FORM GSTR-9C – ANNUAL AUDITED RECONCILIATION REPORT UNDER GST FOR TAXPAYERS WHOSE AGGREGATE TURNOVER EXCEEDS RS. 2 CRORES.
The Goods and Services Tax Act, 2017 came into force in
India with effect from 1.7.2017.
The regular taxpayers irrespective of turnover has to
file consolidated return in FORM GSTR-9 and the composition taxpayers
irrespective of turnover has to file consolidated return in FORM GSTR-9A before
31.12.2018 for the period from July 2017 to March 2018 (for 9 months only)
under Section 35 of the CGST Act, 2017.
The taxpayers whose aggregate turnover during the
financial year 2017-18 exceeds 2 crores will have to submit audited annual
accounts and a reconciliation statement in FORM GSTR-9C (in addition to FORM
GSTR-9) before 31.12.2018.
Filing of FORM GSTR-9C i.e.
Annual audited Statement will not be applicable to the Composition Taxpayers as
their aggregate turnover is limited to Rs.1.5 Crores
The FORM GSTR-9C contains the following tables with
sub-headings.
Basic Details
Reconciliation of turnover
declared in audited Annual Financial Statement with turnover declared in Annual
Return (GSTR-9)
Reconciliation of tax paid
Reconciliation of Input Tax
Credit (ITC)
Auditor’s recommendations on
additional liability due to non reconciliation
From July 2017 to till date all taxpayers were furnishing
only FORM GSTR-3B and GSTR FORM-1 i.e. outward supply details.
FORM GSTR-2 i.e. inward details were not furnished by the
recipients so far. The accuracy of inward
with the other end suppliers was not reconciled.
In the GST Portal GSTR-2A details were made available in
Excel Format for download purpose from 31.8.2018 (which was available for view
purpose only upto 30.8.2018). Hence the
taxpayers can download FORM GSTR-2A i.e. purchase details which is available in
Excel Formal for verification of Input Tax Credit and auditing purpose. Then only the correct Input Tax Credit will
be reconciled between the supplier and the recipient otherwise there may be
chances of difference of Input Tax Credit and in such cases recipient has to
pay GST on the difference of turnover.
The guidelines to fill the details in FORM GSTR-9C were
available in the form itself at the
bottom..
The Central Government Notification is given below for
ready reference:
Instructions: –
1. Terms used:
(a) GSTIN: Goods and Services
Tax Identification Number
2. The details for the period between July 2017 to March 2018 are to be provided in this statement for the financial year 2017-18. The reconciliation statement is to be filed for
every GSTIN separately.
3. The reference to current financial year in this statement is the financial year for which the reconciliation statement is being filed for.
4. Part II consists
of reconciliation of the annual turnover declared in the audited Annual Financial Statement with the turnover as declared in the Annual Return furnished in FORM
GSTR-9 for
this GSTIN. The instructions to fill this part
are
as follows :-
Table No.
|
Instructions
|
5A
|
The turnover as per the audited Annual Financial Statement
shall be declared
here. There may be cases where multiple GSTINs (State-wise) registrations exist on the same PAN. This is common for persons / entities with presence
over multiple States. Such persons / entities, will have to internally derive their GSTIN wise turnover and declare the same here. This shall include export turnover (if any). It may
be noted that reference to audited Annual
Financial Statement includes reference to books of accounts in case of persons
/ entities having
presence over multiple States.
|
5B
|
Unbilled revenue which was recorded in the books of accounts on the basis of
accrual system of accounting
in the last financial year and was carried forward
to the current financial year shall be declared here. In other words, when GST
is payable during the financial year on such revenue (which was recognized earlier), the
value of such revenue
shall be declared here.
