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Indirect Tax Alert

Have you filed your GST annual return and reconciliation statement, due date is approaching fast?

December 21, 2023

Overview of GST Annual Return (GSTR-9) and Reconciliation Statement (GSTR-9C)

GSTR-9 is an annual return to be filed yearly by taxpayers registered under GST (subject to turnover limit above Rs. 2 Cr.). It consists of details regarding outward supplies and inward supplies made/ received during the relevant financial year under different tax heads i.e. CGST, SGST & IGST.

It is a consolidation of all the monthly/quarterly returns (GSTR-1, GSTR-2A/2B, GSTR-3B) filed in that year. Due date of filling GSTR-9 for FY 2022-23 is 31st December 2023.

GSTR-9C is a reconciliation statement to be filed by taxpayers whose aggregate turnover during a financial year exceeds Rs. 5 Cr. It is a statement which consist reconciliation of GST returns filed with the Audited Annual Accounts. Due date of filing GSTR-9C for FY 2022-23 is 31st December 2023.

GSTR-9C is dependent on GSTR-9 annual return as there are certain fields which are auto-populated from GSTR-9. There are some optional and mandatory fields to be filled up in GSTR-9C. Due care must be taken while filing GST annual return such as reconciliation of GSTR-2A/2B with GSTR-3B, GSTR-1 with GSTR-3B and all the GST returns to be reconciled with books of accounts.

Best Practices & Tips:

  1. Maintain GSTR- 9 & 9C workings with links to all the relevant data.
  2. Maintain separate details of ITC claimed, reversed, and re-claimed if the taxpayer fulfils the conditions mentioned u/s 16.
  3. In case of amendments, outward register to be maintained with original values.
  4. Credits as per books if unclaimed due to non-matching with GSTR 2A/2B. An option for recovering from vendors can be explored.
  5. Providing an “Annual GST - Management Report” which may consist of the following:
    1. Folder with final workings and filed Form GSTR 1, 3B, GSTR 9 & 9C for the Financial Year.
    2. Reconciliations for the FY – Outward, Inward & RCM – birds eye view
    3. Reasons for variances and action taken (summarily)
    4. Where additional liability was noticed – summary details + payment documentation
    5. Suggestions on internal accounting/processes/reporting going forward

Conclusion:

The activity of filing Form GSTR 9 & 9C now has more importance as it is expected to show the final values (with corrections if any) for a financial year. The department is also using this as a document for scrutiny. Therefore, putting in place procedures to ensure accurate data capture and reporting is imperative.

About MBG’s GST Annual Return GSTR-9 & 9C filing Service

  1. Under ever-changing business circumstances, extensive experience and in-depth knowledge of accounting, tax laws as well as other business regulations are required to perform and deliver the service as above. Our GST Annual compliance practice is comprised of multi-disciplinary professionals including accountants, Indirect Tax Experts, industry specialists and former high-level government officials, who possess expertise and experience in relevant areas;
  2. We will provide practical guidance and recommendations on additional measures that your business can put in place to ensure your business is in the best position possible to minimize the risks of non-compliance.

 MBG’s GST Annual Compliance Offerings

  1. Walkthrough tests of controls of business  transactions in the ordinary course of operations;
  2. Discussions with key personnel to determine the existing standard operating procedures and controls;
  3. Reviewing GST documentation and records to ensure adequacy and compliance with legal requirements;
  4. Review of GST legal framework and tax positions adopted by the company
  5. Identifying any GST compliance gaps relevant for your business and recommending corrective actions;
  6. Classification of GST risks to identify those which require more extensive testing and evaluation.
  7. Observing financial statements to ensure that whether any tax liability to be paid;
  8. Reconciliation of GSTR-2A/2B with GSTR-3B and books of accounts.

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