Checklist: GST Annual return/Audit for FY 2017-18

GST Annual return (Form GSTR-9/9A)/GST Audit (Form 9C)
GST Annual return (Form GSTR-9/9A)
Financial period:                                                                       FY 01/07/2017 to 31/03/2018

Last date of filing annual return:                                              31 Dec 2018

Forms for Filing of GST Annual Return
Regular Taxpayer paying taxes under Normal Scheme:   Form GSTR-9
Taxpayer paying taxes under Composition Scheme:        Form GSTR-9A

Late fees for filing of Annual return: 
CGST
Rs. 100/- per day –Maximum 0.25% of turnover
SGST
Rs. 100/- per day –Maximum 0.25% of turnover

Consequence of failure to submit the annual GST return:

Penalty up to Rs 25,000/- (Section 125 of CGST Act, 2017)

Required documents/information GST Annual return
1.GST Return copy (GSTR-1, GSTR-3B, GSTR-4 from July 2017 to Sept 2018)
2. Purchase bill (GST bill/other bill-unregistered)
3. Invoice copy, debit, credit notes, Advance receipt/payment receipt
4. Bank statement/Cash book-showing payment to vendors to check eligible ITC
5. GST ledger, Sales book, purchase book, ITC register  (Books of account manitanied by assessee)
6.Copy of Income tax return, Balance sheet, Profit and Loss book, Tax audit report (Applicable, if any)

Required details for  GST return (Form 9)
1.       Basic Details
2.       Details of outward and inward supplies declared during the Financial Year
– Supplies made to un- registered persons (B2C)
– Supplies made to registered persons (B2B)
– Unadjusted Advances
– Inward Supplies liable to reverse charge mechanism (RCM)
– Debit/Credit Notes
– Exempted/ Nil Rated/ Non-GST Supplies
– Total Turnover (including advances)
3.       Details of ITC as declared in returns filed during the Financial Year
Inward Supplies (Classification-inputs/input services/ capital goods.)
Other ITC availed
(Note: It is important to note that the ITC which was available but not availed or was available but ineligible shall be lapsed as at the end of the Financial Year. From this it can be implied that, the reconciliation of GSTR-2A with GSTR-3B to ascertain the correct amount of credit was required to be done at the time of filing the return for the month of September. The remaining credit which was not taken in the month of September would now be lapsed and have to be booked as an expense resulting in loss of credit and profitability at the same time.
Contrary to the said situation, it is not clear, whether a taxpayer can avail the eligible credit in excess of the credit specified in GSTR-2A or not as the difference in Table 8 would be shown as negative in such case. This is owing to the fact that the taxpayer may have availed the correct amount of credit based on the invoice but the invoice may not appear in the GSTR-2A. The matter requires clarity as the taxpayer cannot be made deprived of the eligible ITC)
4.       Details of tax paid as declared in returns filed during the financial year
Details of tax payable and paid bifurcated into cash/credit utilization
5.       Particulars of the transactions for the previous Financial Year declared in returns of April to September of current Financial Year or up to the date of filing of annual return of previous Financial Year whichever is earlier
– Amendments (addition/deletion) pertaining to any supplies declared in the returns of the earlier Financial Year
– ITC availed for previous Financial Year
6.       Other Information
Others- details in relation to the refund claimed (which inter alia shall include the aggregate amount of refund filed during the Financial Year viz, sanctioned/ rejected/ pending for processing excluding provisional and non-GST refund claims).
HSN Summary: Rate-wise HSN summary of all inward and outward supplies during the Financial Year.

GST Audit ( Form GSTR 9C )

Required documents/information GST Audit

1.       Audited accounts-B/s,P& L, Tax audit, Statutory audit report
2.       GST Return copy (GSTR-1, GSTR-3B from July 2017 to Sept 2018)
3.       Purchase bill (GST bill/other bill-unregistered)
4.       Invoice copy, debit, credit notes, Advance receipt/payment receipt
5.       Bank statement/Cash book-showing payment to vendors to check eligible ITC
6.       GST ledger, Sales book, purchase book, ITC register


Details -GSTR 9C

    Taxpayers whose annual turnover exceeds Rs  2 crores during the financial year
    All such taxpayers are also required to get their accounts audited and file a copy of audited annual accounts and reconciliation statement of tax already paid and tax payable as per audited accounts along with GSTR 9C.
         This form is divided into mainly 2 parts-  
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

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 both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based an opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format for certification report will vary depending on who the certifier is.
MAJOR PROBLEM/ISSUE WHILE CARRRING OUT GST AUDIT
Major problem faced while carrying out GST audit for the financial year 2017-18
·         HSN of inward supplies is required in the annual return GSTR 9 which was not needed while filing monthly GSTR 3B.
·         Multiple audits under indirect tax laws: VAT audits and Service Tax audit may be required to be carried out for the first quarter and GST audit for the next three quarters;
·         The difference in the annual return as per the books of accounts and GST data filed during the financial year.
·         Segregated details of ITC availed are required as Inputs/Input services/ Capital Goods
·         Reporting of the amended transactions relevant to the FY 2017-18 filed in the returns of April to September of current FY or up to the filing of annual return of FY 2017-18 i.e. 31 Dec 2018, whichever is earlier.
·         Complex procedural compliance under GST
·         Lack of clarity in the GST law, frequent changes in the law, issuance of more than 300+ notifications;
·         Failure of the matching concept – whether it would be possible to identify if the supplier has failed to remit taxes to determine eligibility of credits;
·         Reliability of the audit software is not tested;
·         Absence of/incomplete mandatory records;
·         High volume of procedural lapses and non compliances by the assesses, incorrect documents/documentation procedures;
·         Transitional issues (law does address all types of transactions).

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