous FY (irrespective of month in which such invoice is reported in FORM GSTR-1) would be auto-populated in Table 8A of FORM GSTR-9;

 viii) Value of “non-GST supply” shall also include the value of “no supply” and may be reported in Table 5D, 5E and 5F of FORM GSTR-9;

 ix) Verification by taxpayer who is uploading reconciliation statement would be included in FORM GSTR-9C.

 Below is summary table containing due dates recommended by 31st GST Council Meeting:

FORM Details Period Due Date as Recommended in 31st GST Council Meeting
GSTR-9 Annual Return F.Y. 2017-2018 30.06.2019
GSTR-9A Annual Return (For Composition Taxpayer) F.Y. 2017-2018 30.06.2019
GSTR-9C Reconciliation Statement & Certification F.Y. 2017-2018 30.06.2019
GSTR-8 Return to be filed by E-Commerce Operator Oct 2018
Nov 2018
Dec 2018
31.01.2019
GST ITC-04 Details of goods / capital goods sent to job worker and received back Jul 2017 to Dec 2018 31.03.2019

Disclaimer: The contents of this document are solely for informational purpose. It does not constitute professional advice or recommendation of firm. Neither the authors nor firm and its affiliates accepts any liabilities for any loss or damage of any kind arising out of any information in this document nor for any actions taken in reliance thereon.

Readers are advised to consult the professional for understanding applicability of this writeup in the respective scenarios. While due care has been taken in preparing this writeup, the existence of mistakes and omissions herein is not ruled out. No part of this writeup should be distributed or copied (except for personal, non-commercial use) without our written permission.


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