GSTR-4 – Return Filing, Format, Eligibility, Rules, Due Date

If you are a Chartered Accountant engaged in filing GSTR-9 for a specific company and/or entity, there are certain items to be remembered with respect to the extension of the due date for filing GSTR-9 (Annual Return) and the Reconciliation Statement (GSTR-9C) for the financial year 2019-20. 

Since then the due date for the filing of the GSTR-9 annual return has been delayed many times for numerous reasons, including the complexity of the form and the filing, for example. 

In this post, we will share with you a list of potential explanations and/or problems behind the GSTR-9 Due Date Extended process.

For all companies and CAs, the previous year may have been a very challenging and difficult time trying to grasp the tricky shape of the GSTR-9 when measuring their monthly and quarterly returns along with their accounting books. 

Due Date Extended for GSTR-9 Filing

The CBIC has told that the time period for filing GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for 2018-19 is extended to 30 June 2020. For corporate organizations such as companies, firms and small and medium-sized enterprises with annual sales of less than Rs. 5 crores, the submission of GSTR-9C for the 2018-19 financial year (FY) has been waived.

On the other hand, there are no late fees charged for the delay in filing of GSTR-9 for firms with gross sales of less than Rs. 2 in the financial year (FY) 2017-18 and FY 2018-19.

Challenges faced by CAs during the time of filing of the GSTR-9

A variety of explanations for the difficulties or problems that may be faced by CAs are presented as follows:

(a) ITC mismatch between GSTR-2A and GSTR-9 Table 8A

This is a portion that has posed a variety of problems for taxpayers due to the mismatch between the input tax credit (ITC) seen in the GSTR-2A self-generated return and the input tax credit that is auto-populated in Table 8A of Type GSTR-9.

This may have been attributed to:

  • The Input Tax Credit (ITC) for manufacturers for the financial year 2017-18 would no longer be self-populated in GSTR-9 if the same has been declared after 30 April 2019.
  • The very last figures, having considered the changes, were seen in GSTR-9, as opposed to the gross values shown in Type GSTR-2A.
  • Input tax deductions relating to invoices for such a span of time when the recipient taxpayer has been subject to the Composition Scheme are not shown in GSTR-9.
  • Input tax credit on invoices where the location of the source lies within the State of procurement of the claimant rather than the State of collection of the tax has been excluded in GSTR-9.

(b) Bifurcation of the input tax credit available in GSTR-9 and GSTR-9C

Type GSTR-9 calls for the bifurcation of all production tax credits made available from inputs, inputs, and capital goods. This, in essence, includes a full and detailed review of the books of the accounts of the taxpayer with respect to the checking by the auditor concerned. Not all taxpayers should have maintained a database of this bifurcation leading to an unnecessary challenge in collecting these data today, in order to keep the same issue apart from wrongly reporting.

(c) the income tax credit claimed, but not expressed in GSTR-2A;

During the 2017-18 financial year in which the GSTR-3B returns were filed, taxpayers reported that the input tax credit was available under the CGST Act. However, there is a lot of input tax credit that is still not expressed in the GSTR-2A of some taxpayers. The problem that exists right here is whether such an input tax credit might be deemed ineligible, which would result in taxpayers getting warnings from the Tax Department without a fair opportunity to justify the legitimacy of such credit.

(d) Goods bought in the year 2017-18, but only claimed by ITC in the year 2018-19.

There is currently no separate area for monitoring the input tax credit claimed in the 2018-19 fiscal year for products purchased during the 2017-18 fiscal year. Since the Government has clarified that this input credit will be seen in Table 6(E) of GSTR-9, which is for the full amount of credit available between July 2017 and March 2019. Since auditors intend to compile a reconciliation statement exclusively on the basis of these records, it would have been easier for taxpayers to log this information one by one and more clearly.

(e) Overlay of estimates in Tables 6(B) and 6 (H)

Table 6(B) includes the monitoring of all inward supplies and input tax credits made available throughout the financial year, except for imports and inward supplies which are subject to reverse charges. Table 6(H) includes, on the other hand, the reporting of input tax credits that have been used, reversed, and consequently recovered for the same financial year. This culminated in overlapping estimates between Table 6(B) and Table 6(H) of the GSTR-9. While guidance has been given by the government to advise taxpayers on what the fields entail, more detail is required with examples/remediation of accounting challenges.

(f) Accountability for RCM disclosure in GSTR-9

The clarification issued by the CBIC on the declaration of legal liability under the RCM due for the 2017-18 financial year but paying for the 2018-19 financial year was vague. This is due to the fact that the press release of 4 June 2019 used the terms ‘additional external supply’ without any reference to RCM, while the Central Tax Notice of 28 June 2019 using the words ‘additional liability.’ Though taxpayers are to record the amount of such unknown liability under Table 4(G) of GSTR-9, the resulting tax portion of such liability is to be listed under ‘Tax Payable’ in Table 9.

(g) HSN basic declaration for external and inner supply

The Government has made it mandatory for the HSN summary information to be reported to all vendors with a turnover of more than Rs.1.5 crores. This necessity is controlled for both internal and outward supplies. This has created needless problems for taxpayers who have not maintained their documents in the past and are now going to have to expend a lot of extra effort and time collecting and recording this material.

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