Final GST Annual Return - 9 + 9C NB 101222 FY 2122

Annual Return in Form GSTR 9 & Self
Reconciliation Statement in Form GSTR

9C – FY 2122
under GST Acts, 2017.
Presented by
CA Nitin Bhuta, Mumbai
E-mail: nitin.bhuta@gmail.com
Mobile No 9820295319
Objective: Circulated only for educational Purpose.
Disclaimer
• All views stated are my personal views they are not binding on
WIRC/ICAI. My personal views may be correct/incorrect as they are
expressed based on my understanding of the subject.
• All members/listeners are requested to go through tax law provisions
on their own and advise their clients accordingly as each situations is
peculiar in itself.
• All Illustrations provided are imaginary and any resemblance to any
situations is purely co-incidental and without any intentions to
disclose private and confidential information.
CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail:

nitin.bhuta@gmail.com
Overview of Presentation
Sr No Description
1 Foundation
2 GST Annual Returns Process
3 E Way Bill Flow Chart
4 E Way Bill Flow Chart – Outward Reconciliations
5 E Way Bill Flow Chart – Inward Reconciliations
6 Changes in Annual Return – Form GSTR 9
7 Changes in Self Reconciliation Statement – Form GSTR 9C.

8 Annual Return – Form GSTR 9
9 Illustrations
10 Self Reconciliation Statements – GSTR 9C
11 Basic Document Requirements

12 Conclusion

Foundation

Basic Definitions
Income Tax – Section 2 GST – Section 2
• 13)
( "business" includes any trade, • 17) “business” includes —
(
commerce or manufacture or any • (a) any trade, commerce, manufacture, profession,

vocation, adventure, wager or any other similar activity,
adventure* or concern in the nature of whether or not it is for a pecuniary benefit;
trade, commerce or manufacture;
• (b) any activity or transaction in connection with or
incidental or ancillary to sub-clause (a);
• ………….specified Professions under • (c) any activity or transaction in the nature of sub-clause
(a), whether or not there is volume, frequency,
section 44AA -legal, medical, engineering or continuity or regularity of such transaction; (one of
architectural or accountancy or authorized transaction of self redevelopment)
representative or technical consultancy or • (d) supply or acquisition of goods including capital goods
interior decoration, film artist, Company and services in connection with commencement or closure
Secretary, Information Technology or other of business;
notified + Authorised representative • Comment : Definition is much wider in terms of the
definition given

Basic Definitions
Income tax – Section 2 GST – Section 2
• (17) “business” includes —
• (12A) "books or books of account" • (e) provision by a club, association, society, or any such
body (for a subscription or any other consideration) of the
includes ledgers, day-books, cash books, facilities or benefits to its members; ( activities that also can
account-books and other books, whether be considered – in the cases self redevelopment)
kept in the written form or in electronic • (f) admission, for a consideration, of persons to any premises;
form or in digital form or as print-outs of • (g) services supplied by a person as the holder of an office which
has been accepted by him in the course or furtherance of his
data stored in such electronic form or in trade, profession or vocation;
digital form or in a floppy, disc, tape or • [(h) activities of a race club including by way of totalisator or a
any other form of electro-magnetic data license to book maker or activities of a licensed book maker in
such club; and]
storage device;……………is there any
• (i) any activity or transaction undertaken by the Central
specific provision under GST Law ? Government, a State Government or any local authority in which
(Section 35 of CGST Act 2017 read they are engaged as public authorities;
with Rule 56 of CGST Rules 2017)

Basic Definitions
GST – Section 2 GST – Section 2
• (52) “goods” means every kind of movable • (83) “outward supply” in relation to a
property other than money and securities taxable person, means supply of goods or
but includes actionable claim, growing crops, services or both, whether by sale, transfer,
grass and things attached to or forming part barter, exchange, licence, rental, lease or
of the land which are agreed to be severed disposal or any other mode, made or agreed
before supply or under a contract of supply; to be made by such person in the course or
• (102) “services” means anything other furtherance of business; (can we correlate
than goods, money and securities but such similar terms with transfer
includes activities relating to the use of definition provided under Income Tax Act
money or its conversion by cash or by any 1961?)
other mode, from one form, currency or • (67) “inward supply” in relation to a
denomination, to another form, currency or person, shall mean receipt of goods or
denomination for which a separate services or both whether by purchase,
consideration is charged; acquisition or any other means with or
without consideration;
Supply under GST – Section 7 – Scope of Supply – Section 2(21) of IGST
(1) For the purposes of this Act, the expression “supply” includes —
(a) all forms of supply of goods or services or both such as sale, transfer, barter, exchange, licence,
rental, lease or disposal made or agreed to be made for a consideration by a person in the course or
furtherance of business;
(aa) the activities or transactions, by a person, other than an individual, to its members or
constituents or vice versa, for cash, deferred payment or other valuable consideration.
Explanation. — For the purposes of this clause, it is hereby clarified that, notwithstanding anything
contained in any other law for the time being in force or any judgment, decree or order of any Court,
tribunal or authority, the person and its members or constituents shall be deemed to be two separate
persons and the supply of activities or transactions inter se shall be deemed to take place from one such
person to another;]
(b) import of services for a consideration whether or not in the course or furtherance of business; [and]
(c) the activities specified in Schedule I, made or agreed to be made without a consideration
(1A) where certain activities or transactions, constitute a supply in accordance with the provisions of
sub-section (1), they shall be treated either as supply of goods or supply of services as referred to in
Schedule II
2) Notwithstanding anything contained in sub-section (1), —
(a) activities or transactions specified in Schedule III; or
(b) such activities or transactions undertaken by the Central Government, a State Government or any
local authority in which they are engaged as public authorities, as may be notified by the Government on
the recommendations of the Council,
shall be treated neither as a supplyCAofNitin
goods nor Mobile
Bhuta Mumbai a supply of services.
No. 9820295319 E-mail:
Composite Supply
Section 2(30) defines “Composite supply” means a supply made by a taxable person to a recipient comprising
two or more supplies of goods or services, or both or any combination thereof, which are naturally
bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a
principal supply;
“Principal supply” means the supply of goods or services which constitutes the predominant element of a
composite supply and to which any other supply forming part of that composite supply is ancillary and does
not constitute, for the recipient an aim in itself, but a means for better enjoyment of the principal supply;
Where goods are packed and transported with insurance , the supply of goods , packing
materials , transport and insurance is a composite supply and supply of goods is a principle
supply.

Mixed Supply
Section 2(74) “Mixed supply” means two or more individual supplies of goods or services, or any
combination thereof, made in conjunction with each other by a taxable person for a single price where such
supply does not constitute a composite supply – Will attract the Highest Rate of Tax
Examples: Supply of soap bars where soap boxes are given free of cost; supply of wheat for which a bottle
of honey is given free of cost.
In the above example of honey being supplied with wheat, both wheat and honey will be taxed at the rate
of tax applicable for honey (being commodity taxed at higher rate).

Schedule – Section 2(100 ) of CGST Act 2017
Activities to be treated as supply even if made without consideration
Schedule I
Examples- Permanent transfer or disposal of business, supplies between

related persons or taxable persons having the same PAN, supply of goods by a
principal to his agent and vice versa, import of services for business purpose,
by a taxable person from a related person
CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail: nitin.bhuta@gmail.com

Activities to be treated as supply of goods or supply of services
Examples- Goods -Transfer of title in goods under an agreement where

property in goods passes upon payment of full consideration, supply of goods
by any unincorporated association or body of persons to a member for cash,
Schedule II deferred payment or other valuable consideration, etc.
Examples - Services: Transfer of right or undivided share in goods without

transfer of title, treatment/ process applied to another person's goods,
renting of immovable property, temporary transfer/ permitting the use or
enjoyment of IPRs, development, design, programming, customisation,
adaptation, upgradation, enhancement, implementation of information
technology software, works contract services
The activities covered under Schedule III which are neither a supply of goods
nor a supply of services would not be included in exempt supply
Schedule III
Examples- Services by employee to employer in the course/ relation to

employment, Services of funeral, burial, crematorium or mortuary, sale of
land, sale of completed buildings, actionable claims (other than lottery,
betting and gambling), services by any court or Tribunal, the functions
performed by the Members of Parliament, etc.

Business Transactions
No Supply Exempt NIL Rated
No GST Supply Non Taxable
Supply
Intra State Interstate/Cross Border

( CGST +SGST) ( IGST )
Single Supply Composite Supply Mixed Supply

Tax Rate Principal Supply Maximum Rate
applicable GST Rate of GST Tax

Supply
Goods Services
MAD
MMD
Movement, Monitoring and Documentation Milestones, Agreements and Documentations

Advances towards supply of goods and services
Goods Services
Initially GST payable on all advances
Then changes made for the RTP having a

turnover of less than Rs.1.5 crores for not GST Payable on all advances received
paying GST. towards services
Exempted from the payment of GST for all

from Nov 2017.

Section 164- Power of Government to make rules
SECTION 164. Power of Government to make rules. — (1) The Government may, on
the recommendations of the Council, by notification, make rules for carrying out the
provisions of this Act.
(2) Without prejudice to the generality of the provisions of sub-section (1), the
Government may make rules for all or any of the matters which by this Act are required
to be, or may be, prescribed or in respect of which provisions are to be or may be made
by rules.
(3) The power to make rules conferred by this section shall include the power to give
retrospective effect to the rules or any of them from a date not earlier than the date on
which the provisions of this Act come into force.
(4) Any rules made under sub-section (1) or sub-section (2) may provide that a
contravention thereof shall be liable to a penalty not exceeding ten thousand rupees.
GST Rules
RULE 80. Annual return. — (1) Every registered person, other than those referred to in the second proviso to section
44, an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-
resident taxable person, shall furnish an annual return for every financial year as specified under section 44
electronically in FORM GSTR-9 on or before the thirty-first day of December following the end of such financial year
through the common portal either directly or through a Facilitation Centre notified by the Commissioner :
Provided that a person paying tax under section 10 shall furnish the annual return in FORM GSTR-9A.
(1A) Notwithstanding anything contained in sub-rule (1), for the financial year 2021-22 the said annual return shall be
furnished on or before the thirty first of December 2022.
(2) Every electronic commerce operator required to collect tax at source under section 52 shall furnish annual
statement referred to in sub-section (5) of the said section in FORM GSTR-9B.
(3) Every registered person, other than those referred to in the second proviso to section 44, an Input Service
Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable
person, whose aggregate turnover during a financial year exceeds five crore rupees, shall also furnish a self-certified
reconciliation statement as specified under section 44 in FORM GSTR-9C along with the annual return referred to in
sub-rule (1), on or before the thirty-first day of December following the end of such financial year, electronically through
the common portal either directly or through a Facilitation Centre notified by the Commissioner.
(3A) Notwithstanding anything contained in sub-rule (3), for the financial year 2020-21 the said self-certified
reconciliation statement shall be furnished along with the said annual return on or before the twenty-eighth day of
February, 2022. ( will the date would be extended for FY 2122 ? )
Checklist of Documents to be verified ( Illustrative)
• Registration documentation
• Nature of Business activities – Goods or Services or Both
• Outward Supplies – Normal (B2B & B2C ), Export, SEZ , DN CN etc
• Inward Supplies – Regular – RCM
• Electronic Cash Ledger & Electronic Credit Ledger
• Verification of DN/CN
• Agreements/Purchase order/Sales Orders/Estimates/Quotation etc
• Books of accounts for each GSTN
• HSN and SAC classification
• Tax levies to be verified ( C or S or I or UTGST etc.)
• GST Returns filed & verification of summaries
• GST challans with Cash Ledger
• Financial Statements, TAR, ITR and any other audit reports.
• Reconciliations

GST Annual
Return
GSTR 9
GST Annual Return
Process

Industry Laws Applicable
Books of Accounts Financial Statements
Statutory Compliances Scope

Pillars of Annual Returns/Self Reconciliation
Statement
S I T
Outward Supply
Inward Supplies =
= Taxable + Zero Tax Payouts =
B2B + Imports of
rated + NIL Rated Gross levy ( IGST or
goods and/or CGST+SGST or
+ Exempt
services + RCM CGST+UTGST )
Supplies+
u/s 5(3)/5(4) or minus ITC credits
Non Taxable +
9(3)/9(4)
No Supply
Basic Fundamentals – GSTR 9 & GSTR 9C
Input
Registrati Invoicing Outward Inward GST
Books Tax
on method Supply Supply Returns
Credit
Tax Intra/Inter State

Manual Electronic Normal Composition Bill of Supply
Invoices
Cash /Mercantile System of accounting
GST
Collection
Classificat Value of Place of Time of
RCM & Refund
ions Supply Supply Supply
Verificatio
ns
HSN SAC Intra ( C +S ) Inter ( I )

GSTR 9 & GSTR 9C - Technology
Outward
Supply
Electronic data –
Sample –
PAN and GST
Inference- Assurance –
verifications –
Inward Interest – Accuracy –
system driven –
Supply Genuine – Reliability –
does system
TOS- True and Fair ?
provide e way Bill
Valuation ?
verification?
Taxes paid

Documents to be kept ready for the filing of GSTR 9
Output and Inward Reconciliations
GST Registration
Audit Reports if any GSTR 3B Documents
If Stock
records
maintai
GSTR 2A/2B
GSTR 9 ned as
Books of Accounts
per
other
laws ?
GSTR 1
Final Financial statements Classification of Goods

and Services
Electronic Cash & Credit Ledger
For Each GSTN ?
E Way Bill Flow Chart

E Way Bill Generation
(before the movement of supply) - Step 1
Will continue for
RTP or Other RTP other
Supplier than who are
required to follow E-
For B2B only Invoicing
Existing
Now IRP
Portal
E Way Recipient or
Buyer
E Way
Bill
Under New E
Part I Only
Bill System
for
Part A
Invoicing System
Part A would be
RTP registered for E- Invoicing can
auto generated Transporter
continue using the same for
transactions other than B2B

