GSTN has clarified some issue on GSTR-9 and GSTR-9C through its new press release dated 15th June 2018. There are lots of confusion to file GSTR-9 and GSTR-9C regarding ITC mismatches, auto population of ITC, aggregate turnover and more. So GSTN has clarified all these things in the press release. Here is the text of the this press release. You can also download the press release in PDF format.
Issues reported in filing Form GSTR 9C by the taxpayers:
Taxpayers have reported some issues in filing their Form GSTR 9C, which are clarified below:
1. Turnover for filing Form GSTR- 9C: Form GSTR-9C is to be filed by all those taxpayers whose aggregate turnover has exceeded Rs 2 crore in a financial year. Turnover of
complete year i.e. from 1st April, 2017 to 31st March, 2018 has to be taken into account for calculating the turnover. For example, if a taxpayer has a turnover of Rs. 2.1 Cr for
the period 1st April, 2017 to 31st March, 2018 and a turnover of Rs. 1.9 Cr for the period 1st July, 2017 to 31st March, 2018, then the taxpayer is required to file form
2. Issues reported in filing Form GSTR 9 by the taxpayers: Steps to be taken
Taxpayers have reported some issues in filing their Form GSTR 9, which are clarified below:
a. Some taxpayers have reported that figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not match with the figures as appearing in their Form GSTR-2A. Please note that this may happen due to following reasons:
i) Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form GSTR-1 of the supplier taxpayer. But figures in table 8A of Form GSTR- 9 are auto- populated only on the basis of filed Form GSTR-1 by the supplier taxpayer. In case, Form GSTR -1 is not filed by your supplier, then credit related to those invoices will not appear in table 8A of your Form GSTR-9.
ii) Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR-1, which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019. Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April, 2019, will not get auto-populated in table 8A of Form GSTR-9.
iii) In table 8A of Form GSTR-9, only latest values have been auto-populated based on filed Form GSTR-1, taking into account all the amendments made, if any. Suppose an invoice with taxable value of Rs 100/- with tax of Rs. 18/- was filed in Form GSTR-1 in the month of January, 2018 and same was amended to Rs 90 as taxable value in the month of March, 2018, then
• The Form GSTR-2A of January, 2018 will show ITC of Rs. 18
• The Form GSTR-2A of March, 2018 will show ITC of Rs 16.20 &
• The table 8A of Form GSTR-9 will contain ITC of Rs 16.20.
iv) In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in which place of supply lies in supplier’s taxpayers State, instead of State of the receiver taxpayer. These figures will be shown in Form GSTR-2A of the recipient. For example if a taxpayer of State A visits State B and stays in a hotel in State B, the tax paid by him to the hotel in State B will appear in his Form GSTR-2A, but the same will not be reflected in table 8A of Form GSTR-9.
v) The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the recipient taxpayer was under composition scheme.
b. While filing Form GSTR 9 ‘Proceed to File’ button will be enabled only if ‘Compute Liability’ is clicked. This button is meant for computation of late fees only. Please
note Form GSTR 9 once filed cannot be revised.
3. User getting error message while using Excel version: You are also advised to use Microsoft excel version higher than 2007 while preparing Form GSTR 9C.
4. Providing Membership Number by Auditor: While filing Part B of Form GSTR-9C, Auditors are advised to give their membership number without prefixing ‘0’ in their
membership number. If membership number is ‘016’, then auditor should enter ‘16’ on the aforesaid part in the membership number field & not ‘016’. All the taxpayers are requested to file their FORM GSTR 9C at the earliest, to avoid last minute rush and to avoid payment of late fee.