BGM On GST Audit & Annual Return by CIRC of ICAI Edition July 2019

Central India Regional Council
The Institute of Chartered Accountants of India

(Set up under Act of Parliament)
Background Materialon
Goods & Service Taxes (GST)
Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 1

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DISCLAIMER The views expressed in this Background Material on Annual Return and GST Audit is
being prepared to provide the basic knowledge of Annual Return and GST Audit to our members.
Though the same is being prepared by the experts of the field and we have taken utmost care
regarding authenticity of information, provisions and guidelines mentioned here but still we want to
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to enhance the knowledge & skill of our members.
Central India Regional Council of The Institute of Chartered Accountants of India may not
necessarily subscribe to the views expressed by the author(s) The information cited in this
Background Material on Annual Return and GST Audithas been drawn primarily from the
http://www.cbic.gov.in/ and other sources. Readers are requested to note Sl. Nos / Table nos etc.,
wherever mentioned refer to the appropriate part / table of the relevant Forms. Names etc., of any
person or entity stated in this book are only for a proper understanding of the discussion and not
for anything else. Assumptions stated are to be understood in the context of the discussion and
cannot be applied to a real time situation, mutatis mutandis. While every effort has been made in
this Book to avoid any kind of errors or omissions. It is likely that errors may have crept in. Any
mistake, error or discrepancy noted by the reader should be brought to the notice Central India
Regional Council of the Institute of Chartered Accountants of India, Kanpur if these are found
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suggested that if the context of the Annual Return and GST Audit creates any doubt in the mind of
the reader, s/he should cross-check all the facts, laws and contents of the publication with original
Government / GST Councilpublications or notifications& circulars.
First Edition : July, 2019

Committee/Department : Editorial Board
E-mail : circ@icai.in
Website : www.circ-icai.org
Published by : Central India Regional Council of
Institute of Chartered Accountants of India,
ICAI Bhawan, Plot No.9 ,Block A-1,Lakhanpur, Kanpur - 208024

Foreword
Goods & Services Tax (GST) was introduced in India on 1st July, 2017.
Introduction of GST has been memorable to our CA Fraternity due to
date of Launch i.e. CA Day. GST was introduced with intent of “One
Nation One Tax” which has replaced multilayred and complex indirect
tax structure within country and made Indirect Tax simplified by removing
cascading effect of tax. GST is the biggest reform in the history of Indirect
Taxation system in India which has made India one unified common market.
It is a single tax on the supply of goods and services, right from the
manufacturer to the consumer. GST integrated the country into a
common market by removing barriers across states and enabling smooth
flow of goods from one state to the other. It subsumed various indirect taxes
levied by the centre and the states to bring in a pan-India uniform indirect
taxation system.
Indirect Tax regime has forced the professionals along with every single individual to be in a learning
mode continuosly. GST Council is coming up with certain circulars and notifications from time to
time with intent to address the grivencess of tax payers and simultaneously by plugging the lanuca
or loop holes in GST Law. However we being the partner in nation's building and the trust shown
by the government and keeping in view the expectations of the society from our profession, we
need to be well versed of the subject matter and represent ourself as best experts in field of
Indirect Taxation. It is mandated that we have a greater responsibility for the same and to
stand firm on the expectation of our fellow citizens. We always proudly say our role as “Partner
in Nation Building” and now as “Partner in GST Knowledge Dissemination”.
We at CIRC is proactively & continuously working towards furtherance of profession and

undertaking several new initiatives to assist the members in discharging their professional
duties in the best possible manner. Recently CIRC has published Background Material on Bank
Audit and this month we are publishing on GST. With the aim of updating the working knowledge of
our members, CIRC has come up with this publication in the form of Background Material on
Annual Return and GST Audit which explains Annual Return and GST Audit with comprehensive
clause by clause analysis of the GST Acts, rules, recent notifications, circulars or orders issued
by the Government from time to time & try to bridge the gap between Acounting termonologies
and Law in a very eloquent and lucid language. I am confident enough that this publication
would be of immense use for our Members, especially the young members, in developing the
working knowledge of Annual Return and GST Audit and understanding various practical aspects
of Annual Return & GST Audit and will work as effective tool for them.
I am thankful to all my seniors in Central Council from CIRC CA Anuj Goyal Ji, CA Kemisa Soni
Ji, CA Manu Agarwal Ji, CA Prakash Sharma Ji, CA Pramod Boob Ji and CA Satish Gupta Ji for
always motivating us and for their continuous support in working of CIRC. I am also thankful
to all my regional council colleagues for their continuous and untiring efforts in bringing out this
Background Material.
I really appreciate the efforts being put in by CA Sachin Kumar Jain, RCM of CIRC and all
the members of the editorial team namely CA Shashank Gupta Ji, CA Arjit Agarwal Ji, CA
Jatin Harjai Ji, CA Yash Daddha Ji, CA Raghav Dangayach Ji for undertaking this tedious
task and bringing out this material in such a short span of time and appreciate their
commitment towards profession.
CA Mukesh Bansal
Chairman CIRC

Preface
Respected Professional Colleagues,
It is a matter of pleasure and opportunity to serve for the professionas Co-

Editor of this Background material on Annual Returns and GST Audit. It is
indeed a fact that there are historic and rapid changes in Indian Economy.
The Government of India has introduced the system of Goods and Services
Tax(GST) Act. It is no doubt an important step in the field of Indirect Taxes.
The system has been introduced with a view to benefit, the economy by
reduction in overall burden on Goods and Services and to make it competitive
in domestic as well as international markets. The one tax system in place of
various taxes also reduce the compliance burden.
The Government of India has implemented "Free Accounting and Billing Software" to small Tax
payers wherein GSTN as Nodal Office and we are happy to inform that ICAI also helped in
process.
The basic motto behind this Background Material is to enhance skill and knowledge of our
Members and to provide in hand, a ready information on the important related matter to GST
Annual Return and GST Audit. We have tried to keep the language simple. This will be helpful in
conducting the audit and filing Annual Return. We have also tried to explain the various
Technical Terms in GST Act which will be very useful for the esteem Readers of the Manual.
At this juncture, I give a vote of thanks to our worthy and dyanamic CA Mukesh Bansal
Ji, Chairman of CIRC of ICAI to show his confidence in me and give me this prestigious
responsibility to be the Co- Editor of this Background Material.
At the last, I request to be true with the Profession, protect safeguard our common interest of
Professional Development which will enable us to achieve Success. We are committed to do
betterment of performance with Profession and Sincere towards Nation. I wish all very Happy CA
Day and Happy GST Day and we are pleased to release this BGM on CA Day which is also called
GST Day i.e 1st July
Jai Hind ..Jai ICAI !!
Sincerely Yours
CA SachinKumar Jain
Co-Editor of CIRC Background Material on Annual Returns & GST Audit
Regional Council Member CIRC