E Way Bill Generation
(before the movement of supply) - Step 2
Post Generation E Multiple Consignments in One Vehicle
Step 1
Way Bill is available by Transporter only
to all
Seller directly Fill Form GST EWB
or through 02
IRP Portal Or
E Way New E Way Bill
Part B of E Bill Created by
Buyer Or way Bill Created Transporter only
Generate new
consolidated E
Way Bill
Transporter Vehicle Change of
Number Vehicle

E Way Portal - Peculiarities
Distance determination Restricting One Invoice One E way

due to Pin code
Supplies by Bill ( formulated on the
Mapping – determines
Composition basis of E Invoicing )
validity of E Way Bill
Dealers
Validity of E way can Blocking/

be extended during
E way Bill Expiry
Unblocking of
transit reports
E way Bills

E Way Bill Outward
Reconciliations

Outward Supply
Supply Others
Domestic
Export Exhibition or Fairs

LUT/Bond
Job work Own use

Delivery Challan
SKD/CKD Recipient
Unknown
CA Nitin Bhuta
MIS Reports
E Invoicing BOA
Cash Flow E way Bill
Statements generation
verification Financial
Banking Finance
Reporting
Statements
Audit Reports TAR

Collection Invoice Reporting
verifications Domestic verification
Supplies MCA
Outward Reporting
Reconciliation
GSTR 1 verification Stock Records
GSTR 3B verifications CARO & TAR reporting
Electronic Cash and Credit Ledger R1 and 3B Stock

MCA Reporting
Reporting verification
GSTR 9 & 9C Cost accounting
records
MIS Reports E Invoicing/
Commercial
BOA
Cash Flow E way Bill Invoices
Banking Finance &
SOFTEX Reporting
Statements
Audit Reports Invoice date TAR

Collection Invoice Reporting's
verifications verification
Exports
3 months Supplies MCA
Outward Reporting
Reconciliation
GSTR 1 verification
Bill of Lading date Stock Records
GSTR 3B verifications
CARO & TAR reporting
Electronic Cash and Credit edger R1 and 3B Stock
Reporting verification MCA Reporting
GSTR 9 & 9C plus LUT
Cost accounting
Custom Documentation records
E Way Bill Inward
Reconciliations

Inward Supply
Supply Others
Domestic
Import Exhibition or Fairs

High Seas/Bond
Job work Own use

Returns
SKD/CKD Purchase Returns
CA Nitin Bhuta
MIS Reports
E Invoicing BOA
Banking Finance
Statements
Reporting
Audit Reports TAR

Reporting's
Payment Invoice
Rule 37 verifications verification
Domestic MCA
Supplies Inward Reporting
Reconciliation
GSTR 2A /2B verification Stock Records
GSTR 3B verifications CARO & TAR reporting
Electronic Cash and Credit edger 3B Stock

MCA Reporting
Reporting verification
GSTR 9 & 9C
Cost accounting
Rule 42 & Rule 43 records
MIS Reports
E Invoicing BOA
Banking Finance &
SOFTEX Reporting
Statements
15CA/15CB Reports TAR

Payment Invoice Reporting's
Audit Reports verifications Import verification
Supplies MCA
Inward Reporting
Reconciliation
GSTR 2A/2B verification
Stock Records
GSTR 3B verifications
CARO & TAR reporting
Electronic Cash and Credit edger
3B Stock
MCA Reporting
GSTR 9 & 9C plus LUT Reporting verification
Customs Documentation Cost accounting records
E Way Bills - Issues to Ponder upon ?
• Supplies not supported by E Way Bills - Outward Supplies as well as
Inward supplies - Returns filed ? Taxes paid ? Accounts settled or not
settled ?
• Clients says supplies not made but E way bill was prepared by staff but
not cancelled due to oversight
• E way Bills copies ( not available ) or Job work supplies shown as
supply due to clerical errors.
• Recipient outside India , consideration received in Convertible Foreign
exchange, treated as Export but supply has not crossed customs
borders ?

Changes in GST
Annual Return
GSTR 9
Changes Introduced in GSTR 9 – Financial Year 2021-22 – Not. No 14/2022 dated 05.07.22
Part II -Table 4 Details of Outward and Inward Supplies declared during the financial
year
4 . Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the
financial year
A Supplies made to Unregistered persons (B2C) For FY 2122, net of Debit Source BOA /GSTR 1 – Table
Notes & Credit Notes 5,7,9 & 10
amendments for Table
B Supplies made to Unregistered persons (B2B) 4B to 4E can’t be Table 4A , 4C , 9A & 9C
reported which was
C Zero rated Supply ( Export ) on payment of Tax ( opted or followed or Table 6A 9A & 9C
except supplies to SEZs) permitted for FY 2021.
D Supply of SEZs on payment of Tax Table 6B 9A & 9C
E Deemed Exports Table 6C 9A & 9C

Changes Introduced in GSTR 9 – Financial Year 2021-22 – Not. No 14/2022-dated 05.07.22
Part II -Table 4 Details of Outward and Inward Supplies declared during the financial year
4 . Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during
the financial year ( contd )
F Advances on which Tax has been For FY 2122, net of Source BOA /GSTR 1
paid but invoices has not been Debit Notes & Credit – Table 11A
Notes amendments for
issued ( not covered under (A) to Table 4B to 4E can’t be
(E) above reported which was
G opted or followed or
Inward Supplies on which tax is to permitted for FY 2021.
Source GSTR 3B –
be paid on reverse charge basis Table 3.1 (d)
H Sub-total ( (A to G ) above
Part II -Table 4 Details of Outward and Inward Supplies declared during the financial year
4 . Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during
the financial year ( Contd )
I Credit Notes issued in respect of transactions Table 9B - GSTR 1
specified in (B ) to ( E ) above (-)
J Debit Notes issued in respect of transactions Mandatory Table 9B - GSTR 1

specified in (B ) to ( E ) above (+)
K Supplies/Tax declared through Amendments (+) from FY Table 9A & 9C - GSTR 1
2122
L Supplies/Tax reduced through Amendments (-) Table 9A & 9C - GSTR 1
M Sub-total (I to L above )
Part II -Table 5
5 . Details of Outward Supplies on which tax is not payable as declared in returns filed during the financial year
A Zero Rated Supply ( export) without payment For FY 2122, also option Source BOA /GSTR 1 –
of Tax of Net of Debit Notes & Table 6A 9A 9B & 9C
Credit Notes
B Supply to SEZs without payment of Tax amendments for Table Table 6B 9B & 9C
5H to 5K can be
C Supplies on which tax is to be paid by the reported which was Table 4B
recipient on reverse charge basis opted or followed or
permitted for FY 2021.

Part II -Table 5
5. Details of Outward Supplies on which tax is not payable as declared in returns filed during the financial year
D Exempted For FY 2122, only Source BOA /GSTR 1 –

exempted and NIL Rated Table 8
Supply can be shown as
Consolidated information
E Nil rated but non GST Supply needs Table 8
to be reported separately.
F Non GST Supply To be disclosed separately Table 8

from FY 2122.
G Sub total of (A to F above )
Part II -Table 5
5. Details of Outward Supplies on which tax is not payable as declared in returns filed during the financial year
( Contd )
H Credit Notes issued in respect of transactions Table 9B - GSTR 1
specified in (A ) to ( F ) above (-)
Continues
I Debit Notes issued in respect of transactions specified Table 9B - GSTR 1
in (A ) to ( F ) above (+)
to be
J Supplies/Tax declared through Amendments (+) optional Table 9A & 9C - GSTR 1
for FY 2122
K Supplies/Tax reduced through Amendments (-) too also. Table 9A & 9C - GSTR 1
L Sub-total (H to K above )

Part II -Table 5
5 . Details of Outward Supplies on which tax is not payable as declared in returns filed during the financial year
M Turnover on which tax is not to be paid ( G + L

above )
N Total Turnover ( including advances ) ( 4N +5M

-4G above )

Table 6 – Details of ITC availed or declared in returns filed during the financial year
Not. No 79/2020 dt 15.10.20 ????

A Total amount of input tax credit availed through Form GSTR 3B ( sum Auto Populated Source GSTR 3B
total of Table 4A of Form GSTR 3B )
B Inward Supplies ( other than Imports and inward supplies liable to Inputs Consolidated ITC in Inputs Row only
RCM but includes services received from SEZs) for Inputs and Services but Capital
Capital Goods Goods to be shown separately.
Input Services
C Inward Supplies received from unregistered persons liable to RCM ( Inputs Consolidated ITC in Inputs Row only
other than B above ) on which tax is paid and ITC availed - Mandatory for Inputs and Services but Capital
Reporting from FY 2122 Capital Goods Goods to be shown separately.
Input Services
D Inward Supplies received from registered persons liable to RCM ( Inputs Consolidated ITC in Inputs Row only
other than B above ) on which tax is paid and ITC availed –It was for Inputs and Services but Capital
mandatory Reporting for FY 2021, consolidated details could have Capital Goods Goods to be shown separately.
been reported for Table 6C + Table 6D in Table 6D only. Now 6D Input Services
mandatory reporting for FY 2122
E Import of Goods ( including supplies from SEZs) Inputs Consolidated ITC in Inputs Row only
for Inputs but Capital Goods to be
Capital Goods shown separately.

Table 6 – Details of ITC availed or declared in returns filed during the financial year – source GSTR 3B
F Import of Services ( excluding inward supplies Mandatory Reporting

from SEZs) from FY 2122
G Input Tax credit received from ISD Mandatory Reporting

from FY 2122
H Amount of ITC reclaimed (other than B above) Mandatory Reporting

under the provisions of the Act from FY 2122
I Sub-total ( B to H above )
J Difference ( I – A ) above

Table 6 – Details of ITC availed or declared in returns filed during the financial year
K Transitional credit through TRAN-1 ( including Mandatory Reporting

Revision if any ) from FY 2122
L Transitional Credit through TRAN -II Mandatory Reporting

from FY 2122
M Any other ITC availed but not specified above Mandatory Reporting ITC 01 & ITR 02 ( Section
from FY 2122 18(1)
N Sub – total ( K to M above )
O Total ITC availed ( I + N above )

Table 7 – Details of ITC reversed and ineligible ITC as declared in returns filed during the financial year-
Source GSTR 3B
A As per Rule 37
Report total
B As per Rule 39 value in
Table 7H
C As per Rule 42
only. though
D As per Rule 43 personally I
don’t
E As per Rule 17(5) recommend
the same.
Table 7 – Details of ITC reversed and ineligible ITC as declared in returns filed during the financial year-
Source GSTR 3B
F Reversal of Tran 1 Credit Mandatory Reporting

from FY 2122
G Reversal of Tran –II Credit Mandatory Reporting

from FY 2122
H Other Reversals ( Pl Specify ) Mandatory Reporting ITC 03 Table 4(B) –

from FY 2122 Composition to Regular &
registration cancelled
I Total ITC reversed ( a to H above )
J Net ITC availed for Utilization ( 60-7I)

Table 8 – Other ITC related information – only Relevant changes covered here
A ITC as per GSTR 2A ( Table 3 & 5 ) thereof Auto populated till 30.11.22
B ITC as per sum total of 6(B) & 6(H) above

C ITC on Inward supplies ( other than imports and ISD Mandatory Reporting from No option to attach PDF with
liable to RCM but includes services received from SEZ FY 2122 GSTR 9C is available officially
received during 2017-18 but availed during April to for AT exceeding 5 crore with
March 2019. GSTR 9C as a part of
document upload.
D Difference (A –(B+C) )
E ITC available but not availed ( out of D ) Mandatory Reporting from

FY 2122
F ITC available but ineligible (out of D ) Mandatory Reporting from

FY 2122

Changes Introduced in GSTR 9 – Financial Year 2021-22
Part V -Table 10-13

Particulars of the transactions for the financial year declared in returns in the next financial year till the specified period viz. 30.11.22
10 Supplies /Tax declared through Amendments (+) net of Debit Notes Mandatory for FY Table 9A 9B 9C - GSTR 1
filed only upto 30.11.22 2122
11 Supplies /Tax reduced through Amendments (+) net of credit Notes Mandatory for FY Table 9A 9B 9C - GSTR 1
filed only upto 30.11.22 2122
12 Reversal of ITC availed during the previous Financial Year – GSTR 3B Continues to be optional Table 4B - GSTR 3B
filed only upto 30.11.22 viz. Oct 22. but not desired, better
to report as it is
mandatory to be
reported in GSTR 9C
13 ITC availed for the previous financial year – GSTR 3B filed only upto Continues to be optional Table 4A - GSTR 3B
30.11.22 viz. Oct 22. but not desired, better
to report as it is
mandatory to be
reported in GSTR 9C
Total Turnover (5N+10-11 )
Part VI - Other Information
Other Changes in GSTR 9 Others
15 Particulars of Demands and Refunds Optional but recommended to provide the

details if available
16 Information on Supplies received from Optional but recommended to provide the
composition tax payers deemed supply under details if available
section 143 and goods sent on approval
17 HSN wise summary of Outward supplies Mandatory Reporting from FY 2122 – to be
mapped with data reported in GSTR 1 by RTP.
18 HSN Wise summary of Inward Supplies Optional but recommended to provide the
details if available

Changes in Self
Reconciliation
Statement
GSTR 9C
Changes Introduced in Reconciliation statement GSTR 9C – Financial Year 2021-22 – Not. No 14/2022 dt 05.07.22
Part II – Reconciliation of turnover declared in audited Financial Statements with Turnover declared in Annual Return
( GSTR 9)
5
Reconciliation of Gross Turnover
A Turnover ( including exports ) as per AFS for the state/UT ( for multi
GSTIN units under same PAN the turnover shall be derived from
Audited AFS ) – if audit not done under IT as per section 44AB for
non corporates then audit needs to be done under GST for FY 2122
B Unbilled revenue at the beginning of FY (+) Optional but recommended not to opt for the same
C Unadjusted advances at the end of FY (+) Optional but recommended not to opt for the same
D Deemed Supply under schedule I (+) Optional but recommended not to opt for the same
E CN issued after the end of FY but reflected in the R9 (+) Optional but recommended not to opt for the same
only upto Apr 22 to Oct 22 reported in GSTR 1

