Tuesday, August 20, 2019

Analysis of GSTR-9 Annual Return- Question/ Answer - Part- 1

Technical Guide of Annual Return Form 
GSTR-9

Q.1 What is Annual Return Form GSTR-9?
Ans:
♠ Form GSTR-9 is an annual return to be filed once, for each financial year, by the registered
taxpayers who were regular taxpayers, including SEZ units and SEZ developers.
♠ The taxpayers are required to furnish details of purchases, sales, input tax credit or refund claimed or demand created etc in this return.
♠ In the Annual Return for F.Y 2017-18, the details pertaining to the period from July 2017 to March
2018 are to be reported.
♠ In case, the taxpayer is registered after 1st July 2017, in such case, details for the period from the
effective date of registration till 31st March, 2018 is to be provided in Annual Return.

Q.2 Who need to file Annual Return in Form GSTR-9?
Ans: Form GSTR-9 is to be filed by a person who is registered as a normal taxpayer, including SEZ
unit or SEZ developer and the taxpayers who have withdrawn from the composition scheme to normal
taxpayer any time during the year.

Q.3 Is it Mandatory to file Form GSTR-9 ?
Ans: Yes, it’s mandatory to file Form GSTR-9 for Normal Taxpayers.

Q.4 How can I as a taxpayer file Form GSTR-9. 
Ans: Navigate to Services >Returns>Annual Return to file Form GSTR-9.

Q.5 Form GSTR-9 is required to be filed at entity level or GSTIN level ?
Ans:
• Form GSTR-9 is required to be filed at GSTIN level i.e. for each registration.
• If taxpayer has obtained multiple registrations, under the same PAN, whether in the same state
or different states, he is required to file annual return for each registrations separately.

Q.6 I am a regular/normal taxpayer for part period and composition taxpayer for part period during the financial year. Do I need to file Form GSTR-9 or Form GSTR-9A?
Ans:
• You are required to file both form GSTR-9 and Form GSTR-9A.
• The period during which the taxpayer remained as a Composition Taxpayer, Form GSTR-9A is
required to be filed.
• And, for period during which the taxpayer registered as normal taxpayer, Form GSTR-9 is
required to filed.
• Both Form GSTR-9 and Form GSTR-9A for the respective tax period are required to be filed
for FY 2017-18, in such cases.

Q.7 I got my registrations cancelled in the financial year. Can I file Form GSTR-9?
Ans: Yes, the annual return needs to be filed even if the taxpayer has got his registration cancelled
during the said financial year.

Q.8 What is the due date for filing Form GSTR-9 for F.Y. 2017-18 ?
Ans: Form GSTR-9 for F.Y. 2017-18 can be filed by 30th June, 2019. In case of Filing after the due
date, late fee will be levied.

Q.9 Can I revise Form GSTR-9 return after filing ?
Ans: No, You cannot revise Form GSTR-9 Return after filing.

Q.10 What are the pre-conditions for filing Form GSTR-9 ?
Ans:
• Taxpayer must have active GSTIN during the relevant financial year as a normal/regular
taxpayer even for a single day.
• Taxpayer has filed all applicable returns i.e. Form GSTR-1 and Form GSTR-3B of the relevant
financial year before filing the Annual Return.


Q.11 Can I file nil Form GSTR-9 ?
Ans:
• Nil Form GSTR-9 can be filed for the financial year, if you have
• Not made any Outward Supply; AND
• Not received any goods/services;
• No other liability to report; AND
• Not Claimed any refund; AND
• Not received any order creating demand.


Q.12 Is there any Offline Tool for filing Form GSTR-9 ?
Ans: Yes.

Q.13 I have not filed all my applicable return(s)/ statement(s) during the financial year. Still, can I file Annual return without filing of those applicable return(s)/ statement(s)?
Ans: You cannot file return in Form GSTR-9 without filing Form GSTR-1 and Form GSTR-3B for all applicable periods during the relevant financial year.