Editorial Team
CA Jatin Harjai is a Practicing Chartered Accountant based out of Jaipur. Through his more
than fifteen years of career, he has become recognized for his contribution and expertise as a
knowledgeable professional, advisor and consultant in the field of financial consultancy and tax
advisory. He is consultant in the world bank project for GST Implementation for Govt. of
Rajasthan.
He has been Special invitee member of National Indirect Tax Committee of ICAI for consecutive
three years. He is Co-opted member of national Indirect Tax Committee of PHD Chamber of
Commerce & Industries for year 2018-19. He is Chairman of Technical Research (Indirect Taxes)
Committee of Tax Consultants Association of Jaipur. Further he is an active member and founder
Convener of the Study Group framed by the ICAI for study, research and recommendations on
GST, whereby all group members are eminent chartered accountants practicing in the field of
Indirect Taxes. He was Co-opted member of Direct Tax Committee of ICSI for the year 2018
CA Shashank Gupta is a practicing Chartered Accountant & is also a Lawyer by qualification.

He has pursued PG.D in tax laws under the aegis of Supreme Court of India where he was the
batch topper and was felicitated by the Law Minister of India in the presence of Hon’ble Chief
Justice of India and four other Supreme Court judges. He is presently a PH.D candidate on the
topic ‘Implementation of GST in India and VAT a cross country analysis’. He is a special invitee to
the IDT committee of ICAI. He is also a member of the Core Advisory Group of ICSI for GST.
Shashank is a prolific speaker and has addressed a range of seminars across the nation on
various issues under the gamut of indirect taxes. He is a regular speaker on the conventions and
seminars conducted by ICAI, ICSI and ICMAI.
He has also conducted sessions for various industry forums.He has several years of experience in
advising clients on a wide range of issues under indirect tax. He is an active litigator and has
argued several matters before adjudication authorities, Commissioner Appeals as well as CESTAT (Indirect tax tribunal)
and has also assisted several leading and multinational clients in dispute resolution, contract review and transaction
structuring.
Shashank carries a perfect blend of a dedicated academic background coupled with years of practical experience.
Presently he is a partner and head of indirect tax practice at Girish Ahuja & Associates. Earlier, Shashank has worked
with Deloitte, BMR Advisors and other leading consultancy organizations.
CA Arjit Agarwal is practicing Chartered Accountant & throughout First Class in Schooling
and Commerce Graduate with over 8 Years of post qualification experience in the areas of Direct
Taxation, Financial Operations, MIS Reporting, Budgeting etc in Multinational Companies.
He is regular contributing articles for CIRC of ICAI for last 7 years and sometimes for NIRC of
ICAI also on Taxation aspects. He has presented papers during his CA course at CA Students
National Conventions and post qualified Speaker at various National Forums of ICAI. He is
actively engaged for the profession and nominated as Co-Opted Member of different Committees
of CIRC ICAI in year 2017-18 , 2018-19 and currently Co-opted Member of Editorial Committee
of CIRC of ICAI for 2019-20. He has received Appreciation Awards at 13th Annual Function and
39th Regional Conference of CIRC of ICAI for his contribution towards profession. Currently he is
elected Managing Committee Member of Moradabad Branch of CIRC of ICAI and Editor in Chief
of Branch Monthly Members E Newsletter.
CA Yash Dadha is a practicing Chartered Accountant and is a fellow member of ICAI. He

has also qualified LLB (Academic). He is having working experience of over 10 years in the
fields of Indirect Taxes with concentration only on GST, Service Tax & Excise matters. He
is currently engaged in handling litigation along with advising clients, structuring
transactions and conducting Due Diligence in given fields of taxation. He was a Special
Invitee to the Indirect Tax Committee of ICAI for the term 2018-19. He is also on panel of CII
as GST, Service Tax & Excise Advisor for Industry Members. He has represented ICAI in
Regional Advisory Committee, Rajasthan under ageis of Chief Commissioner of Excise &
Customs, Jaipur.
CA Raghav Dangayach is a practicing Chartered Accountant and has an experience of Indirect

& Direct Taxation, Company Law Advisory & Auditing.
He specializes in all aspects of Value Added Tax (VAT)/ Central Sales Tax (CST), Central
Excise, Service Tax, Customs, Foreign Trade Policy (FTP), Special Economic Zone (SEZ), Export
Oriented Unit (EOU). Export-Import Laws and well acquainted with the concept and impact of
way forward Goods and Services Tax (GST). He has been a Co-opted Member of STUDENTS
COMMITTEE of CIRC of ICAI for the year 2018-19

Central India Regional
Council 2019-20
Chairman
CA. Mukesh Bansal
Vice Chairman
CA. Churchill Jain Background Material on Annual
Return & GST Audit
Secretary
CA. Abhisak Pandey Editor in Chief
CA. Mukesh Bansal
Treasurer
CA. Abhishek Sharma Co-Editor
CA. Sachin Kumar Jain
CICASA Chairman
Editorial Members
CA. Devendra Kumar Somani
CA. Jatin Harjai
CA. Shashank Gupta
Members
CA. Arjit Agarwal
CA. Atul Agarwal
CA. Yash Dadha
CA. Atul Mehrotra
CA. Raghav Dangayach
CA. Dinesh Kumar Jain
CA. Nilesh Gupta
CA. Sachin Kumar Jain
CA. Shashikant Chandraker
Ex – Officio Members
CA. Anuj Goyal
CA. Kemisha Soni
CA. Manu Agarwal
CA. Prakash Sharma
CA. Pramod KumarBoob
CA. Satish Kumar Gupta