F Trade Discounts accounted in the Audited AFS (+)
nitin.bhuta@gmail.com Optional but recommended not to opt for the same
( GSTR 9)
5
G Turnover from April 2017 to June 2017 (-) NA
H Unbilled revenue at the end of Financial Year (-) Optional but recommended not to opt for the same
I Unadjusted advances at the beginning of FY (-) Optional but recommended not to opt for the same
J Credit Notes accounted for in audited AFS but are not (-) Optional but recommended not to opt for the same
permissible under GST

K Adjustments on account of supply of goods by SEZ units (-) Optional but recommended not to opt for the same
to DTA Units
L Turnover for the period under Composition scheme (-) Optional but recommended not to opt for the same

( GSTR 9)
5
M Adjustments in turnover in Section 15 and Rules (+/-) Optional but recommended not to
thereunder opt for the same
N Adjustment in Turnover due to foreign exchange (+/-) Optional but recommended not to
fluctuations opt for the same
O Adjustments in Turnover due to reasons not listed (+/-) Total of 5B to 5N – Notification
above- Residuary entry recommends reporting here but I don’t
recommend
P Annual Turnover after adjustments as above Auto
Q Turnover as declared in Annual Returns GSTR 9 Auto
R Unreconciled Turnover ( Q- P ) CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail:
12
Reconciliation of Net Input Tax credit ( ITC )
A ITC availed as per audited AFS for the state /UT ( for Multi
GSTIN units under same PAN Number this should be
derived from BOA
B ITC Booked in earlier FY claimed in CFY (+) It is mandatory for FY 2122 but it was
optional for FY 2021. Thus, information
to be reported in GSTR 9- Row No 12 &
13.
C ITC booked in CFS to be claimed in subsequent FY (-) It is mandatory for FY 2122 but it was
optional for FY 2021. Thus, information
to be reported in GSTR 9- Row No 12 &
13.
D ITC availed as per Audited FS or BOA Auto
E ITC claimed in Annual Returns GSTR 9
F Unreconciled ITC ( D- E ) nitin.bhuta@gmail.com ITC 1
14 Reconciliation of ITC declared in Annual Return ( GSTR 9 ) with ITC availed on

expenses as per Audited annual financial statements or books of accounts
A
to
Q
Continues to be Optional
R Total Amount of Eligible ITC availed Auto
S ITC claimed in Annual Return ( GSTR 9) Auto
T Unreconciled ITC ( R- S) ITC 2

Basics of Annual Returns

Basics of GST Annual Return 9
• What do you mean by Annual Return under GST Act 2017?
• What information needs to be reported in Annual Return?
• What is the purpose of Annual Return ?
• Annual Return consists of only actual information filed by RTP. No
new information can be added, modified or revised in the AR.
• Can such annual return be amended or modified or revised ?

• Transactions pertaining to previous FY but declared upto September (
November) of Current FY would be reported in Annual Return ( such as
amendments, Input Tax Credit availed , ITC reversed etc.
• No Tax, Interest , Late Fee or Penalty can be paid while filing the Annual
Return before the amendment now it can be paid through DRC -03 using
annual returns option in cash.
• New Requirements to bifurcate the Total ITC availed on Inputs , Capital
Goods and Input Services in Table 6 of GSTR 9
• RTP in between switching over from Composition scheme to normal
scheme would be required to file both GSTR 9A & GSTR 9.
• RTP must have active GSTIN during the relevant financial year as a Normal
Tax Payer ( even it can be valid for one day in a Financial year)

• Annual Returns GSTR 9 applicable to whom?
AR to be filed electronically only every year by every RTP and not by Advisor
It is applicable to all Registered Tax Dealers (RTP) and the same is required to be filed for each
GSTIN Number
Including RTP having NIL liabilities

• Annual Returns GSTR 9 not applicable to whom?
AR is not applicable to following :-

Input service Distributors
E commerce Operators
TDS deductors u/s 51 or 52
CTP
NRCTP

GSTR 9 & GSTR 9C applicability
Aggregate Turnover more Aggregate Turnover more

Aggregate Turnover Less
than 2 crores and less than 5 Crores
than 2 Crores
than 5 crores
Exempted ??? Optional Compulsory to File

Compulsory to file GSTR 9 GSTR 9 & GSTR 9C
to file GSTR 9
For Each GSTIN Registration

Annual Return Section 44(1) Rule 80
RTP Rule 80(1) where AT exceeds

GSTR 9
Rs.2 crores
Composition Dealer
Rule 80(1) GSTR 9A
TCS Rule 80(2) GSTR 9B
Aggregate Turnover exceeds Rs.5

GSTR 9 + GSTR 9C
crores
ISD, CTP , NRCTP , ISD ,TDS are excluded from the requirements of filing of AR.
• What is due date for the filing of Annual Returns GSTR 9 ?
Due date of Filing of AR is 31.12.2022 as on today.

Rule 80(3A) invocation u/s 164 ?

• What are the implications if RTP don’t file Annual Returns GSTR 9 ?
If AR is not filed by Due date then there is late fee of

Rs.100 per day under CGST plus Rs.100 per under
SGST/UTGST subject to maximum of 0.5% ( .25%+.25% )
of Turnover in state/Union Territory as per section 44
plus General Penalty u/s 125 of GST Act 2017 of
Rs.25000/-

• What would happen if RTP don’t file Annual Returns GSTR 9 ?
Notice in Form GSTR -3A would be issued by the GST

department under Section 46 read with Rule 68 and RTP
would be requested to file AR 9 within 15 days from the
receipt of the notice. Such notice would be issued
electronically.

• If person has not filed GSTR -1 as well as GSTR 3B , can he still file
Annual Returns GSTR 9 ?
No , RTP would be required

to file GSTR 1 & 3B first
before he can file GSTR 9.

• Is Annual Returns GSTR 9 to be filed before GSTR 9C – Audit Report?
It is recommended to file and cannot

be filed before the filing of GSTR 9
and only after GSTR-1, GSTR 3B &
GSTR 9 filing of GSTR 9C- Audit
Report is initiated.

• Is it necessary to determine value of aggregate turnover even though
turnover is less than 2 crores in previous FY?
It is recommended to check and

determine aggregate turnover as per
section 2(6) of the Act. Why is it
necessary?

• Section 2(6) defines “aggregate turnover” means the aggregate
value of all taxable supplies (excluding the value of inward supplies
on which tax is payable by a person on reverse charge basis),
exempt supplies, exports of goods or services or both and inter-State
supplies of persons having the same Permanent Account Number, to
be computed on all India basis but excludes central tax, State tax,
Union territory tax, integrated tax and cess;
The phrase “aggregate turnover” is widely used under the GST laws.
Aggregate Turnover is an all-encompassing term covering all the
supplies effected by a person having the same PAN.

Aggregate Turnover
• It specifically excludes:
· Inward supplies effected by a person which are liable to tax under reverse charge
mechanism; and
· Various taxes under the GST law, Compensation cess.
• The different kinds of supplies covered are:
• (a) Taxable supplies;
• (b) Exempt Supplies:
• supplies that have a ‘NIL’ rate of tax;
• supplies that are wholly exempted from SGST, UTGST, CGST, IGST or Cess;
and
• supplies that are not taxable under the Act (alcoholic liquor for human
consumption and articles listed in section 9(2) and in schedule III);
• (c) Export of goods or services or both, including zero-rated supplies.

Aggregate Turnover
• Points to remember:-
• Aggregate turnover is relevant to a person to determine:
• Threshold limit to opt for composition scheme: Rs. 1.5 Crore in other
states/Rs.75 Lakhs in specified states in a financial year);
• Threshold limit to obtain registration under the Act: 20 Lakhs for services
whereas for goods it is 40 lakhs (or 10 Lakhs in case of supplies effected
from Special Category States) in a financial year.
• Filing of Self Reconciliation statement in Form GSTR 9C is mandatory only if
aggregate turnover exceeds Rs.5 crores as specified u/s 35(5).
Aggregate Turnover
• Inter-State supplies between units of a person with the same PAN will also
form part of aggregate turnover.
• For an agent, the supplies made by him on behalf of all his principals
would have to be considered while analysing the threshold limits.
• For a job-worker, the following supplies effected on completion of job
work would not be included in his ‘aggregate turnover’:
• Goods returned to the principal
• Goods sent to another job worker on the instruction of the principal
• Goods directly supplied from the job worker’s premises (by the principal):
It would be included in the ‘aggregate turnover’ of the principal.
Aggregate Turnover
SR No Particulars Value ( Rs. )
1 Taxable Turnover as per Financial Statements ( excluding Taxes ) B2B, xxxxxx.xx
B2C, Exports, SEZ , Net effect of CN/DN etc.
2 Value of Exempt Supply , NIL Rated Supply , Non Taxable Supplies & xxxxxx.xx
No Supply too excluding supplies notified under schedule III as per
CGST Act, 2017.
3 Branch Transfers ( excluding Taxes ) – such transaction would be xxxxxx.xx
nullified in the annual Financial statements
4 Transactions between Related Parties ( excluding Taxes ) – Employer xxxxxx.xx
and Employee where value exceeds Rs.50000
5 Transactions between Principal and Agent ( excluding Taxes ) xxxxxx.xx
6 Value of Cross Charges between HO & Branch and so on -such xxxxxx.xx

transaction would be nullified in the annual Financial statements
7 Total Value of Aggregate Turnover ( Sum of 1 to 6 ) xxxxxx.xx

Determination of Aggregate Turnover
Branches
Business Model & Depots
HO/Factory
Cross
Charge
Investments or Properties Aggregate

Warehouses
Out and Out Supplies ??? Turnover
Ledgers NIL Rated

& Fixed Exempt
Related Assets No Supply
Non GST Supply
parties

Clause by Clause Analysis –
Annual Return 9

Annual Return 9
( 6 Parts –19 Tables -460 Data fields)
Part I Basic Information Table 1-3
Part II Liabilities ( Output + RCM) Table 4-5
FY
Part III Input Tax Credits Table 6-8 2122
Part IV Tax Paid Details Table 9
Part V Circular 26 Effects Table 10-13 FY2223
Part VI Other Information Table 15-19

Part I – Basic Information- Table 1 & 3
“FORM GSTR-9
“FORM GSTR-9
(See rule
(See rule80)80)
Annual Return
Annual Return
Pt.
Pt. I I Basic Details
Basic Details
1
1 Financial Year
Financial Year
2
2 GSTIN
GSTIN
3A
3A Legal Name
Legal Name
3B
3B Trade Name (if any)
Trade Name (if any)
To be
filed for Auto
each
GSTN

Cross Border Transactions
FERA FEMA
• Repealed as on 29/12/1999 • New FEMA introduced after the
• Intention is to regulate Foreign repealment of FERA
Exchange Transactions • Intention is to facilitation of Trade and
• Period when there was extremely low Investment
Foreign Exchange • Period when there is satisfactory level
• Everything is assumed to be of Foreign Exchange
prohibited unless permitted • Everything is assumed to be permitted
• Violations subject to criminal unless prohibited
proceedings • Violations subject to Civil Offences
• Interpretation of provisions – RBI is • Interpretation of provisions – RBI is
final not final
Data Auto Populated
Part II – Liability ( Output + RCM )- Table 4 & 5

9(3)/5(3)
9(4)/5(4)
Pt. II Details of Outward and inward supplies declared during the financial year
(Amount in ₹ in all tables)
Nature of Supplies Taxable Value Central Tax State Tax / Integrated Tax Cess
Presumptive
UT system of
Tax
Taxation under
1 2 3 4 5 6
4 Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the
ITR ?
financial year
A Supplies made to un-registered persons Table 5,7,9 & 10
(B2C)
B Supplies made to registered persons Table 4A 4C
(B2B)
C Zero rated supply (Export) on
payment of tax (except supplies to SEZs) Table 6A
Table 6B GSTR 1
D Supply to SEZs on payment of tax
E Deemed Exports Table 6C
Advances on which tax has been paid
F but invoice has not been issued (not
covered under (A) to (E) above) Table 11A
G Inward supplies on which tax is to be
paid on reverse charge basis Table 3.1 (d) GSTR 3B
H Sub-total (A to G above) - - - - -
Merchant Exporters ? Advances received from Clients ( Balance Sheet Items )

Part 4A?Notification 48 CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail:
Deemed Exports – Table 4
GST- N No 48/2017 dt 18.10.2017 Foreign Trade Policy
• Supply of goods against advance • Supplies to projects against international

authorization competitive bidding
• Supply of capital goods against EPCG • Supplies to projects with zero customs
authorization duty
• Supply of goods to • Supply of goods to mega power projects
EOU/STP/EHTP/BTP against International Competitive Bidding
• Supply of gold by bank/PSU specified • Supplies to UN Agencies
in Notification No. 50/2017-Customs • Supply of goods to nuclear projects
dated 30.06.2017. through competitive bidding

Data Auto Populated
4 Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the
financial year Wrong Invoices/Shipping
Credit Notes issued in respect of bills
I transactions specified in (B) to (E) above
(-) Table 9B
Debit Notes issued in respect of
J transactions specified in (B) to (E) above Table 9B
(+) GSTR 1
K Supplies / tax declared through Table 9A, 9C
Amendments (+)
L Supplies / tax reduced through Table 9A, 9C
Amendments (-)
M Sub-total (I to L above) - - - - - DN/CN amendments or
N Supplies and advances on which tax is to refund vouchers
- - - - - adjustments
be paid (H + M) above