Q.14 What are the details to be Submitted in Table-4A of GSTR-9 ?
Ans:
• Aggregate value of supplies made to consumers and unregistered persons on which tax has
been paid shall be declared here.
• It will include details of supplies made through E-Commerce operators and are to be declared
as net of credit notes or debit notes issued in this regard.
• Irrespective of the nature of supplies (Intra state or Inter State supplies) and the quantum of
supplies, they are required to be disclosed in this head.

Q.15 What are the details to be submitted in Table-4B of GSTR-9?
Ans:
• Aggregate value of supplies made to registered persons (including supplies made to UINs) on
which tax has been paid shall be declared here other than those attracting reverse charge and
supplies through e-commerce operators.
• Taxable Outward supplies to registered person through e-commerce operators.
• Details of debit and credit notes are to be mentioned separately.

Q.16 What are the details to be submitted in Table-4C of GSTR-9?
Ans:
• Aggregate value of exports (except supplies to SEZs) on which tax has been paid shall be
declared here.
• It contains information pertaining only to exports on payment of Tax and not exports without
payment of Tax.

Q.17 What are the details to be submitted in Table-4D of GSTR-9?
Ans:
• Aggregate value of supplies to SEZs on which tax has been paid shall be declared here.
• It will include supplies to SEZ whether by an SEZ to another SEZ or by a DTA unit to SEZ. It
does not include supplies to SEZ without payment of tax.

Q.18 What are the details to be submitted in Table-4E of GSTR-9?
Ans:
• Aggregate value of supplies in the nature of deemed exports on which tax has been paid shall
be declared here.
• Section 147 and NN 48/2017-Central Tax dated 18th October 2017, prescribe the following
supplies to be regarded as deemed exports
• Supply of goods against advance authorization.
• Supply of capital goods against EPCG authorization.
• Supply of goods to EOU (export oriented undertakings)
• Supply of gold by bank/PSU specified in Notification No 50/2017-Customs dated 30th June
2017.
All the above nature of supplies will be considered as deemed exports.

Q.19 What are the details to be submitted in Table-4F of GSTR-9?
Ans:
• Details of all unadjusted advances i.e. advance has been received and tax has been paid but
invoice has not been issued in the current year shall be declared here.
• As per Rule 50 of CGST Rules, upon receipt of advance , Receipt Voucher is required to be
issued but tax invoice is not required to be issued until actual supply in respect of such
advance. Tax is payable on advance even though supply is pending.
• Notification no 40/2-17-CT dated Oct 13, 2017 exempted payment of tax on advances received
towards supply of goods, in case of taxable persons whose aggregate turnover is or is likely to
be less than Rs 1.50 Cr.
• Notification no 66/2017-CT dated Nov 11, 2017 that exempts from payment of tax on advances
received towards supply of goods.
So, Advances in respect of goods is upto Nov 10, 2017 subject to above notification is liable for GST & Advances towards supply services remained liable to payment of tax on advances.

Q.20 What are the details to be submitted in Table-4G of GSTR-9?
Ans:
• Aggregate value of all inward supplies (including advances and net of credit and debit notes)
on which tax is to be paid by the recipient (i.e.by the person filing the annual return) on reverse
charge basis.
• This shall include supplies received from registered persons, unregistered persons on which tax
is levied on reverse charge basis.
• This shall also include aggregate value of all import of services.

Q.21 What are the details to be submitted in Table-4I of GSTR-9?
Ans: Aggregate value of credit notes issued in respect of B to B supplies (4B), exports (4C), supplies
to SEZs (4D) and deemed exports (4E) shall be declared here.

Q.22 What are the details to be submitted in Table-4J of GSTR-9?
Ans: Aggregate value of debit notes issued in respect of B to B supplies (4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E) shall be declared here.

Q.23 What are the details to be submitted in Table-4K & 4L of GSTR-9?
Ans: Details of amendments made to B to B supplies (4B), exports (4C), supplies to SEZs (4D) and
deemed exports (4E), credit notes (4I), debit notes (4J) and refund vouchers shall be declared here.