Table of Contents
Chapter Chapters & Contents Page No.
No.
1. Introduction
a) Introductionon Annual Return & GST Audit
b) Relevant Provisions of GST Act(s) and Rules
7-10
c) What is the time limit to file Annual Return?
d) Consequences of failure to submit the annual return
e) Conclusion
2. Form GSTR 9 Annual Return
a) Check Points to be considered before filing Form GSTR-9 (Annual Return) 11-12
b) Important amendments having impact on Annual Return
3. Clause wise Analysis – Form GSTR-9 (Annual Return)
a) Part I – Basic Details
b) Part II - Details of Outward and inward supplies made during the financial
year
c) Part – III - Detailsof ITC for the Financial Fear
d) Part IV- Table 9 Details of tax paid as declared in returns filed during the 13-55
financial year
e) Part 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
f) Part VI - Other Information
4. Audit under GST: Certification &Scope of GST Audit
a) Introduction
b) Practices to be adopted for GST Audit
c) Certification 56-60
d) Auditors’ Note
e) Vigilant aspects of the Certificate
f) Scope of GST Audit
5. Form GSTR-9C (Reconciliation Statement)
a) Basics - GSTR 9C - Reconciliation Statement
b) Suspicious Issues arising on account of disjunct between Act and Rules 61-64
c) Accounts and Records
d) Consequence of failure to submit annual return and reconciliation statement
6. Clause wise Form Analysis – Form GSTR-9C (Reconciliation
Statement)
a) Part I – Basic Details
b) Part II - Reconciliation of Turnover declared in AuditedAnnual Financial
Statement with Turnover declared in AnnualReturn (GSTR 9) 65-95
c) Part III - Reconciliation of Taxes Paid
d) Part IV - Reconciliation of Input Tax Credit (ITC)
e) Part V - Auditor’s Recommendation on Additional Liability due to non-
reconciliation.

1. Introduction
It is first time that annual compliances (Annual Return and GST Audit) under GST are to be
made by tax payer and auditors. Hence, it is bound to happen that some issues will arise in
filling up and filing of the requisite forms. In cases covered by GST Audit, a certification
from auditor is also required to be filed, along with annual return and reconciliation
statement, which also requires auditor to comment on preparation of books of accounts,
records and other documents as per provisions of GST law. Sec. 35(1) read with Rule 56
prescribes accounts and documents which are to be maintained. Accordingly apart from
reconciliation statement it is necessary for auditor to check and verify sufficiency and
correctness of accounts and documents prepared and maintained by the registered tax payer.
However, this document is being compiled mainly to give ready reference for clauses of form
GSTR 9 & GSTR 9C.
2. Relevant Provisions of GST Act(s) and Rules

a. Section 35
(5) Every registered person whose turnover during a financial year exceeds the prescribed
limit shall get his accounts audited by a chartered accountant or a cost accountant and shall
submit a copy of the audited annual accounts, the reconciliation statement under sub-
section (2) of section 44 and such other documents in such form and manner as may be
prescribed.
b. Section 44
(1) Every registered person, other than 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 electronically in such form and
manner as may be prescribed on or before the thirty-first day of December following the end
of such financial year.
(2) Every registered person who is required to get his accounts audited in accordance with
the provisions of sub-section (5) of section 35 shall furnish, electronically, the annual return
under sub-section (1) along with a copy of the audited annual accounts and a
reconciliation statement, reconciling the value of supplies declared in the return furnished
for the financial year with the audited annual financial statement, and such other particulars
as may be prescribed.
c. Rule 80
80. Annual return.-
(1) Every registered person, other than an Input Service Distributor, a person paying tax
under section 51 or section 52, a casual taxable person and a nonresident taxable person,
shall furnish an annual return as specified under sub-section (1) of section 44 electronically
in FORM GSTR-9 through the common portal either directly or through a Facilitation
Centre notified by the Commissioner:
Provided that a person paying tax under section 10shall furnish the annual return in FORM
GSTR-9A.

(3) Every registered person whose aggregate turnover during a financial year exceeds two
crore rupees shall get his accounts audited as specified under sub-section (5) of section 35
and he shall furnish a copy of audited annual accounts and a reconciliation statement, duly
certified, in FORM GSTR-9C, electronically through the common portal either directly or
through a Facilitation Centre notified by the Commissioner.
From the above provisions, it is understood that the 2 broad areas inviting attention are:
• Annual Return
• Reconciliation Statement
3. What is the time limit to file Annual Return?

According to Section 44(1) of CGST Act, 2017,every registered person (except persons
excluded as above)have to file annual return on or before 31st December following the end of
financial year.
An explanation was inserted in this section vide Order No. 1/2018-Central Tax dated 11th
December, 2018 to provide that the annual return for the period from the 1st July, 2017 to
the 31st March, 2018 shall be furnished on or before the 31st March, 2019.”
The above provision has been amended again vide Order No.03/2018-Central Tax dated 31st
December 2018 and the due date has been extended to 30th June 2019 which further
extended till 31st August 2019.
4. Consequences of failure to submit the annual return

 Late Fee for delayed filing
Section 47(2) of the CGST Act provides for levy of a late fee of Rs. 100/- per day for delay in
furnishing annual return in Form GSTR 9, subject to a maximum amount of quarter percent
(0.25%) of the turnover in the State or Union Territory. Similar provisions for levy of late fee
exist under the State / Union Territory GST Act, 2017.
On a combined reading of Section 47(2) and Section 44 (1) of the CGST Act, 2017 and State
/ Union Territory GST Act, 2017 a late fee of Rs.200/- per day (Rs. 100 under CGST law
+Rs. 100/- under State / Union Territory GST law) could be levied which would be capped to
a maximum amount of 0.5% (0.25% under the CGST Law + 0.25% under the SGST /
UTGST Law) of turnover in the State or Union Territory.
 General Penalty for Contravention of Provisions
Any person, who contravenes any of the provisions of this Act or any rules made there under
for which no penalty is separately provided for in this Act, shall be liable to a penalty which
may extend to Rs. 25,000. An equal amount of penalty under the SGST/UTGST Act would
also be applicable. Hence a penalty of up to Rs.50,000/- could be levied.