Data Auto Populated
5 Details of Outward supplies on which tax is not payable as declared in returns filed during the financial year
A Zero rated supply (Export) without

payment of tax
- Table 6A
B Supply to SEZs without payment of tax
- Table 6B
C Supplies on which tax is to be paid - - - - -
by the recipient on reverse charge basis Table 4B
D Exempted -
E
F
Nil Rated
Non-GST supply
- Table 8
-
G Sub-total (A to F above) - - - - -
GSTR 1
Credit Notes issued in respect of - - - -
H transactions specified
in A to F above (-)
Table 9B
Debit Notes issued in respect of - - - -
I transactions specified Table 9B
in A to F above (+)
J Supplies declared through Amendments - - - -
(+)
Table 9A,9C
K Supplies reduced through Amendments (- - - - -
) Table 9A, 9C
L Sub-Total (H to K above) - - - -
M Turnover on which tax is not to be paid
- - - - -
(G + L above)
N Total Turnover (including advances) (4N
- - - -
+ 5M - 4G above)
Total Outward Supplies including on which tax is not payable

Part II – Table 5 Outward Supplies on which Tax is not payable(Source –GSTR 1 )
Goods Services
Export
SEZ
Exempt Repatriations of
Customs Act Supplies Funds
NIL Rated
Non GST Only three supplies – Lease of land
1. High Sea Sales
Supplies for agriculture ,govt services by CG,
2.Sales from Bonded
Non SG & Government Authorities etc.
Warehouse/MOOWR
Taxable
3. Recovery of cost credited
Supplies
to Expenditure/ Asset/
Liability etc LUT conditions to be complied
4. CN not subjected GST and needs to be checked while
would covered in clause 5F Under Without filing AR
LUT/Bond LUT/Bond
Not. No
79/2020
Part III – Input Tax Credits – Table 6 to 8- Source GSTR 3B dt
15.10.20
????
Pt. III Details of ITC as declared in returns filed during the financial year
Description Type Central Tax State Tax / Integrated Tax Cess
GSTR
UT
Tax
3B
1 2 3 4 5 6
6 Details of ITC availed as declared in returns filed during the financial year Auto
A Total amount of input tax credit availed through FORM
GSTR-3B (sum total of Table 4A of FORM GSTR-3B)
B Inward supplies (other than imports and Inputs
inward supplies liable to reverse charge Capital Goods Table
but includes services received from
SEZs)
Input Services 4(A)(5)
C Inward supplies received from
unregistered persons liable to reverse
Inputs
RTP needs to work on
Capital Goods
charge (other than B above) on which tax Input Services reclassifications Table Table
4(A)(3)
D
is paid & ITC availed
Inward supplies received from registered Inputs 6A=
persons liable to reverse charge (other
than B above) on which tax is paid and
Capital Goods
Table Total of
Input Services
ITC availed 4(A)(3) 6B to 6I
E Import of goods (including supplies from Inputs
SEZs)
Capital Goods
Table and if
4(A)(1)
F Import of services (excluding inward supplies from SEZs) not ? To
G Input Tax credit received from ISD ITC to be bifurcated between Eligible and Ineligible Credits Table be
4(A)(2)
H Amount of ITC reclaimed (other than B above) under the
provisions of the Act
rework
I Sub-total (B to H above) - - -
Table 4(A)(4)
Part III – Input Tax Credits – Table 6 to 8- Source GSTR 3B
Pt. III Details of ITC as declared in returns filed during the financial year
Description Type Central Tax State Tax / Integrated Tax Cess
Sale Demerger
UT
Transfer of
Auto Business etc
Tax
1 2 3 4 5 6
J Difference (I - A above) - - -
Transition Credit through TRAN-I (including revisions if any)
K TRAN I
L Transition Credit through TRAN-II TRAN II

M Any other ITC availed but not specified above - - - - ITC 01 – ITC 02
N Sub-total (K to M above) - - -
O Total ITC availed (I + N above) - - - Section
18(1)

7 Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year
A As per Rule 37 Invoices to be paid within 180 days
B As per Rule 39 Ineligible ITC received from ISD
C As per Rule 42 Ineligible ITC on Exempted services
Table 4(B)
D As per Rule 43 Ineligible ITC on CG Exempt & common ITC on CG 4(D)
E As per section 17(5) Blocked Credits
F Reversal of TRAN-I credit Ineligible Credit Reversed – EC SHEC & KKC
G Reversal of TRAN-II credit Ineligible credit Reversed – unsold stock ITC
H Other reversals (pl. specify) ITC 03 Table 4(B)
I Total ITC Reversed (A to H above) - - - -

Composition
J Net ITC Available for Utilization (6O - 7I) - - - to Regular
Data Auto Populated

What to do
Points to Ponder Upon
1. Invoices unpaid after 180 days – Domestic as well as International Transactions – only on year end outstanding
or in respect of each invoices ?
2. Invoices are not raised pertaining to Cross charge between related charges? If one RTP has accounted while
filing GSTR 1 as well as and other RTP have not accounted the same in their GSTR 3B?
3. Merchant Trade (Out and Out sale from say Japan to UK) is exempt from GST. What if India based Logistics
Support Service Provider (Freight Forwarder) is providing Ocean Freight services from Japan to UK. To provide
this services he may avail services of Freight Forwarder situated say in Japan. Further he will receive his
consideration in foreign currency and will also pay to foreign freight forwarder in foreign currency.
Section 13(8) of IGST Act - The place of supply of services by way of transportation of goods, including by mail or
courier to, - (a) a registered person, shall be the location of such person;
(b) a person other than a registered person, shall be the location at which such goods are handed over for their
transportation. Provided that where the transportation of goods is to a place outside India, the place of supply shall
be the place of destination of such goods.

What to do?
4. In case of FOB Import from China or Ex works import of Goods from china, Indian importer typically employs services of Indian
freight forwarder. Such Indian Freight Forwarder typically connects with Chinese freight forwarder for Import of Goods (from
Factory of Chinese manufacturer in case of Ex works import and from port of china in case of FOB Import). Chinese forwarder
pays directly to shipping line and Indian forwarders pays to Chinese forwarder in forex. Indian forwarder charge 5% GST on
Indian importer on ocean freight and 18% GST on other charges. Issue for consideration: Whether Indian Forwarder is required
to pay GST on RCM basis on such freight forwarding charges paid to Chinese forwarder as import of services?
Section 13(9) of IGST Act reads as under (9) The place of supply of services of transportation of goods, other than by way of mail
or courier, shall be the place of destination of such goods.
5. Hotel accommodation charges paid in the Foreign Currency and reported in the Financial statements in Directors Reports as
well as Notes to accounts whether such payouts would trigger GST liability under RCM u/s 9(3) or 5(3) in case of Domestic RTP?
……………..is it termed as imports of service ?
6. ITC availed and utilized on advances paid ?

What to do?
7. MNC India is the subsidiary of MNC overseas whose business is scattered all over the world. MNC India has
transactions with all the entities of MNC overseas. MNC India CA is providing services to MNC overseas entities in
respect of various tax laws compliances to be done in India considering POEM, BC , PE etc. As per the provisions of
FEMA, MNC India CA is required to raise his invoices on MNC overseas Entities but as per the terms of the
arrangement MNC India CA should not raise any invoices on MNC Overseas Entities what fees he is charging to MNC
India which includes services provided to MNC Overseas Entities.
Q. Will such non invoicing permitted under GST law to MNC India CA ? Is it not the violation of FEMA when his fees
raised to MNI India for services rendered to MNC Overseas Entities especially when there is loss foreign exchange for
the RBI ? What should be done in such scenario?
8. ITC availed on Imports………….supplier not paid…………will it trigger Rule 37 reversals?

What to do?
7. MNC India is the subsidiary of MNC overseas whose business is scattered all over the world. MNC India has
transactions with all the entities of MNC overseas. MNC India CA is providing services to MNC overseas entities in
respect of various tax laws compliances to be done in India considering POEM, BC , PE etc. As per the provisions of
FEMA, MNC India CA is required to raise his invoices on MNC overseas Entities but as per the terms of the
arrangement MNC India CA should not raise any invoices on MNC Overseas Entities what fees he is charging to MNC
India which includes services provided to MNC Overseas Entities.
Q. Will such non invoicing permitted under GST law to MNC India CA ? Is it not the violation of FEMA when his fees
raised to MNI India for services rendered to MNC Overseas Entities especially when there is loss foreign exchange for
the RBI ? What should be done in such scenario?
8. ITC availed on Imports………….supplier not paid…………will it trigger Rule 37 reversals?
9. E Invoicing issues & ISD Invoicing Issues or RCM claims issues or ITC on Imports ( time limits)…………………?

8 Other ITC related information

A ITC as per GSTR-2A (Table 3 & 5 thereof) Auto
B ITC as per sum total of 6(B) and 6(H) above Auto
C ITC on inward supplies (other than imports and inward
supplies liable to reverse charge but includes services
received from SEZs) received during 2017-18 but availed Table 4(A)(5)
during April to September, 2018
D Difference [A-(B+C)]
E ITC available but not availed (out of D)
Need to populate only
F ITC available but ineligible (out of D)
IGST paid on import of goods (including supplies from SEZ)
IF ITC as per GSTR 2A is
G more than ITC as per
IGST credit availed on import of goods (as per 6(E) above) GSTR 3B
H
Auto
I Difference (G-H)
ITC available but not availed on import of goods (Equal to I)
J Table 6E ???
Total ITC to be lapsed in current financial year (E + F + J)
K Auto

Part IV – Tax Paid – Table 9- Source GSTR 3B
Pt. IV Details of tax paid as declared in returns filed during the financial year
9 Description Tax Payable Paid through cash Paid through ITC OTL- Rs.20 Lakhs ITC –
Rs.15 Lakhs
Central Tax State Tax / Integrated Tax Cess Bal – Rs.5 Lakhs
UT Paid late by 10 days
Tax Interest paid on 5
Lakhs ? Or Interest
1 2 3 4 5 6 7 payable on 20 Lakhs
Integrated Tax - - - - -
Central Tax - - - -
State/UT Tax - - - -
Table 6.1-
Cess - -
GSTR 3B
Interest - -
Late fee - -
How do we report
Penalty - - in AR? No such
Other - - provision or
Data Auto Populated report in table 14
Interest Rate
changes nitin.bhuta@gmail.com
Part V – Circular 26 Effects - Table 10 – 14 – FY 2223 i.e. 1.4.2022 to 30.11.2022
Pt. V Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of
filing of annual return of previous FY whichever is earlier
Description Taxable Value Central Tax State Tax / Integrated Tax Cess
DN and CN can be
UT issued by the Supplier
Tax
only.
1 2 3 4 5 6
10 Supplies / tax declared through
Amendments (+) (net of debit notes) Table 9A 9B 9C
GSTR
11 Supplies / tax reduced through 1
Amendments (-) (net of credit notes) Table 9A 9B 9C
12 Reversal of ITC availed during previous
financial year Table 4(B) GSTR
13 ITC availed for the previous financial 3B
year Table 4(A)
14 Differential tax paid on account of declaration in 10 & 11 above
Description Payable Paid Increase in OTL is
1 2 3
Integrated Tax
permitted beyond due
Central Tax date whereas reduction
State/UT Tax in OTL is not permitted
Cess
beyond due dates
Interest

Reversal of ITC availment /reversal and Reavailment
FY 2122 - part III

a. If reversed in FY
FY 2223 - Part V
2122 ( Table 7C a. Reversed in FY If not reversed then
& Table 7D) of 2223 ( table 12 only option to pay
GSTR 9- Rule 42 of GSTR 9) through DRC 03 with
& 43 b. Reavailed in FY Interest using annual
b. If reavailed 2223 ( Table 13 returns option.
then Table 6A
of GSTR 9
of GSTR 9 )

Part V – Table 10 –Supplies /tax declared through
amendments + ( net of debit Notes ) – Apr 22 to Nov 22
( technically Oct 22 return only)
Additional Invoices pertaining to FY 2122 reported till GSTR 1 of October 22
Debit Notes dated before 31/03/2022 and not reported in FY 2122
Amendments to Invoices pertaining to FY 2122 reported

till GSTR 1 of October 22

Part V – Table 10 –Supplies /tax reduced through
amendments - ( net of credits notes ) – Apr 22 to Nov 22
( technically Oct 22 return only)
Credit Notes dated 2021-22 and reported till GSTR 1 of October 22
Amendments to Invoices pertaining to FY 2122 reported (with errors )

In GSTR 1 of FY 2223 upto Oct 22.

Part VI – Other Information – Table 15 -19 ( FY 2122 )
Pt. VI Other Information

15 Particulars of Demands and Refunds
Details Central State Tax / UT Integrated Tax Cess Interest Penalty Late Fee
Tax Tax / Others
1 2 3 4 5
• Only GST demand
A Total to be included
Refund • SCN not to be
claimed
B Total Refund reported under this
sanctioned
tables
C Total Refund • Appeals made
Rejected
values to be
D Total Refund
Pending
reported in this
sections.
E Total
demand of • Refund under LUT
taxes
Total taxes
or Refund without
paid in LUT ? ITC claim on
F respect of E
above
Inputs/Inputs
Total
Services and/or CG
demands
G pending out
of E above

Refunds
• Refunds of taxes paid in excess
• Refund of taxes paid on account of deemed exports (where refund is

claimed by the suppliers)
• Refund of balance in cash ledger after the payment of taxes
• Refund of Taxes paid on account of deemed exports ( where refund is

claimed by the recipients.

