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24 Certification : Part B of

Form GSTR-9C

24.1 Introduction
As mentioned in the earlier Chapters, Form GSTR-9C (Reconciliation
Statement) is divided into two parts namely Part A and Part B. The Part
A is further divided into five sub-parts. The nature and information re-
quired to be declared in each of the clauses of sub-parts are discussed
in Chapter 19 to Chapter 23.
The Chartered Accountant is required to certify the reconciliation
statement prepared in Form GSTR-9C as per the format of certification
given in Part B. The two forms of certificate are given in Part B. The
heading of two forms are as follows:
I. Certification in cases where the reconciliation statement (FORM
GSTR-9C) is drawn up by the person who had conducted the
audit.
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.
It is evident from the above that certification in Form I is applicable
when reconciliation statement has been drawn-up by the person who
has conducted the audit. The Form-II is applicable when reconciliation
statement is drawn-up by the person who had not conducted the audit.
The analysis of provision relating to issuance of certificate are discussed
in this chapter.

24.2 Contents
The contents of this chapter are as follows:
(a) Certification as per Form I (Refer paras 24.3 to 24.9)
(b) Certification as per Form II (Refer paras 24.10 to 24.12)

221
Para 24.6 Certification : Part B of Form GSTR-9C 222

24.3 Certification as per Form I


The provisions are discussed in the following paras:
(a) Person required to issue certificate (Refer para 24.4)
(b) Nature of certification (Refer para 24.5)

24.4 Person required to issue certificate


The certificate in Form I is to be provided where reconciliation is
drawn-up by the person who has conducted the audit of annual finan-
cial statement. The requirement of conducting the audit is contained in
different statutes for different purposes. For example, if the registered
person is a company, he is required to get the accounts audited from
practising Chartered Accountant under the Companies Act, 1956 and also
file the accounts with the Registrar of companies. Similarly, under The
Co-operative Societies Act, the accounts are required to be audited by
the auditor. There can be other Statutes, under which annual financial
statement are required to be audited.
If the reconciliation statement in Form GSTR-9C is drawn-up by the
Chartered Accountant who has audited the accounts as mentioned
above, then he is required to issue the certificate in Form I.
Since, the Chartered Accountant himself has audited the accounts, the
certificate on balance sheet and profit & loss accounts, etc. will also
be provided by him. It will therefore be observed from the format of
certificate in Form I that he certifies the examination of the annual
financial statement also.

24.5 Nature of certification


The provisions on nature of certification are discussed in the following
paras:
(a) Maintenance of books of account (Refer para 24.6)
(b) Obtaining information and explanation (Refer para 24.7)
(c) Documents required to be attached (Refer para 24.8)
(d) Certification of True & Correct (Refer para 24.9)

24.6 Maintenance of books of account


The auditor is required to certify that registered person has/has not
maintained proper books of account. The requirement of maintaining
the books of account are discussed in the following sub-paras:
223 Maintenance of books of account Para 24.6

(a) Registered person (Refer para 24.6-1)


(b) Owner or Operator of godown (Refer para 24.6-2)
(c) Notification by Commissioner (Refer para 24.6-3)
(d) Verification (Refer para 24.6-4)

24.6-1 Registered Person


Every registered person is required to maintain records as per the
provisions of Section 35 of the GST Act read with Rule 56 to Rule 58.
Section 35(1) of the GST Act is reproduced below:
“35. (1) Every registered person shall keep and maintain, at his principal
place of business, as mentioned in the certificate of registration, a true
and correct account of—
(a) production or manufacture of goods;
(b) inward and outward supply of goods or services or both;
(c) stock of goods;
(d) input tax credit availed;
(e) output tax payable and paid; and
(f) such other particulars as may be prescribed:
Provided that where more than one place of business is specified in the
certificate of registration, the accounts relating to each place of business
shall be kept at such places of business.”
The Rule 56 of the GST Rules in exercise of power under Section
35(1)(f) of the GST Act provides for maintenance of certain records in
sub-rules (1) to (5) which are reproduced below:
“56. Maintenance of accounts by registered persons.—(1) Every registered
person shall keep and maintain, in addition to the particulars mentioned
in sub-section (1) of section 35, a true and correct account of the goods
or services imported or exported or of supplies attracting payment of tax
on reverse charge along with the relevant documents, including invoices,
bills of supply, delivery challans, credit notes, debit notes, receipt vouchers,
payment vouchers and refund vouchers.
(2) Every registered person, other than a person paying tax under section
10, shall maintain the accounts of stock in respect of goods received
and supplied by him, and such accounts shall contain particulars of the
opening balance, receipt, supply, goods lost, stolen, destroyed, written
off or disposed of by way of gift or free sample and the balance of stock
including raw materials, finished goods, scrap and wastage thereof.
Para 24.6 Certification : Part B of Form GSTR-9C 224

(3) Every registered person shall keep and maintain a separate account
of advances received, paid and adjustments made thereto.
(4) Every registered person, other than a person paying tax under section
10, shall keep and maintain an account, containing the details of tax
payable (including tax payable in accordance with the provisions of
sub-section (3) and sub-section (4) of section 9), tax collected and paid,
input tax, input tax credit claimed, together with a register of tax invoice,
credit notes, debit notes, delivery challan issued or received during any
tax period.
(5) Every registered person shall keep the particulars of—
(a) names and complete addresses of suppliers from whom he has
received the goods or services chargeable to tax under the Act;
(b) names and complete addresses of the persons to whom he has
supplied goods or services, where required under the provisions of
this Chapter;
(c) the complete address of the premises where goods are stored by him,
including goods stored during transit along with the particulars of
the stock stored therein.”
u Record by agents, manufacturer, supplier of service or person
executing works contract
This rule also specifies the maintenance of additional records by agents,
manufacturer, person supplying services and person executing works
contract in sub-rules (11), (12), (13) & (14) respectively. These sub-rules
are reproduced below:
(11) “Every agent referred to in clause (5) of section 2 shall maintain
accounts depicting the,—
(a) particulars of authorisation received by him from each principal
to receive or supply goods or services on behalf of such principal
separately;
(b) particulars including description, value and quantity (wherever
applicable) of goods or services received on behalf of every principal;
(c) particulars including description, value and quantity (wherever
applicable) of goods or services supplied on behalf of every principal;
(d) details of accounts furnished to every principal; and
(e) tax paid on receipts or on supply of goods or services effected on
behalf of every principal.
(12) Every registered person manufacturing goods shall maintain monthly
production accounts showing quantitative details of raw materials or

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