 Notice to defaulters
Section 46 of the CGST Act provides where a registered person fails to furnish a return under
section 39 or section 44 or section 45, a notice shall be issued requiring him to furnish such
return within fifteen days in such form and manner as may be prescribed.
5. Conclusion
Hence understanding the importance of GST Annual Return being a mandatory compliance it
is pertinent to understand the elements of the Form.
Form GSTR-9 (Annual Return) and Form GSTR-9C (Reconciliation Statement)were notified
vide Notification No. 39/2018 – Central Tax dated 4th September, 2018 and Notification No.
49/2018 – Central Tax dated 13th September, 2018 respectively.
The above forms have been substituted with revised forms vide Notification No. 74/2018 –
Central Tax dated 31st December 2018 wherein few changes have made in the forms
already notified.
In this publication, efforts have been directed to carve out a Clause wise analysis and
explanation of the above revised Forms. Since Annual Return is a pre-requisite for
Reconciliation Statement, Annual Return is discussed first and then the Reconciliation
Statement.

FORM GSTR-9 - ANNUAL RETURN
1. Check Points to be considered before filing Form GSTR-9 (Annual Return)

a) It is mandatory to file all FORM GSTR-1 and FORM GSTR-3B for the Financial Year
before filing the annual return. The details for the period between July 2017 to March
2018 are to be provided in this return for Financial Year 2017-18.
b) The instructions of the revised form instruct that through the given form, additional
liability for the FY 2017-18 not declared in FORM GSTR-1 and FORM GSTR-3B may
be declared in this return.
c) Towards the end of the return, taxpayers shall be given an option to pay any additional
liability declared in this form, through FORM DRC-03. Taxpayers shall select ―
“Annual Return” in the drop down provided in FORM DRC-03. It may be noted that such
liability can be paid through electronic cash ledger only.
d) Form GSTR-9should be treated as a document consolidating the monthly summation of
figures punched in periodic GST Returns for a specific Financial Year only which are
duly rectified and tax, if any relating to the Financial Year is paid through GSTR-3B or
DRC-03, as the case may be.
2. Important amendments having impact on Annual Return

Removal of Difficulty Order No. 02/2018 dated 31st December, 2018
(Relevant for Input Tax Credit)

2. In sub-section (4) of section 16 of the said Act, the following proviso shall be inserted,
namely: -
“Provided that the registered person shall be entitled to take input tax credit after the due date
of furnishing of the return under section 39 for the month of September, 2018 till the due date
of furnishing of the return under the said section for the month of March, 2019 in respect of
any invoice or invoice relating to such debit note for supply of goods or services or both
made during the financial year 2017-18, the details of which have been uploaded by the
supplier under sub-section (1) of section 37 till the due date for furnishing the details under
sub-section (1) of said section for the month of March, 2019.”.
This has been discussed in depth later.
(Relevant for Outward Supplies, particularly GSTR-1)

3. In sub-section (3) of section 37 of the said Act, after the existing proviso, the following
proviso shall be inserted, namely: ––
“Provided further that the rectification of error or omission in respect of the details
furnished under sub-section (1) shall be allowed after furnishing of the return under
section 39 for the month of September, 2018 till the due date for furnishing the details
under subsection (1) for the month of March, 2019 or for the quarter January, 2019 to
March, 2019.”

Analysis:
It should be noted here that a similar proviso imposing time limit for rectification of error or
omission is also provided in Section 39 (i.e. monthly return) but ROD 2 has not added any
such proviso to extend the time limit there under. Hence tax on any outward supply
transaction pertaining to a FY (including FY 17-18) can be paid either up to GSTR-3B of
September of subsequent FY or through DRC-03 thereafter.
Now a careful reading and understanding of ROD 2 and Instructions to Form GSTR-9
discussed further indicate that information to be reported in Form GSTR-9 cannot be reported
in the absence of submission of the relevant details in Form GSTR-1 and Form GSTR-3B for
the financial year 2017-18, the same has been pointed out throughout the form through
instructions to source data on basis of GSTR-1 and GSTR-3B only.
Thus, it appears that one would not be permitted to report any additional liability in Form
GSTR-9 without reporting the same in subsequent GSTR-1 up to March 2019 as per ROD 2
discussed above and payment of such additional tax liability. Since filing of GSTR-1 and
GSTR 3B is a prerequisite, it implies that they must agree with each other by the end of the
last opportunity granted vide ROD 2 reproduced above. However, there may be situations
when they are not in agreement, viz.:
• Where outward supplies for the financial year 2017-18 are correctly reported in Form
GSTR 3B, but the omission or error was occurred in GSTR-1
In such case GSTR-1 (already filed) must be rectified before the due date for filing of
GSTR-1 for March 2019 so that Form GSTR 9 carries the correct turnover.
• Where outward supplies for the financial year 2017-18 reported by the supplier are
correctly uploaded in Form GSTR-1 during financial year 2018-19 (on availing the
benefit provided by Order 2) but correction not made in GSTR-3B
The additional tax liability unpaid must be paid through Form DRC 3 so that Form GSTR
9 would carry the correct information regarding outward supplies and taxes duly paid
(partly through GSTR 3B and rest through DRC 3).
Hence Removal of Difficulty Order No. 2 and the amendments in the Form have now enabled
reporting of rectified details in GSTR-9 so that correct figures are carried in GSTR-9 and
GSTR-9C for reconciliation.
Another view indicated and supported by Instruction No. 3 is that additional liability for the
FY 2017-18 not declared in FORM GSTR-1 and FORM GSTR-3B may be declared in this
return.
As per Press Release dated 04.06.2019 it is clarified as that payments made through FORM
DRC-03 for any supplies relating to period between July 2017 to March 2018 will not be
accounted for in FORM GSTR-9 but shall be reported during reconciliation in FORM GSTR-
9C.
(Clarification is sought from government in this regard.)