(For example, if rupees Ten Crores
of unbilled
revenue existed for the financial year 2016-17, and during
the current financial year, GST was paid on rupees Four
Crores of
such revenue, then value of rupees Four Crores rupees shall be declared
here)
|
5C
|
Value of all advances for which GST has been paid but the same has not been
recognized as revenue in the audited Annual Financial
Statement shall be declared
here.
|
5D
|
Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017
shall be declared
here. Any deemed supply
which is already part of
the
turnover in the audited Annual Financial Statement is not required to be included here.
|
5E
|
Aggregate value of credit notes which were issued after 31st of March for any
|
supply accounted
in the current financial
year but such
credit notes were
reflected in the annual return
(GSTR-9)shall
be declared
here.
|
|
5F
|
Trade
discounts which are accounted for in
the audited Annual Financial
Statement
but on which GST was leviable(being not permissible) shall
be declared
here.
|
5G
|
Turnover
included in the audited Annual Financial Statement for April 2017 to
June 2017 shall be declared
here.
|
5H
|
Unbilled revenue which was recorded in the books of accounts
on the basis of
accrual system
of accounting during the current financial
year but GST was
not payable on such revenue in the same
financial year shall be declared
here.
|
5I
|
Value of all advances for which GST has not been paid but the same has been
recognized as revenue in the audited Annual Financial
Statement shall be declared
here.
|
5J
|
Aggregate value of credit notes which have been accounted for in the audited
Annual Financial Statement but were not admissible
under Section 34 of the
CGST Act shall be declared
here.
|
5K
|
Aggregate value of all goods supplied by SEZs to DTA
units for which the
DTA units
have filed bill
of entry shall be declared
here.
|
5L
|
There may be cases where registered persons
might have opted out of the
composition scheme during the current financial year. Their turnover as per the
audited Annual Financial
Statement would include
turnover both as composition taxpayer
as well as normal taxpayer. Therefore, the turnover for which
GST was paid under
the composition scheme shall be declared
here.
|
5M
|
There may be cases
where the
taxable value
and the invoice value
differ due to
valuation principles under section 15 of the CGST Act, 2017 and
rules thereunder. Therefore, any
difference between the turnover reported in the Annual Return
(GSTR
9)
and
turnover reported
in the audited
Annual
Financial Statement
due to difference in valuation of supplies shall be declared here.
|
5N
|
Any difference between the turnover reported in the Annual Return (GSTR9)
and turnover reported
in the audited
Annual Financial Statement due
to
foreign exchange fluctuations shall be declared
here.
|
5O
|
Any difference between the turnover reported in the Annual Return (GSTR9)
and turnover reported
in the audited
Annual Financial Statement due
to
reasons
not listed above shall be declared
here.
|
5Q
|
Annual turnover as declared in the Annual Return
(GSTR 9) shall
be declared
here. This turnover may be derived from Sr. No. 5N,
10 and 11 of Annual
|
Return (GSTR 9).
|
|
6
|
Reasons
for non-reconciliation between the annual turnover declared in the
audited Annual Financial Statement
and turnover as declared in the Annual
Return (GSTR 9) shall be specified
here.
|
7
|
The table
provides for reconciliation of taxable turnover from the audited
annual turnover after adjustments with the taxable turnover declared in annual return
(GSTR-9).
|
7A
|
Annual turnover as
derived in Table 5P above would be auto-populated here.
|
7B
|
Value of exempted,
nil
rated, non-GST and
no-supply
turnover shall be
declared
here. This shall
be reported
net of credit
notes, debit notes and amendments if
any.
|
7C
|
Value of zero rated supplies (including supplies to SEZs) on which tax is not
paid shall be declared here. This
shall be reported net of credit notes,
debit notes and amendments if any.
|
7D
|
Value of reverse charge supplies on which tax is to be paid by the recipient
shall be declared here. This shall
be reported net of credit notes,
debit notes and
amendments if any.
|
7E
|
The taxable turnover is derived as the difference between the annual turnover
after adjustments
declared in Table 7A above and the sum of all supplies
(exempted, non-GST, reverse charge
etc.) declared in Table 7B, 7C and 7D
above.
|
7F
|
Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall
be declared
here.
|
8
|
Reasons
for non-reconciliation
between adjusted annual taxable turnover as
derived from Table 7E above and the taxable turnover declared in Table 7F
shall be specified here.
|
5. Part III consists of reconciliation
of the tax payable as
per declaration
in the reconciliation
statement and the actual tax paid as declared in Annual Return (GSTR9). The instructions
to fill this part are as
follows :-
Table No.
|
Instructions
|
9
|
The table provides
for reconciliation of tax paid as
per reconciliation
statement
and amount of tax paid as declared in Annual Return
(GSTR 9). Under the
head labelled ―RC‖, supplies where tax was paid on reverse charge basis
by the recipient (i.e. the
person for whom reconciliation
statement has been
prepared ) shall be declared.