Q.24 What are the details to be submitted in Table-5A of GSTR-9?
Ans:
• Aggregate value of exports (except supplies to SEZs) on which tax has not been paid shall be
declared here.
• Exports made under LUT or bond without payment of integrated tax shall be declared here.
• NN 37/2017- Central tax, dated Oct 4, 2017 extended the facility of LUT to all exporters under
rule 96A of CGST Rules except those who have been prosecuted for any offence under the
CGST Act or the IGST Act or any of the existing laws and the amount of tax tax evaded in
such cases exceeds Rs 250 lakhs.
• Circular No 8/8/2017-GST, dated Oct 4, 2017 has clarified that the LUT shall be valid for the
whole financial year in which it is tendered.

Q.25 What are the details to be submitted in Table-5B of GSTR-9?
Ans:
• Aggregate value of supplies to SEZs on which tax has not been paid shall be declared here.
• As per section 16 of IGST Act Supplies to SEZ developer or SEZ unit is a zero rated supply
with options available to either supply goods or services under bond or LUT without payment
of tax or supply of goods or services with payment of tax.
• Circular No 48/22/2018-GST, dated 14 Jun-2018 has clarified that the supplies to a SEZ
developer or a SEZ unit shall be zero rated and the supplier shall be eligible for refund of
unutilized input tax credit or integrated tax paid, as the case may be, only if such supplies have
been received by the SEZ developer or SEZ unit for authorized operations.

Q.26 What are the details to be submitted in Table-5C of GSTR-9?
Ans:
• Aggregate value of supplies made to registered persons on which tax is payable by the recipient
on reverse charge basis.
• Details of debit and credit notes are to be mentioned separately.
• Services provided by an individual advocate including a senior advocates by way of legal
services, directly or indirectly to any business entity located in taxable territory. The Value of
such services shall be reported in Table-5C of GSTR-9.

Q.27 What are the details to be submitted in Table-5D, 5E, 5F of GSTR-9?
Ans:
• Aggregate value of exempted, Nil Rated and Non-GST supplies shall be declared here.
• Their is no clarity between exempted and nil rated supply in law since the lawmakers have not
provided any definition of nil rated supply.
• Non GST supply is not defined anywhere in GST law.
• Recently, An Explanation is also inserted in section 17 (3) of CGST Act vide Central Goods
and Services tax (Amendment ) Act, 2018, dated 29-Aug-2018, that the Value of exempt
supply shall not include the value of activities or transactions specified in Schedule III, except
those specified in paragraph 5 of said schedule.

Q.28 What are the details to be submitted in Table-5H of GSTR-9?
Ans: Aggregate value of credit notes issued in respect of supplies declared in 5A, 5B, 5C, 5D, 5E and
5F shall be declared here.

Q.29 What are the details to be submitted in Table-5I of GSTR-9?
Ans: Aggregate value of debit notes issued in respect of supplies declared in 5A, 5B, 5C, 5D, 5E and
5F shall be declared here.

Q.30 What are the details to be submitted in Table-5J & 5K of GSTR-9?
Ans: Details of amendments made to exports (except supplies to SEZs) and supplies to SEZs on which tax has not been paid shall be declared here.

Q.31 What is Table 5N?
Ans:
• Total turnover including the sum of all the supplies (with additional supplies and amendments)
on which tax is payable and tax is not payable shall be declared here.
• This shall also include amount of advances on which tax is paid but invoices have not been
issued in the current year.
• This shall not include the aggregate value of inward supplies on which tax is paid by the
recipient (i.e. by the person filing the annual return) on reverse charge basis.

Q.32 What is Table -6A?
Ans: Total input tax credit availed in Table 4A of FORM GSTR-3B for the taxpayer would be autopopulated here.

Q.33 What are the details to be submitted in Table-6B of GSTR-9?
Ans:
• Aggregate value of input tax credit availed on all inward supplies except those on which tax is
payable on reverse charge basis but includes supply of services received from SEZs shall be
declared here.
• Total ITC availed is to be classified as ITC on inputs, capital goods and input services.
• Supply of goods from SEZ shall not be included as no tax invoice is raised by SEZ for such
supply.
• Input tax credit which was availed, reversed and subsequently reclaimed in ITC ledger shall not
be declared here.
• For Eg. Credits which are reversed on account of non payment to vendor within 180 days as
required under second proviso to section 16 (2). When payment is made, the Registered person
is eligible for reclaim the credit.