Refunds
• Refunds of Unutilised ITC in case of Zero rated supplies of G/S without
the payment of Tax
• Refund of taxes paid on account of Supply of G/S made to SEZ

unit/Developer
• Refund of taxes paid in case of Zero rated supplies of G/S with payment
of taxes
• Refund of unutilized ITC on account of Inverted duty structure

16 Information on supplies received from composition taxpayers, deemed supply under section 143 and goods sent on approval Information provided
basis in Income Tax Return
Details Taxable Value Central Tax State Tax / Integrated Tax Cess where audit is not
UT applicable under
Tax Income Tax Act 1961.
1 2 3 4 5 6
Supplies received from Composition GSTR
A Table 5
taxpayers 3B
B Deemed supply under Section 143 Job work supplies – Goods & CG
Goods sent on approval basis but not Goods not received

C returned within 6 months
Closing Stock Bifurcation ?

Stock records not maintained in FS/TAR ? Stock details reported in

17 HSN Wise Summary of outward supplies TAR & FS ?
HSN UQC Total Taxable Rate of Tax Central Tax State Tax / Integrated Tax Cess
Code Quantity Value UT
Tax
GSTR 1- Table UQC net
1 2 3 4 5 6 7 8 9
12 of returns
Compulsory reporting
18 HSN Wise Summary of Inward supplies
HSN UQC Total Taxable Rate of Tax Central Tax State Tax / Integrated Tax Annual Turnover or
Code Quantity Value UT
Tax
Cess
Aggregate Turnover ???
1 2 3 4 5 6 7 8 9 < 5 Cr – 4 Digits
> 5 Cr -6 Digits
19 Late fee payable and paid
Description Payable Paid
1 2 3 Applicable if AR is filed
A Central Tax
B State Tax
beyond due dates
Changes in Rate Structures as notified from time to time

Admissibility Verifications If anti profiteering
under evidence exercise not done ?
law?
I hereby solemnly verify and declare that the information given herein above is true and correct to the
best of my knowledge and belief and nothing has been concealed there from and in case of any reduction
in output tax liability the benefit thereof has been/will be passed on to the recipient of supply.
Place Signature of Authorised Signatory

Date Designation/Status
Information highlighted in yellow is not right and absolute wrong considering the principles of natural
justice and Rules of Law of the Country. Information stating passing of benefits arising out of GST
implementation is relevant from anti profiteering clause perspective.

Illustrations

Outward Supply
Table 4 , 5 , 10 & 11

GSTR 9 Dream and Ideal Situations
Books GSTR 1 GSTR 3B
ITC after all reversals GSTR 2A / GSTR 3B – Table 4

and adjustments RCM/Imports/ISD

Deemed Exports – Table 4
GST- N No 48/2017 dt 18.10.2017 Foreign Trade Policy
• Supply of goods against advance • Supplies to projects against international

authorization competitive bidding
• Supply of capital goods against EPCG • Supplies to projects with zero customs
authorization duty
• Supply of goods to • Supply of goods to mega power projects
EOU/STP/EHTP/BTP against International Competitive Bidding
• Supply of gold by bank/PSU specified • Supplies to UN Agencies
in Notification No. 50/2017-Customs • Supply of goods to nuclear projects
dated 30.06.2017. through competitive bidding

Total Aggregate Turnover for each GSTIN
Table 4 Table 5 Table 10 Table 11 Total
Details of
Outward and Details of Supplies /tax
Supplies /tax Aggregate
inward Outward and declared
inward supplies declared through taxable
supplies made through
made during the amendments (-) Turnover for
during the amendments ( Net of Credit
financial year on each GSTIN
financial year which n o tax is (+) ( Net of notes ) (5N +10-11 )
on which tax is payable debit notes )
payable

OUTWARD SUPPLY on Which Tax is payable
– GSTR 9 – FY 2122 – Table 4
Supply declared in Supply not declared in
Supply declared in
FY 2223 pertaining to FY FY 2122 –R1/3B
FY 2122 – R1/3B
2122 –R1/3B
Table 4 Table 10 & 11 Table 4 + DRC 03
Table 9 Table 14 Table 9 + Cash Payment

Part II – Table 5 Outward Supplies on which Tax is not payable(Source –GSTR 1 )
Goods Services
Export
SEZ
Exempt
Customs Act Supplies Repatriations of Funds
NIL Rated
Non GST
Only three supplies – 1. Lease of land 2.
Supplies agriculture, fishing etc 3.govt services by
1. High Sea Sales ?
Non CG, SG & Government Authorities etc.
2.Sales from Bonded
Warehouse/MOOWR Taxable
3. Recovery of cost credited to Supplies
Expenditure/ Asset/ Liability etc LUT conditions to be complied
4. CN not subjected GST would covered
in clause 5F
and needs to be checked while
filing AR
Under Without
LUT/Bond LUT/Bond
OUTWARD SUPPLY on which no Tax is payable
– GSTR 9 – FY 2122 – Table 5
Supply declared in
FY 2122 – R1/3B
2122 –R1/3B
Table 10 & 11
Table 5 Table 5 + DRC 03 ?
– only Table 5
Table 9 – no effect Table 14 – no effect Cash Payment ?

OUTWARD SUPPLY on Which Tax is payable – GSTR 9 –
pertaining to FY 2122 declared
in FY 2223 after 30.11.2022
Supply declared in
FY 2122 – R1/3B
2122 –R1/3B
Table 4 ? Table 10 & 11 ? Table 4 + DRC 03 ?
Table 9 +Cash Payment

Table 9 - ? Table 14 - ?
?

Financial Data
Turnover Value of Supply IGST CGST SGST Total GST Total

(Net )
Books of accounts FY 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000

2122
R1 and 3B in FY 2122 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000

– Total ( A)
R1 and 3B of FY 2223 50,000 4,500 2,250 2,250 9,000 59,000
from Apr 22 to Nov
22 (B)
Turnover not 50,000 4,500 2,250 2,250 9,000 59,000

Reported at all (c )
FY 2021 reported in 1,00,000 9,000 4,500 4,500 18,000 1,18,000

FY 2122 R1 & 3B (D)
FY 2122 not reported 50,000 4,500 2,250 2,250 9,000 59,000

at all (E )

Illustration FY 212 Reporting – GSTR 9

(Net )
Books of accounts 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000

FY 2122
R1 and 3B in FY 2122 – 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000

Total ( A)
Add : Turnover not 50,000 4,500 2,250 2,250 9,000 59,000
Reported at all (c )
Less : FY 2021 reported 1,00,000 9,000 4,500 4,500 18,000 1,18,000

in FY 2122 R1 & 3B (D)
Value to be reported in 9,50,000 85,500 42,750 42,750 1,71,000 11,21,000

Table 4 (A+C-D)
R1 and 3B of FY 2223 50,000 4,500 2,250 2,250 9,000 59,000

from Apr 22 to Nov 22
(B) – Part V – Row
10/11
Total Value declared in 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000
GSTR 9 = Table 4 +Part
V – Row 10 – Row 11

Illustration FY2223 Reporting – GSTR 9

(Net )
Books of accounts 10,00,000 90,000 45,000 45,000 1,80,000 11,80,000

FY 2122
FY 2021 reported 1,00,000 9,000 4,500 4,500 18,000 1,18,000

in FY 2122 R1 & 3B
(D)
Why ? ? ? ? ? ? ?
FY 2122 not 50,000 4,500 2,250 2,250 9,000 59,000

reported at all (E )
Why ? ? ? ? ? ? ?

Input Tax Credit
Table 6 , 7 & 8

Input Tax Credit
Table 6 Table 7 Net ITC
Details of ITC
Details of ITC availed reversed and
Net ITC Available for
during the financial Ineligible ITC for the
Utilization (6O - 7I) =
year financial year
7J
- GSTR 3B - GSTR 3B

ITC availed in the financial year
– GSTR 9 – FY 2122 – Table 6 /7/8 – Part V
ITC availed and utilised in ITC claimed in GSTR 3B of FY ITC not claimed for in
GSTR 3B 2223 pertaining to FY 2122
FY 2122 –3B
FY 2122 up to Nov 22
Not. No
79/2020
dt Table 8C/
Bifurcation Lapsed
15.10.20 Part V- Row 12/ 13
????
Table 9 – Electronic Credit Ledger

–ITC utilised
No Impact Loss/write off

ITC availed in the financial year – pertaining to previous
claimed in subsequent financial year –
Table 6 /7/8 & Part V – FY 2122 & GSTR 9C
ITC claimed in GSTR 3B of FY ITC claimed in GSTR 3B of FY
2223 pertaining to FY 2122 up 2223 pertaining to FY 2122 GSTR 9C
to Nov 22 up to Nov 22
Not. No
79/2020
dt Part V- Row -13
Table 12C- ITC booked in CFS
15.10.20 ( ITC availed in previous to be claimed in subsequent
???? Table 8C –FY 2122
financial year ) FY (- )
– FY 2122

ITC availed in the financial year – pertaining to FY 2021-
in FY 2122 up to 30.09.2021 – Table 6 /7/8 & Part V
ITC availed and utilised in ITC claimed in GSTR 3B of FY ITC not claimed for in
GSTR 3B 2122 pertaining to FY 2021
FY 2021 –3B
FY 2122 up to Sep 21.
Not. No
79/2020
dt Table 8C –FY 2021/
Bifurcation Lapsed
15.10.20 Row 13 (ITC availed)
????
Table 9 – Electronic Credit Ledger No Impact -if not Loss/write off

– ITC utilised reported in GSTR 9?

ITC availed in the financial year – pertaining to previous
year claimed in subsequent financial year –
Table 6 /7/8 & Part V – FY 2122 & GSTR 9C
ITC claimed in GSTR 3B of FY ITC claimed in GSTR 3B of FY
2223 pertaining to FY 2122 up 2223 pertaining to FY 2122 GSTR 9C
to Nov 22 up to Nov 22
Not. No
79/2020
dt
Part V- Row -13
15.10.20 Table 12B -ITC Booked in
( ITC availed in previous earlier FY claimed in CFY ( +)
???? Table 8C – FY 2122
financial year )
– FY 2122

Financial Data as per Books of accounts as well as in TAR –FY 2122
Input Tax Credit IGST CGST SGST Total GST
Opening Balance (A)

30,000 15,000 15,000 60,000
Add: availed in BOA (B)
60,000 30,000 30,000 1,20,000
LESS: Utilised in BOA
(C )
50,000 25,000 25,000 1,00,000
Closing Balance = D
(A+B-C )
40,000 20,000 20,000 80,000
Opening Balance includes
ITC of FY 2021 claimed in
5,000 2,500 2,500 10,000
FY 2122 (E)
Closing Balance includes
ITC of FY 2122 claimed in
10,000 5,000 5,000 20,000
FY 2223 up to Nov 22 (F )

Data as per Electronic Credit Ledger – FY 2122
Input Tax Credit IGST CGST SGST Total GST
Opening Balance as per ECL

(A)- ( D )
25,000 12,500 12,500 50,000
Add: availed in GSTR 3B
(B)+ ( E) – (F )
55,000 27,500 27,500 1,10,000
LESS: Utilised in BOA
(C ) – Table 6
50,000 25,000 25,000 1,00,000
Closing Balance = D
(A+B-C )
30,000 15,000 15,000 60,000
Opening Balance includes ITC of
FY 2021 claimed in FY 2122 (E)
5,000 2,500 2,500 10,000
– Row 13 of Part V
Closing Balance includes ITC of FY

2122 claimed in FY 2223 up to
10,000 5,000 5,000 20,000
Nov 22 (F) – Table 8C
Total as per Books = D+F

40,000 20,000 20,000 80,000

GST PAYOUTS
Table 9 & 14

GST Payouts
Table 9 Table 14
Payable Cash Credit Payable Paid
Non Non
Editable Editable Editable
Editable Editable
Return filing period of GSTR 9 Part V – Next Permissible period

Some Illustrative Examples
If Value of outward supplies reported
in GSTR 1 =GSTR 3B = Books then
GSTR 1 = GSTR 3B = Books =
data would be auto populated by
Rs.10,00,000/-
GSTN Portal using GSTR 1 nothing to
be done by the RTP.
Table 4 = GSTR 1=
Rs.10,00,000/-
Any changes in GSTR 9- No

If Value of outward supplies reported in GSTR 1
=GSTR 3B matches but value as per Books don’t GSTR 1 = GSTR 3B = Rs.10,00,000/-
match and such deviation are reflected in FY 2223
by RTP then data would be auto populated by
GSTN Portal using GSTR 1 but filing AR , deviations
Books = Rs.15,00,000/-
reported In FY 2122 to be reported in Part V –
Table 10 , 11 & 14. to the extent of GSTR 3B Deviations = Rs.5,00,000/-
deviations
Table 4 = GSTR 1= Rs.10,00,000/- While filing GSTR 9- Table 10,

Deviations to be reported in Part V of 11 & 14 to be updated by
Table 10 , 11 & 14. Rs.5,00,000/- only
=Books matches but value as per 3B don’t match GSTR 1 = Books = Rs.10,00,000/-
and such deviation are reflected in FY 2223 by RTP
then data of outward supplies to be considered as
per 3B & not GSTR 1 but filing AR , deviations
GSTR 3B = Rs.15,00,000/-
Table 10 ,11 & 14 to the extent of GSTR 3B Deviations = Rs.5,00,000/-
deviations.
Table 4 = GSTR 3B= Rs.10,00,000/- While filing GSTR 9- Table 10 ,

Deviations to be reported in Part V of 11 & 14 to be updated by
Table 10, 11 & 14. Rs.5,00,000/- only
GSTR 1 = Rs.12,00,000/-
=Books matches but value as per 3B don’t match
and such deviation are reflected in FY 2223 by RTP
GSTR 3B = Rs.10,00,000/-
then data of outward supplies to be considered as
per 3B & not GSTR 1 but filing AR , deviations
Books = Rs.15,00,000/-
Table 10 , 11 & 14 to the extent of GSTR 3B
Deviations = Rs.5,00,000/-
deviations.
Table 4 = GSTR 3B= Rs.10,00,000/- While filing GSTR 9- Table 10 , 11 &

Deviations to be reported in Part V of
14 to be updated by Rs.5,00,000/-
Table 10 , 11 & 14. only

Some issues to Ponder Upon What can be done?
1. If RTP has paid GST on my outward supply for FY 2122 but the
same is not reported in GSTR 1 as well as GSTR 3B is any
remedy available?
2. If RTP has raised invoices in FY 2122 but his advisor or
accountant has filed his GST invoices with different Invoice
Numbers in FY 2223 and RTP has filed its Oct 22 return as well
as Filed its ITR return? Is any remedy available for corrections?
3. ITC on advance claimed ? - silent/reverse? Interest on reversal
4. Stock details – TAR /Corporate FS/ITR ?