|
9P
|
The total amount
to be paid as per liability declared in Table 9A to 9O is auto
populated here.
|
9Q
|
The amount payable as declared in Table
9 of the Annual Return (GSTR9)
shall be declared here. It should also contain any differential tax paid on Table
10 or 11 of
the Annual Return (GSTR9).
|
10
|
Reasons
for non-reconciliation between payable
/ liability declared in Table
9P above and the
amount payable
in Table 9Q shall be specified here.
|
11
|
Any amount
which is payable due to
reasons specified under Table 6,
8 and 10
above shall be declared here.
|
6.
Part IV consists
of reconciliation of Input Tax Credit (ITC). The instructions to fill Part
IV are as
under:-
Table No.
|
Instructions
|
12A
|
ITC availed (after reversals) as per the audited Annual Financial Statement
shall be declared here. There may be cases where multiple GSTINs (State-
wise) registrations exist
on the same PAN. This is common for
persons / entities with presence over multiple States. Such persons
/ entities, will have to
internally derive their ITC for each individual GSTIN and declare the same
here. It may be noted that reference to audited Annual Financial Statement includes reference to books of accounts in case
of persons / entities having
presence over
multiple States.
|
12B
|
Any ITC which was booked in the audited Annual Financial Statement of
earlier financial year(s)but availed in the ITC ledger
in the financial yearfor
which the reconciliation
statement is being filed for shall be declared here.
This shall include transitional credit which was booked in earlier years but availed duringFinancial Year
2017-18.
|
12C
|
Any ITC which has been booked in the audited Annual Financial Statement of
the current financial year but the same has not been credited to the ITC ledger for
the said financial year shall
be declared here.
|
12D
|
ITC
availed as per audited Annual Financial Statement or books of accounts
as derived from values declared in Table 12A,
12B and 12C above will be
auto-populated here.
|
12E
|
Net ITC available for utilization as declared in Table 7J of Annual Return
(GSTR9)
shall be declared
here.
|
13
|
Reasons for non-reconciliation of ITC
as per
audited Annual Financial
Statement or
books
of
account (Table 12D)
and the net
ITC (Table12E)
|
availed
in the Annual Return
(GSTR9) shall be specified here.
|
|
14
|
This table is for reconciliation
of ITC declared in the Annual Return
(GSTR9)
against the expenses
booked in the audited Annual Financial Statement or
books of account. The various sub-heads specified under this table are general
expenses in the audited Annual Financial Statement or books of account
on which ITC may or may not be available.
Further, this is only an indicative list of heads under which expenses are generally
booked. Taxpayers may add or delete any of these heads but all heads of expenses
on which GST has been paid
/ was payable are to
be declared here.
|
14R
|
Total ITC declared in Table
14A to 14Q above shall be auto
populated here.
|
14S
|
Net ITC availed as declared in the Annual Return (GSTR9) shall be declared
here. Table
7J of the Annual Return (GSTR9) may be used for filing
this
Table.
|
15
|
Reasons
for non-reconciliation
between ITC availed on the various
expenses
declared in Table
14R and ITC declared in Table 14S shall
be specified here.
|
16
|
Any amount
which is payable due to reasons specified in Table 13 and 15
above shall be declared here.
|
7. Part V consists
of
the
auditor’s recommendation
on
the
additional
liability
to be discharged by
the taxpayer due to non-reconciliation of turnover or non-reconciliation of input tax credit. The auditor shall also recommend if there is any other amount to be paid for
supplies not included in the Annual Return. Any refund which has been erroneously taken
and
shall be paid back to the
Government shall also be declared in this
table. Lastly, any other outstanding demands which is recommended to be settled by the auditor shall
be declared in this Table.
8. Towards, the end of the reconciliation statement taxpayers shall be given an option to pay their
taxes as recommended
by
the auditor.
PART – B- CERTIFICATION
I. Certification in cases where the reconciliation statement (FORM GSTR-9C)
is drawn up by the person who had conducted the audit:
* I/we have examined the—
(a) balance sheet
as on ………
(b) the *profit and loss account/income and expenditure account
for the period beginning
from ………..…to ending on
……., and
(c) the cash flow statement for the period beginning from ……..…to ending on ………, —
attached herewith, of M/s ……………
(Name), …………………….………… (Address),
..…………………(GSTIN).