Clause wise Analysis – Form GSTR-9 (Annual Return)
1. Part I – Basic Details

This part requires the basic details of the registered person and the relevant Financial Year for
which Annual Return is filed. All the details in the given Part of the Form will be auto-
populated and Financial Year has to be opted from a drop-down available at the return
dashboard.
Although the form uses the term ‘Financial Year’, Instruction No. 2 to the Form provide that
the details for the period between July 2017 to March 2018 are to be provided in this return.
2. Part II - Details of Outward and inward supplies made during the financial year
The heading of this part has been substituted from “Details of Outward and inward supplies
declared during the financial year” to “Details of Outward and inward supplies made during
the financial year”.
Analysis:
Instruction 4 of the Form for Part II provide that all supplies for which tax payment has
been made through FORM GSTR-3B between July 2017 to March 2018 shall be declared
in this part.
The values in the given part will be auto-populated in the system drafted GSTR-9 on the basis
of GSTR-1 filed by the Registered Person and the same can be verified with the GSTR-1
summary available for the Financial Year on GSTR-9 Dashboard only.
The given part of the Form is divided in two Tables:
Table 4 (Turnover and Liability Table)

Details of advances, inward and outward supplies made during the financial year on
which tax is payable
a. Table 4A and 4B
Clause 4A: Supplies made to un-registered persons (B2C)

Clause 4B: Supplies made to registered persons (B2B)

Clause 4A Clause 4B
Instruction Aggregate value of supplies Aggregate value of supplies made to
made to consumers and registered persons (including supplies
unregistered personson which made to UINs) on which tax has been
tax has been paid paid
Inclusions • Supplies made through E- • Supplies made through E-
Commerce operators Commerce operators
• Net of credit notes or debit
notes
Reference Tables Table 5, Table 7, Table 9 and Table 4A and Table 4C
of GSTR-1 Table 10
Exclusion • Supplies on which tax is to be paid
by the recipient on reverse charge
basis
• Details of debit and credit notes (to
be mentioned separately)
b. Clause 4C
Zero rated supply (Export) on payment of tax (except supplies to SEZs)
Instruction: Aggregate value of exports(except supplies to SEZs) on which tax has been paid
Reference Table of GSTR-1:Table 6A of FORM GSTR-1
Remarks:
Table 6A of FORM GSTR-1 includes two types of export invoices:
1. Exports with payment of tax
2. Exports without payment of tax under Letter of Undertaking
Table 6A in summary of GSTR-1 (PDF) will only show the total amount of exports and
hence the amount of exports with payment of tax can only be verified through invoice level
summary of GSTR-1 available for download on GST portal in Json format.
c. Clause 4D
Supply to SEZs on payment of tax
Instruction: Aggregate value of supplies to SEZs on which tax has been paid
Reference Table of GSTR-1:Table 6B of FORM GSTR-1
Remarks:
Table 6B of FORM GSTR-1 includes two types of SEZ supplies:
1. SEZ supplies with payment of tax
2. SEZ supplies without payment of tax under Letter of Undertaking
Table 6B in summary of GSTR-1 (PDF) is available as part of total amount B2B invoices as
per Table 4A, 4B, 4C, 6B and 6C. Hence the amount of SEZ supplies with payment of tax

can only be verified through invoice level summary of GSTR-1 available for download on
GST portal in Json format.
d. Clause 4E
Deemed Exports
Instruction:
Aggregate value of supplies in the nature of deemed exports on which tax has been paid
Reference Table of GSTR-1:Table 6C of FORM GSTR-1
Remarks:
Table 6C is available as part of total amount of B2B invoices in Table 4A, 4B, 4C, 6B and
6Cin GSTR-1. Hence the amount of deemed exports can only be verified through invoice
level summary of GSTR-1 available for download on GST portal in Json format.
e. Clause 4F
Advances on which tax has been paid but invoice has not been issued (not covered
under (A) to (E) above)
Instruction: Details of all unadjusted advances i.e. advance has been received and tax has
been paid but invoice has not been issued in the current year.
Reference Table of GSTR-1:Table 11A of FORM GSTR-1
Remarks:
Only Table 11A will give the total amount of advances received in the relevant Financial
Year. The unadjusted advances should be calculated as follows:
Table Information
Table 11A Advances received
(-)Table 11B Advances adjusted
= Value for Clause 4F of FORM GSTR-9 Net unadjusted advances
The auto populated figures in Clause 4F of GSTR-9 are correctly reflected as per above
calculation.
f. Clause 4G
Inward supplies on which tax is to be paid on reverse charge basis
Instruction:
Aggregate value of all inward supplies (including advances and net of credit and debit notes)
on which tax is to be paid by the recipient (i.e.by the person filing the annual return) on
reverse charge basis.

Inclusions:
• Supplies received from registered persons, unregistered persons on which tax is levied on
reverse charge basis. Illustrative List of supplies leviable to tax under RCM when
received from following suppliers:
o Goods Transport Agencies
o Advocates
o Arbitral Tribunal
o Sponsorship Services
o Government or Local Authority
o Director (not an employee of company)
o Insurance Agent
o Recovery Agent
o Transportation of Vessel
o Transfer or permitting right to use copyright
o Cab Services by E-Commerce Operator
(Reference: Section 9(3) of CGST Act, 2017 and Sec. 5(3) of IGST Act, 2017)
• Inward supplies received from unregistered persons on which tax is levied under RCM
upto 12th October 2017. (Reference: Section 9(4) of CGST Act, 2017 and Sec. 5(4) of
IGST Act, 2017)
• Import of services.
Aggregate value of all above inward supplies should be taken including advances and net of
credit and debit notes.
Reference Table of GSTR-3B: Table 3.1(d) of FORM GSTR-3B
Analysis:
This detail will be auto-populated in the system drafted GSTR-9 on the basis of GSTR-3B
filed and the same can be verified with the GSTR-3B summary available for the Financial
Year on GSTR-9 Dashboard only.
Although the auto populated details in this clause will be on the basis of RCM liability on
inward supplies reported in GSTR-3B for July 2017 to March 2018 only, the instruction
provide for all inward supplies on which tax is to be paid and hence a call needs to be taken
to declare any additional liability under reverse charge either paid in subsequent GSTR-3B or
not paid till filing of Annual Return. If any such liability under reverse charge has been
identified, it can be declared in this clause only. Rectification of amount of inward supplies in
GST returns in the next financial year should be reported in table 10 or 11 accordingly.
g. Table 4 – Clause I and Clause J

Credit Notes and Debit Notes issued in respect of transactions specified in (B) to (E)
above (-)
Instruction:Aggregate value of credit notes/debit notes issued in respect of B to B supplies

(4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E).