GSTR 9 – Online Download from GSTN Portal
Navigate through
Login to GSTN Portal Select Returns
Services
Not
Avail
Select Annual
able
Returns Download GSTR 9 Summary
Download GSTR 1 Summary

Compute
Offline Online
Late Fees
Download GSTR 3B Summary
Preview Download GSTR 9 Download Table 8A Summary

• NIL GSTR can be filed if you have

• Not made any outward supply ( commonly known as sale ) AND
• Not received any goods and/or services ( commonly known as Purchase ) AND
• No other liability to Report AND
• Not claimed any credit ( ITC) And
• Not claimed any Refund AND
• Not received any order creating demand AND ( SCN – not be considered)
• There is no late fee to be paid etc.
• Please note that such option would be auto reflected on GSTN Portal but if select it
to be No then again same option won’t be available under any circumstances.

• Download GSTR 9 Summary

• Download GSTR 1 Summary
• Download GSTR 3B Summary
• Download Table 8A Summary.
• Computation of Late Fees
• Preview of GSTR 9
Conclusions in Annual Returns
• Data which has been auto populated is till 30/11/2022 but Table 8A download is not available so
what to do ?
• Compute Tax Liability and pay through DRC-03.
• ITC credit can not be increased in the annual return but reversal of ITC is permissible in annual
return.
• Data not entered in returns can be added in GSTR-9 effectively if liability increased then pay through
DRC-03, if liability reduced the same shall be ignored by the systems and will allow for its filing.
• Most of tables contains auto populated data but the same is for convenience purpose but needs to
be checked form books of accounts.

• Please ensure that all working papers in the form of documentation are kept on
record so that in future they are available to substantiate your basis authenticating
the compilation of annual returns.
• Please understand that Sovereign has all data available at their disposal using the
techniques of data mining, Artificial Intelligence, Virtual and Mixed Technological
data base to verify and match the data.
• All BU would be requested to explain substantiate and share their internal

documents in future. So make sure you have everything maintained in physical as
well as digital form to avoid any kind of probable litigation issues.

• Withdrawals and amendment of Annual Return filed won’t be allowed

or permitted due to system controls maintained by the GSTN Platform.
• If BU is unable to explain with the documentation , chances are that

looking at the trend followed, such discrepancies might be result into
issue of SCN and probable litigations which may disrupt ease of doing
business in India.

G S T S e l f
R e c o n c i l i a t i o n
S t a t e m e n t
F o r m 9 C
Self Reconciliation Statement
•Audit in Normal Relationships

•Wedding Examples – Vicky & Katrina, Ranbir & Alia, Ambani + Piramals
, Priyanka & Nick , Ranveer and Deepika
•Sundry creditors written back on which ITC has been claimed
•Writing off Fixed Assets in the Financial Statements
•Industry – Real Estate, FMCG etc.
•Multi State GSTIN Audit Issues – Languages – determination of ITC
reversals under Rule 42 & Rule 43.
•Ascertainment & Determination – Positive and Negative

Self Reconciliation Statement of Business Units
• Audit Enforced by Law – Statutory Audit/Cost Audits/Tax Audit/VAT
Audit/GST Audit/Society Law/Special Audits/Investigation Audits etc.
• Voluntary – Internal/Suo Motto/Due Diligence
• Banks – Stock Audit/Revenue Audits/Forensic Audit/Concurrent Audit
• Industry specific – Insurance , Aviation's, SEBI, Pharma- FDA etc.
• Any other Type of Audits
• Self Reconciliation Statement is the reconciliation statement driven by
verification of the documentation and economic transaction values of
business enterprise (including deemed supplies between Related
parties and distinct persons) on self assessment basis.
Self Reconciliation Statement of Business Units
• Statutory Audit report is always linked to Status of an entity whereas Self
Reconciliation Statement is always linked to GSTIN Number of the RTP.
• Before commencing and compilation of the Self Reconciliation Statement one
needs to understand the nature of business activities carried by the BU.
• BU advisors needs to aware about the all kinds of tax compliances applicable to
such BU.
• Self Reconciliation Statement Program needs to devised according to the sector in
which such BU is operating

Self Reconciliation Statement Of Business Units
• Self Reconciliation Statement Test checks ? 100% verification ? RTP or advisors

need to be extra vigilant , careful in maintaining the documentation because
there is convergence of Accounting, Direct Tax Law, Indirect Laws under old
regime as well as new regime and all other ancillary and incidental laws
applicable to BU.
• One needs to be clear who would be using such Reports and Financial
Statements ( Stakeholders – Target audience )
• Considering size, volume and nature of economic activity audit needs to be
conducted by using technology features as the volume of data assimilation is a
Hercules task to complete the audit by 31.12.22. ( Extension ? – Rule 80(3A) –
Section 164)
Clause by clause analysis of form 9C (Rule 80(3)
• Every Self Reconciliation Statement report needs to be filed electronically by

all RTP using EVC & DSC options on or before 31.12.22.
• It is always recommended to ask RTP to file annual return GSTR 9 first as lot of
data picking will happen from GSTR 9 . Now without filing GSTR 9, 9C filing
won’t be initiated by the Portal.
• GSTR 9 needs to be filed by every RTP as there is no exemption for the same.
• GSTR 9C need not be filed by most of Government authorities ( say CG, SG &
Local authority)
• GSTR 9C need not be filed by ISD , E Commerce operators, Composition
Dealers and/or persons deducting TDS u/s 51 or 52 of the Act, CTP and NRCTP.
( Similar to GSTR 9 )
Clause by clause analysis of form 9C (Rule 80(3)
• All RTP and advisors filing GSTR 9C need to compile data for each GSTN wise to
be reconciled with audited Financial statements of enterprise on PAN India
Basis.
• If possible and permissible it is recommended to have individual financial
statements drawn up for each GSTN wise so that consolidation of data
becomes little easier for the compilation of GSTR 9 as well as GSTR 9C.
• Annual Financial Statements consist of Notice, Directors Report, Auditors
Report, Balance Sheet, Profit and Loss Account/Income & Expenditure
account, Cash Flow Statements and Notes to accounts , Other workings etc.
• Tax Audit Reports consisting of either Form 3CA/3CD for Corporate assessee or
Form 3CB/3CD for non corporate assessee. Similarly transfer pricing reports

Clause by Clause analysis – GSTR 9C key take
aways
• Various AARs/Notifications – Circulars issued time to time etc.
• While reporting or compiling information under 9C all above documents needs to
be considered so that all information reported everywhere is properly reconciled
For E.g.
• Exports reported in FS needs to be reported in GSTR 1 as well as GSTR 3B and vice a versa
• Imports reported in FS needs to be reported in GSTR 3B for the claim of ITC and vice a versa
• Withholding Taxes information u/s 195 reported in Tax Audit Report clause 34
• Related Party Transaction u/s 40A (2)(b) or AS 15 or Transfer Pricing adjustment reported
under clause 30A etc.
• Details of Branches reported in Clause 2 of Form 3CA/3CB

Business Transactions
No Supply Exempt NIL Rated
No GST Supply Non Taxable
Supply
Intra State Interstate/Cross Border

( CGST +SGST) ( IGST )
Single Supply Composite Supply Mixed Supply

Tax Rate Principal Supply Maximum Rate
applicable GST Rate of GST Tax

Composite Supply
Section 2(30) defines “Composite supply” means a supply made by a taxable person to a recipient comprising
two or more supplies of goods or services, or both or any combination thereof, which are naturally
bundled and supplied in conjunction with each other in the ordinary course of business, one of which is a
principal supply;
“Principal supply” means the supply of goods or services which constitutes the predominant element of a
composite supply and to which any other supply forming part of that composite supply is ancillary and does
not constitute, for the recipient an aim in itself, but a means for better enjoyment of the principal supply;
Where goods are packed and transported with insurance , the supply of goods , packing
materials , transport and insurance is a composite supply and supply of goods is a principle
supply.

Mixed Supply
Section 2(74) “Mixed supply” means two or more individual supplies of goods or services, or any
combination thereof, made in conjunction with each other by a taxable person for a single price where such
supply does not constitute a composite supply – Will attract the Highest Rate of Tax
Examples: Supply of soap bars where soap boxes are given free of cost; supply of wheat for which a bottle
of honey is given free of cost.
In the above example of honey being supplied with wheat, both wheat and honey will be taxed at the rate
of tax applicable for honey (being commodity taxed at higher rate).

Annual Returns –Self Reconciliation Statements to be considered
Outward Supply ITC Tax Paid

•Classification Issues –HSN & •Wrong claim of ITC •Wrong deposit of Tax u/s
SAC •Tax Invoices not auto Section 77
• POB Issues populated in GSTR 2A •Wrong Deposit of Interest
•Incorrect Reporting •Reversals under Rule 37,39 payable
•Non Reporting ,42 & 43 etc. •Non Deposit of GST ,
•Exempt, NIL Rated & Non Interest, Late Fees etc.
•Unclaimed ITC in GSTR 3B
Taxable Supplies •Payment of tax due to ITC
•LUT Issues
•Documents information in issues
GSTR 1 •Nexus Theory – Table 17/18
Illustrative Only
GST Law Statutory
A B Reports
Extended Nexus Theory

C Business Laws D
GST Audit Circulars/

E Checklist Review F Notification
Self Reconciliation G AAR/ Old Regime

H Final Reporting
Statement precedents
Basics of Self Reconciliation Statement

Basics of Self Reconciliation Statement GSTR 9C
• Self Reconciliation Statement GSTR 9C applicable to whom?
GSTR 9C to be filed electronically only every year by every RTP
whose aggregate turnover exceeds Rs.5 Crores
and the same is required to be filed for each GSTIN Number

Basics of Self Reconciliation Statement GSTR 9C
• Self Reconciliation Statement GSTR 9c not applicable to whom?
GSTR 9C is not applicable to following :-

Input service Distributors
E commerce Operators
TDS deductors u/s 51 or 52
CTP /NRCTP and
Government Authorities

Basics of Self Reconciliation Statement in GSTR 9C
• What is due date for the filing of Self Reconciliation Statement in
GSTR 9C ?
Due date of Filing of 9C is 31.12.2022 as on today

Rule 80(3A) invocation u/s 164 ?

• If person has not filed GSTR -1 as well as GSTR 3B , can he still file
Annual Returns GSTR 9C ?
No , RTP would be required to file

GSTR 1 , 3B & GSTR 9 before he
can file GSTR 9C.

• Is Annual Returns GSTR 9 to be filed before GSTR 9C – Audit Report?
It is recommended to file and

cannot be filed before the filing of
GSTR 9 and now only after filing of
R1, R3B & GSTR 9 filing of GSTR 9C-
Audit Report is initiated.

• Section 2(6) defines “aggregate turnover” means the aggregate
value of all taxable supplies (excluding the value of inward
supplies on which tax is payable by a person on reverse charge
basis), exempt supplies, exports of goods or services or both
and inter-State supplies of persons having the same Permanent
Account Number, to be computed on all India basis but excludes
central tax, State tax, Union territory tax, integrated tax and
cess;
The phrase “aggregate turnover” is widely used under the GST
laws. Aggregate Turnover is an all-encompassing term covering
all the supplies effected by a person having the same PAN.
Aggregate Turnover
• It specifically excludes:
· Inward supplies effected by a person which are liable to tax under reverse charge
mechanism; and
· Various taxes under the GST law, Compensation cess.
• The different kinds of supplies covered are:
• (a) Taxable supplies;
• (b) Exempt Supplies:
• supplies that have a ‘NIL’ rate of tax;
• supplies that are wholly exempted from SGST, UTGST, CGST, IGST or Cess;
and
• supplies that are not taxable under the Act (alcoholic liquor for human
consumption and articles listed in section 9(2) and in schedule III);
• (c) Export of goods or services or both, including zero-rated supplies.