2.
Based on our
audit I/we report
that the said registered person—
*has maintained the books of accounts,
records and
documents as
required
by the
IGST/CGST/<<>>GST Act,
2017 and the rules/notifications
made/issued thereunder
*has not maintained the following accounts/records/documents as required by the
IGST/CGST/<<>>GST Act,
2017 and the rules/notifications made/issued
thereunder:
1.
2.
3.
3.
(a) *I/we report
the following observations/
comments / discrepancies / inconsistencies; if any:
…………………………………….
…………………………………….
3.
(b) *I/we further report that, -
(A) *I/we have obtained all the information and explanations which, to the best of *my/our knowledge and belief, were necessary
for the purpose of the audit/ information and
explanations which, to the best of *my/our knowledge and belief, were necessary
for the
purpose of the audit were not provided/partially provided
to us.
(B) In *my/our opinion, proper books of account *have/have not been kept by the registered
person so far as appears from*my/ our examination of the
books.
(C) I/we certify that the balance sheet, the *profit and loss/income and expenditure account and the cash flow Statement are
*in agreement/not in agreement with the books of account
maintained at the
Principal
place of
business at ……………………and
**
……………………additional place of business
within
the
State.
4. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be
furnished under section 44(2) of
the CGST Act is
annexed
herewith
in Form
No. GSTR-9C.
5. In *my/our opinion and to the best of *my/our information
and according to explanations
given to *me/us, the particulars given in the said Form No.GSTR-9C are
true and correct subject
to following observations/qualifications,
if any:
(a) ……………………………………………………………………………………
(b) …………………………………………………………………………………… (c) ……………………………………………………………………………………
………………………………………
………………………………………
**(Signature and
stamp/Seal of the Auditor)
Place: ……………
Name of
the signatory ………………… Membership No………………
Date: ……………
Full address
………………………
II. Certification in cases
where the reconciliation statement (FORM GSTR-9C) is
drawn up by
a person other than the person who had conducted the audit
of the accounts:
*I/we report that the audit of the books of accounts and the financial statements
of M/s.
………...........…………………. (Name and address of
the assessee with GSTIN)
was conducted by M/s. …………………………………………..………. (full name and address
of auditor along with status), bearing membership number in
pursuance of the provisions of the …………………………….Act, and *I/we annex hereto a copy
of their audit report dated
……………………………. along with a copy of each of :-
(a) balance sheet
as on ………
(b) the *profit and loss account/income and expenditure account for the
period beginning
from ………..…to ending on …….,
(c) the cash flow statement for
the period beginning from
……..…to ending on ………, and
(d) documents
declared
by
the said Act
to be part of, or annexed to, the *profit and loss account/income
and expenditure account and
balance sheet.
2. I/we report that
the
said registered
person—
*has maintained
the books of accounts, records and
documents as required
by
the
IGST/CGST/<<>>GST Act,
2017 and the rules/notifications
made/issued thereunder
*has not maintained the following accounts/records/documents as required by the
IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued
thereunder:
1.
2.
3.
3. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be
furnished under section 44(2) of
the CGST Act is
annexed
herewith
in Form
No.GSTR-9C.
4. In *my/our opinion and to the best of *my/our information and according to examination of books of account
including other
relevant documents and explanations given to *me/us, the particulars given in the said Form No.9C are
true and correct subject to the following observations/qualifications,
if any:
(a) …………………………….…………………………….………………………
(b) …………………………….…………………………….……………………… (c) …………………………….…………………………….………………………
………………………………………
**(Signature and
stamp/Seal of the Auditor)
Place: ……………
Name of
the signatory ………………… Membership No………………
Date: ……………
Full address
………………………‖.
[F. No. 349/58/2017-GST
(Pt.)]
(Gunjan Kumar Verma)
Under Secretary to
the Government of India
Note:- The principal rules were published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i) vide notification No. 3/2017-Central Tax, dated the 19th June,
2017, published vide number G.S.R 610 (E), dated the 19th June, 2017 and last amended
vide notification No. 48/2018-Central Tax, dated the
10th September, 2018, published vide number G.S.R 859 (E), dated
the 10th September, 2018.