Reference Table of GSTR-1: Table 9B
Analysis:
• The auto-populated values in this clause of GSTR-9 are net value of Debit notes and
Credit notes reported in Table 9B of GSTR-1 filed for the financial year.
• Credit Notes and Debit Notes issued during the financial year in respect of outward
supplies made during the financial year are required to be reported here.
• However, total amount of Table 9B cannot be borrowed for computation of the amount
under this clause because Table 9B may also include credit notes issued against supplies
wherein no tax was payable. Such credit notes would be reported under clause 5H and not
4I.
• Any commercial/accounting credit notes without GST should not be considered for the
calculation of taxable value and tax amount in GSTR-9.
h. Table 4 – Clause K and Clause L

Supplies / tax declared or reduced through Amendments
Instruction:
Details of amendments made to B to B supplies (4B), exports (4C), supplies to SEZs (4D)
and deemed exports (4E), credit notes (4I), debit notes (4J) and refund vouchers.
Reference Table of GSTR-1: Table 9A and 9C
Analysis:
In the auto-populated draft at portal, amendments are correctly considered at differential
amount increased/reduced through such amendments.
For example, an invoice of taxable value Rs. 100,000 and 18% tax thereon was reported Rs.
10,000 and applicable tax and an amendment was made later to declare correct values, then
the values in this clause will be correctly reflected as Rs. 90,000 and applicable tax.
i. Table 4 – Clause N
Supplies and advances on which tax is to be paid (H + M) above
The aggregate values computed in this Clause include Supplies and advances on which tax is
to be paid (net of Credit/Debit notes and amendments) made during the Financial Year.
Remarks:
The value in Clause 4N of FORM GSTR-9 (excluding Clause 4G)plus amendments reported
in Table 10 and 11 in Part V of GSTR-9 will be the final value of taxable turnover carried
forward to FORM GSTR-9C in Clause 7F for reconciliation with taxable turnover as per
books computed thereof.
Clause-wise Cross referencing of GSTR-9 and GSTR-1

(For Table 4 and Table 5)

GSTR-9
GSTR-1 4A 4B 4C 4D 4E 4F 4I 4J 4K/ 5 5 5 5D 5 5 5
4L A B C , H I J/
5E 5
, K
5F
Table 4A, 4B,4C,   
6B, 6C – B2B
Invoices
Table 5A, 5B – 
B2C (Large)
Invoices
Table 9B –  
Debit/Credit
Notes
(Registered)
Table 9B –   
Debit/Credit
Notes (Un -
registered)
Table 6A – 
Export Invoices
Table 7 – B2C 
(Others)
Table 8 – Nil
rated, exempted
and non GST
outward supplies
Table 11A(1), 
11A(2) - Tax
Liability
(Advances
Received)
11B(1), 11B(2) - 
Adjustment of
Advances
12 - HSN-wise
summary of
outward supplies
9A - Amended  
B2B Invoices
9A - Amended 
B2C (Large)
Invoices
9C - Amended  
Credit/Debit

Notes
(Registered)
9C - Amended  
Credit/Debit
Notes
(Unregistered)
9A - Amended 
Exports Invoices
10 - Amended 
B2C(Others)
11A - Amended 
Tax Liability
(Advance
Received)
11B -Amendment 
of Adjustment of
Advances
Notes to consider:
Source of GSTR-9 – GSTR-3B or GSTR-1?
3B 1
Instruction 4 of the Form for Heading of Table 4 of GSTR-9 is as under:
Part II provide that all supplies Details of advances, inward and outward supplies made during the
for which tax payment has financial year on which tax is payable.
been made through FORM
GSTR-3B between July 2017 to Clause wise instructions direct that relevant data for the clauses may
March 2018 shall be declared in be sourced from Tables of GSTR-1 and hence the auto populated
this part. figures are generated on the basis of GSTR-1 only.
Clause wise instructions for Also, Instruction to Clause 5N, i.e., the total of Table 4 and 5 provide
Part-II provide that ‘Aggregate that ‘Total turnover including the sum of all the supplies (with
value of supplies made to on additional supplies and amendments) on which tax is payable and tax
which tax has been paid shall is not payable shall be declared here.’
be declared here’.
Hence it is evident that the headings and instructions of the Form are contrary and hence a
call is needed to be taken on case to case basis
Issues:
1. Reporting of additional liability – A dichotomy between Instructions
Comparison of Instructions:

Can be declared Only tax paid transactions
Instruction No. 3 states Instruction No. 4 provide as under:
that additional liability
for the FY 2017-18 not Part II consists of the details of all outward supplies & advances received
declared in FORM during the financial year for which the annual return is filed. It may be
GSTR-1 and FORM noted that all the supplies for which payment has been made through
GSTR-3B may be FORM GSTR-3B between July 2017 to March 2018 shall be declared
declared in this return. in this part.
Further, Instruction 7 provides that Part V consists of particulars of

transactions for the previous financial year but paid in the FORM GSTR-
3B of April to September of current FY or date of filing of Annual
Return for previous financial year.
It is evident from a careful reading thatthe above instructions are contrary where on one side
Instruction No. 3 proposes that the liability for FY 2017-18 missed while reporting in GSTR-
1 and GSTR-3B can be reported in GSTR-9 whereas Instruction 4 and 7 restricts the details
in Part II and Part V to only such transactions for which tax has been paid through GSTR-3B
in respective periods.
In this regard, a recent clarification has been issued wherein it has been clarified that
irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a
supply in Pt. II or Pt. V is essentially driven by when was tax paid through FORM GSTR-3B
in respect of such supplies. If the tax on such supply was paid through FORM GSTR-3B
between July 2017 to March 2018 then such supply shall be declared in Pt. II and if the tax
was paid through FORM GSTR3B between April 2018 to March 2019 then such supply shall
be declared in Pt. V of FORM GSTR-9.
It has been clarified by GST council that“any additional outward supply which was not
declared by the registered person inFORM GSTR-1 and FORM GSTR-3B shall be
declared in Pt.II of the FORM GSTR-9. Such additional liability shall be computed in
Pt.IV and the gap between the “tax payable” and “Paid through cash” column of
FORM GSTR-9 shall be paidthrough FORM DRC-03”.
2. Red Alert on variation in auto-populated figures more than 20%
It has to be kept in mind that although the auto-populated values in Form GSTR-9 are
editable, where such values are modified by more/less than 20%, the same will be highlighted
in red for attention.