Aggregate Turnover
• Points to remember:-
• Aggregate turnover is relevant to a person to determine:
• Threshold limit to opt for composition scheme: Rs. 1.5 Crore in other
states/Rs.75 Lakhs in specified states in a financial year);
• Threshold limit to obtain registration under the Act: 20 Lakhs for Services
and 40 Lakhs for Goods (or 10 Lakhs in case of supplies effected from
Special Category States) in a financial year.
• Filing of Self Reconciliation Statement is mandatory if aggregate turnover is
more than Rs.5 crores.
Aggregate Turnover
• Inter-State supplies between units of a person with the same PAN will
also form part of aggregate turnover.
• For an agent, the supplies made by him on behalf of all his principals
would have to be considered while analysing the threshold limits.
• For a job-worker, the following supplies effected on completion of job
work would not be included in his ‘aggregate turnover’:
• Goods returned to the principal
• Goods sent to another job worker on the instruction of the principal
• Goods directly supplied from the job worker’s premises (by the
principal): It would be included in the ‘aggregate turnover’ of the
principal.
Aggregate Turnover
SR No Particulars Value ( Rs. )
1 Taxable Turnover as per Financial Statements ( excluding Taxes ) B2B, xxxxxx.xx
B2C, Exports, SEZ , Net effect of CN/DN etc.
2 Value of Exempt Supply , NIL Rated Supply , Non Taxable Supplies & xxxxxx.xx
No Supply too excluding supplies notified under schedule III as per
CGST Act, 2017.
3 Branch Transfers ( excluding Taxes ) – such transaction would be xxxxxx.xx
nullified in the annual Financial statements
4 Transactions between Related Parties ( excluding Taxes ) – Employer xxxxxx.xx
and Employee where value exceeds Rs.50000
5 Transactions between Principal and Agent ( excluding Taxes ) xxxxxx.xx
6 Value of Cross Charges between HO & Branch and so on -such xxxxxx.xx

transaction would be nullified in the annual Financial statements
7 Total Value of Aggregate Turnover ( Sum of 1 to 6 ) xxxxxx.xx

Determination of Aggregate Turnover
Branches
Business Model & Depots
HO/Factory
Cross
Charge
Investments or Properties Aggregate

Warehouses
Out and Out Supplies ??? Turnover
Ledgers NIL Rated

& Fixed Exempt
Related Assets No Supply
Non GST Supply
parties

Clause by clause analysis of form 9C –Self Reconciliation
Statement
• Applicable to all RTP whose aggregate turnover exceeds prescribed limits as specified under the GST
Act 2017 viz. 5 Crores
Form9C
• All RTP would need to file Annual return GSTR 9+ GSTR 9C with audited financial statements and any
other documents as necessary to be filed on or before 31.12.2022
• All Composition dealers need to file GSTR 9A

• All E Commerce operators need to file GSTR 9B
Form 9A &
9B • Need to be filed on or before 31.12.2022
• All other RTP need to file GSTR 9 mandatorily if aggregate turnover exceeds Rs.2 Cr.
• Need to be filed on or before 31.12.2022
Form 9

Clause by clause analysis of form 9C –

Poser – GSTR 9C?
• Difference of Opinion with Team Members as well as with clients
• Difference of opinion due to notifications/circulars/AARs etc
• Drafting & reconciliation ???? should be done meticulously to avoid any kind of
litigation
• Can we as advisors rely on Management representation letters ?
• Can RTP say that it is not possible to explain some aspects of business transactions
during the assessment?

Poser – GSTR 9C?
• Can RTP say that in some business, certain practices are followed but they are not aligned to GST law
? So whether business practice would prevail or GST law would prevail?
• Can RTP say that due to shortage of staff or last minute approach by the client, there is a mistake in
the Self Reconciliation Statement report? Will such stand be accepted as defence?
• Can RTP say certain books of accounts are not maintained ?
• Can RTP ignore the adding additional POB in RC ?
• Can we apply the principles of Materiality while filing Self Reconciliation Statement as advisor ?

Poser – GSTR 9C?
• Can RTP ignore the classification of goods and services of the supplies?
• Do RTP need to reconcile the transactions with subsidiaries /branches or not?
• Can RTP say stock records not maintained under Income Tax Law and thus
quantitative details not reported under GST law?
• If Client has applied against Advance Ruling so how do we report such aspect in GST
Returns ?

Some illustrative situations under section 122(1) r.w.s 73/74
Invoice Tax
Collecte Failure to
Supply Failure to
False or W/o d in TDS not collect or at
w/o Unpaid remit
incorrect supply contrave deducted
Invoice lower rate
ntion
Penalty
1. minimum Rs.10000/- 2. Tax evaded 3. Tax not deducted 4. Tax which is short deducted /collected 5. Tax
collected but not paid to the Govt 6. ITC wrongly availed 7. ITC wrongly distributed by ISD 8. Fraudulent
claim of refunds
Any person who aids or abets any such offence shall be liable to a penalty which may extend to Rs.25000/-

Some illustrative situations under section 122(1) rws section 73/74
Other Offences
Tampers/destroys any material Disposing/tampering with goods detained seized or

evidence or documents attached
Penalty
1. minimum Rs.10000/- 2. Tax evaded 3. Tax not deducted 4. Tax which is short deducted /collected 5. Tax
collected but not paid to the Govt 6. ITC wrongly availed 7. ITC wrongly distributed by ISD 8. Fraudulent
claim of refunds
Any person who aids or abets any such offence shall be liable to a penalty which may extend to Rs.25000/-

Clause by clause analysis of form 9C –Self
Reconciliation Statement
Part A- Turnover - Reasons Part A -Taxes paid- Reasons
Form 9C- Self

Part B- Recommendations/ Observations

Part A- Input Tax Credit - Reasons
and/or Qualifications

Clause by clause analysis of form 9C –Self
Part A – Reconciliations statements – Section
44(2) of CGST Act –
Audited FS/Books and
Annual Return GSTR 9

Clause by clause analysis of Form 9C – Self Reconciliation Statement –
basic structure – Reconciliation STATEMENTS Part A
Particulars Rows Reconciliations
Part I Basic Details 1-4
Part II Reconciliation of Turnover 5-8 AT-1
declared in Audited Financial
Statements with annual Turnover AT-2
declared in Annual Return GSTR -9
Part III – Reconciliation of Tax Paid 9-11 PT-1
Part IV – Reconciliation of Input 12-16 ITC -1
Tax Credit ( ITC ) ITC -2
Part V – Auditors
recommendation on additional
liability due to non reconciliations

Clause by clause analysis of Form 9C – Self Reconciliation
Statement – basic structure – Part A – Part I Basic DETAILS
Sr No. Basic Details
1 Financial Year
2 GSTN
3A Legal Name <Auto >
3B Trade Name ( if any ) <Auto >
4. Are you liable to audit under any Act ? <<Please Specify >>

Clause by clause analysis of Form 9C – Self Reconciliation Statement – basic
structure – PART ii Reconciliation OF TURNOVER DECLARED IN AUDITED FINANCIAL
STATEMENTS WITH TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9)
Sr No Particulars Rows
5 Reconciliation of Gross Turnover A to R

AT-1
6 Reasons for un-reconciled difference in Annual Gross Turnover A to C – Only Text

7 Reconciliation of Taxable Turnover A to G
AT-2
8 Reasons for un-reconciled difference in Taxable Turnover A to C – Only Text

Reconciliation OF TURNOVER DECLARED IN AUDITED FINANCIAL STATEMENTS WITH
TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) – Additions /increases in
TURNOVER
• B. Unbilled revenue at the beginning of Financial Year (+)

• Clause 5B – Unbilled revenue taken into accounts in the last FY and carried forward
in the current FY against which invoice is issued in the current FY on which GST is
payable then same shall be added - look for Unbilled revenue information in
reported in last FY of AFS.
• C. Unadjusted advances at the end of Financial Year ( Notification No
40/2017 of goods –Turnover upto 1.50 crores & Notification No 66/2017
dated 15/11/17 whereby no GST payable on advances on supply of Goods
as per section 12 ( domestic supplies only) (+)
• Clause 5C – unadjusted advances at the end of the FY on which GST has been paid FY
but has not been taken into account for calculation of turnover in the Financial
statements shall be added to the turnover as shown in clause 5A – look for
information on Advances from Clients in the AFS as well as verify the same in Service
Tax Returns of RTP.
TURNOVER
• D. Deemed Supply under Schedule I (Section 7(3) – Permanent transfer of

Business Assets, Related Party ( Employees)/Distinct persons (Branches ) supplies,
Principal and Agent Supplies & Import of Services – Related Parties/Distinct
persons (+)
• Clause 5D- Aggregate value of deemed supplies not taken into Financial statements turnover
shall be added in Turnover reported in clause 5A.
• J. CN accounted for in Annual Financial statements but are not permissible under
GST. (+)
• Clause 5J – Aggregate value of Credit Notes which have been accounted for in the audited
Financial statements but were not admissible under section 34 shall be reduced ( which
means audited financial turnover would increase to that extent ) from the turnover reported
in Clause 5A.
• Section 2(37) r.w.s s 34(1) provides CN can issued only in respect of (1) Taxable value exceeds
or (2) Tax payable exceeds or (3) Goods returned by recipient and/or (4) supply found to be
deficient for other reasons it won’t be admissible to reduce OTL.

TURNOVER
• F. Trade Discounts accounted for in the annual audited financial statements

but are not permissible under GST as per section 15(3) of valuation rules
(+)
• Clause 5F – Trade Discounts which are taken into effect for arriving at the Financial
statements turnover but on such trade discounts also GST was leviable ( as the same
is not permitted to be reduced from the price for the purpose of calculating GST ) is
required to be added back.
• Section 15(3) stipulates that value of supply shall not include any discount which is
given:
• (a) BEFORE OR AT the time of supply if such discount has been duly recorded in the invoice
issued in respect of such supply; and
• (b) After the supply has been effected if:-
• i. such discount is established in terms of an agreement entered into at or before the time of supply
and specifically linked to relevant invoices and
• Ii. Input tax credit as is attributable to the discount on the basis of document issued by the supplier
has been reversed by the recipient of the supply.

TURNOVER
5 Reconciliation of Gross Turnover
Turnover (including exports) as per audited financial statements for
the State / UT (For multi-GSTIN units under
A same PAN the turnover shall be derived from the audited Annual
Financial Statement)
B Unbilled revenue at the beginning of Financial Year (+)
C Unadjusted advances at the end of the Financial Year (+)
D Deemed Supply under Schedule I (+)
J CN accounted for in Annual Financial statements but are not (+)
permissible under GST.
F Trade Discounts accounted for in the audited Annual (+)
Financial Statement but are not permissible under GST
TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) – DEDUCTIONS /Decreases in
TURNOVER
• G. Turnover from April 17 to June 2017 (-)

• Do we report non GST Turnover in 5G or 5O ???
• H. Unbilled revenue at the end of the Financial Year (-)
• Clause 5H – Unbilled revenue taken into accounts at the end of current FY
and carried forward in the next FY then same shall be reduced - look for
Unbilled revenue information in reported in current FY of AFS.
• I. Unadjusted advances at the beginning of Financial Year (-)
• Clause 5I – unadjusted advances at the beginning of the FY on which GST has
been paid during last FY and not during the current FY but as revenue has
been booked in Current FY , hence it shall be reduced from the turnover as
shown in clause 5A – look for information on Advances from Clients in the last
AFS as well as verify the same in Service Tax Returns of RTP.
Reconciliation OF TURNOVER DECLARED IN AUDITED FINANCIAL STATEMENTS
WITH TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) – DEDUCTIONS
/Decreases in TURNOVER
• E. CN issued after the end of Financial Year but reflected in Annual Return.
(-)
• Clause 5E – Aggregate value of Credit Notes which are issued after 31st March 2022
for any supply accounted in FY 21-22 but such credit notes were reflected in the
Annual return GSTR 9 shall be added in the Turnover as per clause 5A. – Refer to
Annual Returns prepared by RTP as well as GSTR 1 filed for FY 21-22.
• Section 2(37) r.w.s s 34(1) provides CN can issued only in respect of (1) Taxable value
exceeds or (2) Tax payable exceeds or (3) Goods returned by recipient and/or (4)
supply found to be deficient for other reasons it won’t be admissible to reduce OTL.
• K. Adjustments on account of supply of goods by SEZ units to DTA Units (-)
• Clause 5K - because DTA units must have filed BoE for self consumption thus needs
to be reduced from 5A.
• L. Turnover for the period under composition scheme (-)
WITH TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) – DEDUCTIONS
/Decreases in TURNOVER
G
Turnover from April 2017 to June 2017 (-)
H
Unbilled revenue at the end of Financial Year (-)
I
Unadjusted Advances at the beginning of the Financial
Year (-)
E
CN issued after the end of Financial Year but reflected in Annual (-)
Return
K
Adjustments on account of supply of goods by SEZ
units to DTA Units (-)
L
Turnover for the period under composition scheme (-)

WITH TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) –
ADDITIONS/INCREASES/ DEDUCTIONS /Decreases in TURNOVER
• M. Adjustments in Turnover under section 15 & Rules thereunder –

valuation rules (+/-)
• Where the taxable value and invoice value differ due to valuation
principles under GST, such difference between the turnover reported in
GSTR 9 and turnover reported in the AFS shall be added/reduced from
the clause 5A Turnover.
• N. Adjustments in Turnover due to Foreign Exchange Fluctuations (
+/- )
• O. Adjustments in turnover due to reasons not listed above (+/-)
• Transaction pertaining to Branch Transfers don’t appear in AFS as they
get squared off while drawing up PAN India AFS……………..