Q.34 What are the details to be submitted in Table-6C of GSTR-9?
Ans:
• Aggregate value of input tax credit availed on all inward supplies received from unregistered
persons (other than import of services) on which tax is payable on reverse charge basis shall be
declared here.
• Reverse charge on supply received from URP was introduced in GST Act w.e.f. 01.07.2017,
but later in Oct 13, 2017 the government withdrawn the same.
• Therefore, Clause 9C will contain data relating to inward supplies received from unregistered
Persons liable to GST u/s 9(4) from Jul 1,2017 to Oct 12,2017 only.
• Total ITC availed is to be classified as ITC on inputs, capital goods and input services.

Q.35 What are the details to be submitted in Table-6D of GSTR-9?
Ans:
• Aggregate value of input tax credit availed on all inward supplies received from registered
persons on which tax is payable on reverse charge basis shall be declared here.
• In this table, the taxable person should report aggregate value of input tax credit availed on all
inward supplies (of Input, Input Services and capital goods) as received from Registered
Persons on which he is liable to pay tax under reverse charge as per section 9(3) of CGST Act,
2017/IGST ACT,2017

Q.36 What are the details to be submitted in Table-6E of GSTR-9?
Ans:
• Details of input tax credit availed on import of goods including supply of goods received from
SEZs shall be declared here.
• Total ITC availed is to be classified as ITC on inputs, capital goods and input services.
• Table 6E of GSTR-9 contains input tax credit availed on all bill of entries filed on goods
imported during the period July 2017 to March 2018.

Q.37 What are the details to be submitted in Table-6F of GSTR-9?
Ans: Table 6F Contains the aggregate value of Input tax credit availed on all import of services
(excluding inward supplies from SEZs) where tax has been paid under reverse charge by the recipient
of services.

Q.38 What are the details to be submitted in Table-6G of GSTR-9?
Ans:
• Aggregate value of input tax credit received from input service distributor shall be declared
here.
• Registered Person should be in possession of invoice issued by ISD u/r 54(1) of CGST Rules.
• It is also relevant that ineligible portion of ITC distributed should not be availed as ITC.

Q.39 What are the details to be submitted in Table-6H of GSTR-9?
Ans:
• Aggregate value of input tax credit availed, reversed and reclaimed under the provisions of the
Act shall be declared here.
• For Example, ITC reversed on account of non payment to vendor within 180 days. When
payment is made, the Registered Person is eligible to reclaim the credit. Such credits are to be
reported in Table 6H.

Q.40 What is Table 6J?
Ans:
• The difference between the total amount of input tax credit availed through FORM GSTR-3B
and input tax credit declared in row B to H shall be declared here. Ideally, this amount should
be zero.

Q.41 What is Table 6K?
Ans: Details of transition credit received in the electronic credit ledger on filing of FORM GST
TRAN-I including revision of TRAN-I (whether upwards or downwards), if any shall be declared here.

Q.42 What is Table 6L?
Ans: Details of transition credit received in the electronic credit ledger after filing of FORM GST
TRAN-II shall be declared here.

Q.43 What is Table 6M?
Ans:
• Details of ITC availed but not covered in any of heads specified under 6B to 6L above shall be
declared here.
• Details of ITC availed through FORM ITC01 and FORM ITC-02 in the financial year shall be
declared here.
• Example 1, Credit availed under section 18(1)(a) to 18(1)(d) of the CGST Act, 2017 it to be
disclosed here.
• Example 2, Credit availed under section 18(3) read with Rule 41(1) of CGST Rules,2017 on
account of sale, merger, demerger, amalgamation, lease or transfer of a business is to be
disclosed here.

For more Question/ Answer - >>Next Post Part - 2


Source : GSTN Website (www.gst.gov.in) and ICAI Technical Guide

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