The authorities may also seek explanation such variance in system generated figures.
Clarified by council that it may be noted that auto-population is a functionality provided to

taxpayers for facilitation purposes, taxpayers shall report the data as per their books of
account or returns filed during the financial year
3. Disjunct between GSTR-1 and GSTR-3B – Impact on reporting in GSTR-9

In the prevalent return structure, there is a disjunct between GSTR-1 and GSTR-3B and tax is
paid as per transactions declared in GSTR-3B which may be at a variance from GSTR-1.
j. Table 5 (Turnover without liability)

Details of Outward supplies on which tax is not payable as declared in returns filed
during the financial year
The values in the clauses of this Table will be auto-populated on basis of GSTR-1 filed for
the Financial Year.
Clause 5A - Zero rated supply (Export) without payment of tax

Clause 5B - Supply to SEZs without payment of tax
5A 5B
Instruction Aggregate value of exports (except Aggregate value of supplies
supplies to SEZs) on which tax has not to SEZs on which tax has not
been paid shall be declared here. been paid shall be declared
here.
GSTR-1 Table 6A Table 6B
Reference Table
Remarks:
The auto-populated values for exports or SEZ supplies without payment of tax can be verified
from invoice level GSTR-1 summary only.
k. Clause 5C
Supplies on which tax is to be paid by recipient on reverse charge basis
Instruction:
Aggregate value of supplies made to registered persons on which tax is payable by the
recipient on reverse charge basis. Details of debit and credit notes are to be mentioned
separately. Table 4B of FORM GSTR-1 may be used for filling up these details.
Analysis:
Instruction 4 for Part II of the Form will not be relevant while reporting values in this clause
because no tax has been paid through GSTR-3B on such outward supplies where tax is
payable by recipient.

It is important to note that where the registered person is engaged only in making outward
supplies which are taxable under reverse charge mechanism, he would have not been able to
report these supplies in GSTR-3B since it is a taxable supply under GST but Column 3.1(a)
of GSTR-3B does not accept taxable value without tax liability in respective IGST, CGST
and SGST columns.
It has also been observed that taxpayers do not report their outward supplies on which tax is
payable under RCM in GSTR-1 or they only mention the taxable value and declare the same
in tax columns with 0% tax rates. This is not the correct approach to declare such transactions
in GSTR-1. Instructions to FORM GSTR-1 provide that Table 4 capturing information
relating to B to B supplies should be captured in Table 4B for supplies attracting reverse
charge, rate-wise;
If the registered person has not reported the details in GSTR-1, the auto-populated figures
would not be correct and in such case a call has to be taken to report the actual values of
outward supplies taxable under RCM as per financials in Clause 5C of GSTR-9.
l. Clause 5D, 5E and 5F

Exempted, Nil Rated and Non-GST supply
Instruction:
Aggregate value of exempted, Nil Rated and Non-GST supplies shall be declared here. Table
8 of FORM GSTR-1 may be used for filling up these details.
The value of no supply shall be declared under Non-GST supply (5F).
Analysis:
The term exempt supply has been defined under Section 2(47) of CGST Act, 2017 as under:
(47) “exempt supply” means supply of any goods or services or both which attracts nil rate
of tax or which may be wholly exempt from tax under section 11, or under section 6 of the
Integrated Goods and Services Tax Act, and includes non-taxable supply;
The term non-taxable supply is defined under Section 2(78) of CGST Act, 2017 as:
(78) “non-taxable supply” means a supply of goods or services or both which is not leviable
to tax under this Act or under the Integrated Goods and Services Tax Act.
Remarks:
1. As per the definition, nil rated supplies are exempt supplies only but to the contrary,
GSTR-9 provides two different clauses for exempted and nil rated supplies. Now it poses
a question as to which supplies should be reported as exempted and which ones as nil
rated.
In clause5D, the taxpayer is expected to furnish information in relation to supplies on

which goods and services wholly exempted from tax under Notification 2/2017- CT(Rate)
for goods and 12/2017-CT(Rate) for services during the financial year 2017-18.

In clause 5E, the taxpayer is expected to furnish information in relation to supplies on
which NIL rate of duty is chargeable as per section 9 read with Notification No. 1/2017-
CT (Rate) for goods and Notification No. 11/2017- CT (Rate) for services during the
financial year 2017-18.
2. Value of “No supply” is not required to be declared in any of the returns filed during the
Financial Year but it is required to be declared in Annual Return Part-II. It gives rise to an
ambiguity where such values should be fetched from, since it has not been declared in
returns filed.
The intention is to capture such details which are part of Schedule-III to Section 7 of the
CGST Act 2017 (i.e. Activities which are neither treated as supply of goods and nor treated
as supply of services). Since there was no column in period GST Returns to capture no
supply details, hence it has been specified here. Since no GST can be levied on “no supplies”
hence they are being reported here so that while reconciling the turnover with books of
accounts an unnecessary reconciliation item which shall have no tax impact shall not arise.
Instances of transactions which can be categorized as no supply on the basis of general

meaning of the words are illustrated as under:
• Services by employee to employer in course of employment

• Sale of Land or completed Building
• Transaction of Actionable Claim (other than lottery, betting and gambling)
• High Seas Sales before filing of BOE for Home Consumption
• Bonded Warehouse Sales before filing of BOE for Home Consumption
m. Clause 5H and 5I
Credit Notes issued in respect of transactions specified in A to F above (-)
Debit Notes issued in respect of transactions specified in A to F above (+)
Instruction:
Aggregate value of credit notes/debit notes issued in respect of supplies declared in 5A, 5B,
5C, 5D, 5E and 5F shall be declared here. Table 9B of FORM GSTR-1 may be used for
filling up these details.
Remarks:
Out of referred clauses, value of credit/debit notes in respect of following can only be
reported:
• Exports without payment of tax
• SEZ supplies without payment of Tax
• Supplies attracting tax on reverse charge basis
In relation of Clause D, E and F of Table 5, there is no specific field for Credit/Debit Notes.