• O. Adjustments in turnover due to reasons not listed above (+/-)

• Transaction pertaining to Branch Transfers don’t appear in AFS as they
get squared off while drawing up PAN India AFS……………..examples
• Recoveries due to staff employment contracts, Out of Pocket expenses

considered in the value of supply , stocks issued to discharge CSR
obligations , GST payouts on sale of CG , Business promotion
reimbursements which is considered as supply , Profit/Loss on sale of
CG , Incentives , Rebates received considered as supply , Income
recognized in P & L in special situations, Excluded discounts as per
section 15 etc.
M Adjustments in turnover under section 15 and (+/-)

rules
thereunder
N Adjustments in turnover due to foreign exchange (+/-)

fluctuations
O Adjustments in turnover due to (+/-) Clubbed

reporting
reasons not listed above permitted

Clause by clause analysis – gstr 9c –
Reconciliation OF TURNOVER.
Clause /Rows Descriptions Amount in INR
5A Turnover (including exports ) as per audited Financial statements Manual

for the state/UT ( for multi GSTN units under same PAN the
turnover shall be derived from the audited annual financial
statement)
5P Annual Turnover after adjustments made in clause 5B to 5O Auto
5Q Turnover as declared in Annual Return (GSTR 9 ) Manual
5R Un-reconciled Turnover ( Q- P ) AT 1
6 Reasons ……………….A to C Text only

Illustrative Reasons for unreconciled Turnover as per Row 5R
Accounting Standards Disclosures Goods sent on Approval Basis
Export of Goods without satisfying the conditions of

Any other reasons
Zero rated supply

Reconciliation OF TURNOVER DECLARED IN AUDITED
FINANCIAL STATEMENTS WITH TURNOVER DECLARED IN
ANNUAL RETURN (GSTR -9) – HOW TO CHECK AND ARRIVE?
What do we check ? How do we interpret
Why do we check?
such checks?
• GSTR 1 V. Books • Shortlist the errors or • Comparison of all
• GSTR 3B V. GSTR 1 deviations Tables
• GSTR 3B V. GSTR 2A • Prepare the • Conclude which
• GSTR 3B V. GSTR 2B reconciliations figures/data are
• If exercise is done accurate
• GSTR 2A V. Books
early then economic • Draw up the
• Re-cast, Reclassify and
outflow on account of reconciliations.
reverify the data and
ensuing interest levy
re-reconcile again
can be mitigated

WITH TURNOVER DECLARED IN ANNUAL RETURN (GSTR -9) – ILLUSTRATIVE
Mismatch REASONS / DEVIATIONS
Outward Supplies Inward Supplies

• Outward Invoices not recorded – OTL • Inward Invoices not recorded – OTL
will go up will go down
• Non recording of CN/DN • Non recording of CN/DN
• Duplication of Invoices , DN & CN • Duplication of Invoices , DN & CN
• Non Reporting of Exempt, Nil Rated & • Non Reporting of Exempt, Nil Rated &
Non GST Supplies Non GST Supplies
• Taxable supply considered as exempt • Taxable supply considered as exempt
supply and vice versa supply and vice versa
• Export Turnover being Zero Rated • Incorrect upload of Invoices by the
having no impact on OTL not reported Vendors ( including Non GST Invoices )
in the returns.

• Incorrect reporting of Exempt supplies under Zero Rated
• Incorrect reporting of Exempt supplies under supplies
Zero Rated supplies
• Non-compliance – 5(3) 5(4) 9(3) & 9(4)
• Non compliance – 5(3) 5(4) 9(3) & 9(4)
• Non-Reporting of Non GST Outward Supplies
• Non Reporting of Non GST Outward Supplies
• Incorrect /wrong Reporting of Non GST Outward Supplies
• Incorrect /wrong Reporting of Non GST
Outward Supplies • RCM accounting entries /closing entries not passed.
• RCM accounting entries /closing entries not • Typo Errors while filing GSTR 3B
passed.
• Incorrect Discount treatments
• Typo Errors while filing GSTR 3B
• Reversals under Rule 37 -16(2) Rule 42 & Rule 43 not done.
• Incorrect Discount treatments
• Re availment of ITC under 16(2)


• Typical errors in invoices • Typical errors in invoices
• GSTIN Number • GSTIN Number
• Invoice No • Invoice No
• Invoice Date • Invoice Date
• Invoice value – Gross/Net • Invoice value – Gross/Net
• Rate • Rate
• Taxable Value • Taxable Value
• IGST/CGST/SGST/UTGST/Cess
• IGST/CGST/SGST/UTGST/Cess
• Place of Supply
• Place of Supply

Clause by clause analysis – gstr 9c –
Reconciliation OF TURNOVER.
7 Reconciliation of Taxable Turnover Amount in INR
A Annual Turnover after adjustments ( from 5P above ) Auto
B Value of Exempted, NIL Rated , Non GST Supplies, No Supply
Turnover
C Zero rated Supplies without payment of Tax
D Supplies on which tax is to be paid by the recipient on reverse
charge basis
E Taxable Turnover as per adjustments (A-B-C-D) Auto
F Taxable Turnover as per liability declared in Annual Return (GSTR
9)
G Unreconciled Taxable Turnover ( E- F ) AT2
8 Reasons for unreconciled Taxable Turnover ……….A to C Text

Clause by clause analysis of Form 9C – Self Reconciliation Statement– basic
structure – PART iiI Reconciliation OF TAX PAID
9 Reconciliation of rate wise liability & amount payable thereon A to R

PT-1
10 Reasons for un-reconciled payment of amount A to C – Only Text
11 Additional amount payable but not paid ( due to reasons specified under A to G
Tables 6, 8 & 10 above ) AT-2

Reasons for un-reconciled payment of amount
GSTR 1=GSTR 3B but mismatch GSTR 1=AFS & GSTR 3B but tax
GSTR 3B deviations (+/-)
with AFS levy don’t match
• 3B=R1 • Taxable value of 3B = Value

• GSTR 1 matches with AFS of GSTR 1
w.r. to tax payable ( value ) • But mismatches with • Tax payable as self assessed
• GSTR 3B shows differently AFS in GSTR 3B is different from
from the books of accounts • Captured in Table 10- reported in GSTR 1
• Reported in Part V – reasons for • Captured in Table 10-
Auditors recommendation reasons for unreconciled
unreconciled
of additional tax liabilities payment
payment/s

Pt. III- 9- Reconciliation of rate wisE liability and AMOUNT PAYABLE THEREON
10 - A, B,C – Reasons for un-reconciled payment of amount – (Text)

Pt. III- 11- Additional amount payable but not paid due to
reasons in 6,8,10 above
Clause by clause analysis of Form 9C – GST Audit report – basic structure – PART iV
Reconciliation OF INPUT TAX CREDIT
12 Reconciliation of Net Input Tax credit ( ITC ) A to T
ITC -01
13 Reasons for un-reconciled Difference in ITC A to C – Only Text
14 Reconciliation of ITC declared in Annual Return GSTR 9 with ITC availed in A to T

expenses as per Audited Financial Statements as per books of accounts ITC -02
15 Reasons for un-reconciled Difference in ITC A to C – Only Text
16 Tax Payable on unreconciled difference in ITC ( due to reasons specified in

13 & 15 above )

Clause by clause analysis of Form 9C – GST Audit report – basic structure – PART
iV Reconciliation OF INPUT TAX CREDIT
12 Reconciliation of Net Input Tax credit ( ITC )
A ITC availed as per Audited Financial Statements for the state/UT ( for Multi GSTN
units under same PAN this should be derived from books of accounts) – information
reported under clause 27a of Tax Audit Report if reported and compiled
B ITC booked in earlier financial years claimed in current Financial Year.
C ITC booked in current financial years to be claimed in subsequent Financial Year.
D ITC availed as per audited Financial statements or books of accounts -) – information Auto
reported under clause 27a of Tax Audit Report if reported and compiled.
E ITC claimed in Annual Return ( GSTR 9 )
F Unreconciled ITC ( D-E )

13 Reasons for unreconciled ITC ………………A to C…………… Text

Pt. IV- 14- Reconciliation of Eligible ITC
Pt. IV- 14- Reconciliation of Eligible ITC
15 Reasons for un reconciled difference in ITC -

A Reason 1 text
B Reason 2 text
C Reason 3 text
Tax payable on un reconciled difference
Any amount which is payable due to reasons specified in table 13 and 15 above shall be
declared here.
HELP HOME PREVIOUS Sheet
Goods and Services Tax - GSTR 9C Offline tool
Pt. V. Additional Liability due to non-reconciliation
Please Note : Fields marked with * (red asterisk) are mandatory fields and need to be filled up
To be paid through Cash (₹)

S.No Description Value (₹)
Central Tax State Tax / Union territory Tax Integrated Tax Cess
A 5%
B 12%
C 18%
D 28%
E 3%
F 0.25%
G 0.10%
G1 Others%
H Input tax credit
I Interest
J Late Fee
K Penalty
Any other amount paid for
L supplies not included in annual
return (GSTR9)
Erroneous refund to be paid
M
back)
Outstanding demands to be
N
settled
O Other

Comparison between GSTR 9 & GSTR 9C
GSTR 9 GSTR 9C
• 6 Tables – Turnover , Taxes & ITC • 5 Tables – Turnover , Taxes , ITC &
• Option to pay tax, interest , penalties recommendations
• Recommendation to pay tax, interest ,
etc. through DRC 03 in cash only
penalties etc. & Pay through DRC 03 in
• Reporting of actual information for FY cash only
2122 + Circular 26 effects reported in • Reporting of reconciliations &
Apr – Nov 22 Comparisons and Reasons for
• To be filed by RTP only deviations
• To be filed on or before 31.12.2022 • To be filed by RTP only
• To be filed on or before 31.12.2012

Convergence between GSTR 9 & GSTR 9C
Turnover Taxes ITC

T
U GSTR 9
R GSTR 9 GSTR 9C
N
O
V Table 5N, 10 & 11- Non Taxable = Table 5Q Table 5P
E
R
Table 4N- Taxable = Table 7F Table 7E
T
A Table 9,10,11 = Table 9Q Table 9P
X
Table 7J = Table 12E Table 12D

I
T
C Table 7J = Table 14S Table 14R
Comparisons if they match - No problem. If not, reasons to be given for such variations in rows only in text
Turnover
GSTR 9C GSTR 9
• Reconciliation of Gross • Turnover as declared in Annual

Turnover = Annual Turnover Returns GSTR 9 reported in 5Q
after adjustments as above 5P = Table 5N, 10 & 11- Non
Taxable
If not matching, deviations need to be reported.

Tax Payable
GSTR 9C GSTR 9
• Taxable turnover as per • Taxable turnover as per liability

adjustments as per Table 7E declared in Annual Return
(GSTR9)=Table 7F = Table
4N+Table 10- Table 11

Tax paid
GSTR 9C GSTR 9
• Total amount to be paid as per • Total amount paid as declared

tables above (A to O)* as per in Annual Return Table 9Q of
Table 9P GSTR 9C= Table 9+Table 10-
Table 11 of GSTR 9

Input Tax Credit
GSTR 9C GSTR 9
• ITC availed as per Audited FS or • ITC claimed in Annual Returns

BOA as per Table 12D GSTR 9 in Table 12E of GSTR
9C= 7J of GSTR 9

Input Tax Credit
GSTR 9C GSTR 9
• ITC availed as per Audited FS or • ITC claimed in Annual Return (

BOA as per Table 14R GSTR 9) in Table 14S = Table 7J
of GSTR 9

Summary
GSTR – 9C
Tax Paid -
Turnover- Input Tax
CASH AND
Credit – GSTR
GSTR 1 CREDIT
3B /2A /2B
LEDGER
Document requirements
GSTR 9 and 9C 3B Vs R1 R1 Vs BOA

FY 2021
GSTR 2A FY 2122 3B ITC Vs. GSTR 2A GSTR 2A Vs. BOA

Table 8A GSTR 2A Vs. GSTR 2B GSTR 2B Vs. BOA

Electronic Cash Outward Deviation

Ledger Electronic Credit
Ledger Reconciliations
(TDS Returns ) with Reasons
Tax Paid Workings and

ITC Reconciliations
Reconciliations Ancillary laws
with Reasons
with Reasons reconciliations

Financial
Statements Auditors Report Cash Flow
ROC Annual
ITR TAR
Returns

Conclusion
• Please ensure that all workings papers in the form of documentation are kept
on record so that in future they are available to substantiate your basis of
authenticating the filing of Self Reconciliation Statement.
• Please understand that Sovereign has all data available at their disposal using
the techniques of Data Mining, Artificial Intelligence, Virtual and Mixed
Technological data base to verify and match the data.
• All RTP/Advisors are advised to explain, substantiate and share their internal
documents in future. Ensure that you have everything maintained in physical
as well as digital form to avoid or mitigate any probable litigation issues.
• Withdrawals/amendment of Self Reconciliation Statement filed are not
presently allowed or permitted as controlled by the GSTN Platform.

SURROUND YOURSELF WITH PEOPLE WHO TALK ABOUT VISION AND IDEAS NOT PEOPLE
Thank You for the Patient Hearing

Any suggestions to improve are welcomed with folded hands
CA Nitin Bhuta, Mumbai
Mobile Number 9820295319
E-mail id: nitin.bhuta@gmail.com
Objective: Circulated only for educational Purpose.


Final GST Annual Return - 9 + 9C NB 101222 FY 2122

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Annual Return in Form GSTR 9 & Self

Reconciliation Statement in Form GSTR

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7 Changes in Self Reconciliation Statement – Form GSTR 9C.

11 Basic Document Requirements

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commerce or manufacture or any • (a) any trade, commerce, manufacture, profession,

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with Rule 56 of CGST Rules 2017)

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Activities to be treated as supply even if made without consideration

Examples- Permanent transfer or disposal of business, supplies between

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Activities to be treated as supply of goods or supply of services

Examples- Goods -Transfer of title in goods under an agreement where

Examples - Services: Transfer of right or undivided share in goods without

Examples- Services by employee to employer in the course/ relation to

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Intra State Interstate/Cross Border

Single Supply Composite Supply Mixed Supply

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Movement, Monitoring and Documentation Milestones, Agreements and Documentations

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Initially GST payable on all advances

Then changes made for the RTP having a

Exempted from the payment of GST for all

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Books of Accounts Financial Statements

Statutory Compliances Scope

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Tax Intra/Inter State

HSN SAC Intra ( C +S ) Inter ( I )

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Output and Inward Reconciliations

Final Financial statements Classification of Goods

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Distance determination Restricting One Invoice One E way

Validity of E way can Blocking/

CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail: nitin.bhuta@gmail.com

CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail: nitin.bhuta@gmail.com

Export Exhibition or Fairs

Job work Own use

Audit Reports TAR

GSTR 1 verification Stock Records

GSTR 3B verifications CARO & TAR reporting

Electronic Cash and Credit Ledger R1 and 3B Stock

Audit Reports Invoice date TAR

CA Nitin Bhuta Mumbai Mobile No. 9820295319 E-mail: nitin.bhuta@gmail.com

Import Exhibition or Fairs

Job work Own use

SKD/CKD Purchase Returns

Audit Reports TAR

GSTR 2A /2B verification Stock Records

GSTR 3B verifications CARO & TAR reporting