n. Clause 5J and 5K
Supplies declared through Amendments (+)
Supplies reduced through Amendments (-)
Instruction:
Details of amendments made to exports (except supplies to SEZs) and supplies to SEZs on
which tax has not been paid shall be declared here. Table 9A and Table 9C of FORM GSTR-
1 may be used for filling up these details.
o. Clause 5N
Total Turnover (including advances) (4N + 5M - 4G above)
Instruction:
Total turnover including the sum of all the supplies (with additional supplies and
amendments) on which tax is payable and tax is not payable shall be declared here. This shall
also include amount of advances on which tax is paid but invoices have not been issued in the
current year. However, this shall not include the aggregate value of inward supplies on which
tax is paid by the recipient (i.e. by the person filing the annual return) on reverse charge basis.
Remarks:
The value computed in Clause 5N of FORM GSTR-9 above, along with amendments
declared in April to September of current Financial Year for the previous Financial Year as
declared in Table 10 and 11 of GSTR-9, will be carried forward to FORM GSTR-9C in
Clause 5Q as Turnover as declared in Annual Return (GSTR-9). Such aggregate value taken
from GSTR-9 will be reconciled with Annual turnover as per Financial Statements in GSTR-
9C and reasons of un-reconciled differences will have to be reported.
3. Part – III - Details of ITC for the Financial Year

A. Preliminary Discussion
i. Whether extension of time limit for claiming ITC vide Removal of Difficulty Order
No. 2/2018 has any nexus with the changes made in Form GSTR-9?
It has now, been clarified that Input tax credit on inward supplies pertaining to FY 2017-18
but availed during the period April 2018 to March 2019 shall be declared in Table 8C of
FORM GSTR-9.
Part III has been broadly divided into three tables: Table 6, 7 and 8.
Part – III - DETAILS OF ITC FOR THE FINANCIAL YEAR

I. TABLE-6 - DETAILS OF ITC AVAILED DURING THE FINANCIAL YEAR
This table shall contain the information relating to ITC claimed on all inward supplies
received from registered persons, unregistered persons (RCM), registered persons (RCM),
import of goods, import of services, ISD credit, ITC reclaimed , transitional credits during the
FY 2017-18 i.e. in the GSTR-3B and TRAN-1, filed for the tax periods July-March 2018.
Tables 6, 7 and 8 are now being discussed in detail one by one.
a. Table -6A - Total amount of input tax credit availed through FORM GSTR-3B
Instruction:
Analysis:
Table - 4A of GSTR-3B contains the information relating to ITC claimed on:
• import of goods,
• import of services,
• inward supplies liable to RCM u/s 9(3) and 9(4),
• inward supplies from ISD
• All other input tax credit.
Remark:
Since the data in this table is auto populated from the returns filed during the FY 2017-18,
hence the same cannot be edited.
b. Table -6B - Inward supplies (other than imports and inward supplies liable to reverse
charge but includes services received from SEZs)
Instruction:
Source: Table 4(A)(5) of Form GSTR-3B.

Analysis:
Details of all inward supplies other than those listed below and the ITC on which has been
claimed in Table 4(A)(5) of Form GSTR-3B to be declared here.

List of inward supplies not required to be reported in this table:
a) Inward supplies on which tax is payable under RCM
b) ITC claimed on import of goods
c) ITC claimed on import of services
d) ITC claimed on inward supplies from ISD
e) ITC which was availed, reversed and then reclaimed in the ITC ledger
Remarks:
a) The amount of ITC reclaimed (after availment and reversal) is required to be disclosed
separately in Table 6H. However, in form GSTR-3B, the said information (ITC reclaimed
after reversal) shall always be a part of ITC claimed in Table-4(A)(5) of Form GSTR-3B.
Hence, caution would be required in cases where the ITC has been reclaimed in GSTR-
3B to ensure that it doesn’t get reported in this table.
b) It is relevant to note if the Registered Person has disclosed gross total ITC [including
blocked ITC u/s 17(5)] in Table 4A of GSTR 3B and reduced the ineligible ITC in Table
4B (2) of GSTR 3B, the Registered Person should disclose the gross total ITC [including
ineligible ITC u/s 17(5)] in Table 6B of GSTR 9. The ineligible ITC u/s 17(5)will be
disclosed in Table 7E of GSTR 9. However, where the amount of blocked credit has been
declared only in Table 4(D) of the Form GSTR-3B and not included in Table 4(A), then
the same need not be reported here also.
c) The most complex information in Tables 6 is the bifurcation of the ITC availed into
inputs, input services and capital goods. The breakup of ITC into inputs, input services
and capital goods was originally required in GSTR-2. Therefore, the taxpayers were
originally required and expected to maintain such information for every ITC. Since Form
GSTR-2 has been suspended since inception (barring for July 2017), hence most of the
tax payers might have not maintained such information at the time of claiming ITC in
monthly returns. Therefore, collecting such information might prove to be a tedious task
for those taxpayers. Further, GST law requires to maintain the details of the inputs and
input services used in the manufacture of goods or provision of service along with a
register of input tax credit vide Section 35 when read with Rule 56.
So, this leads to an apprehension that the tax payer is required to maintain the details of
the ITC claimed into ITC on inputs, inputs services and capital goods.
d) In cases where the classification of ITC into Input, Input Services and Capital Goods is
not available in the records as discussed above, following basic approach may be adopted:
• Take Purchase Register, from the books of accounts and get the monthly figure of ITC. It
shall be ITC on inputs
• Take Fixed Assets Register, identify the addition to assets and ITC on such assets can be
tracked from there. In case Tax Audit under Income Tax is applicable, then invoice wise/
date wise additions in fixed assets can be taken from Form 3CD and ITC on capital goods
can be derived accordingly.
• From Total ITC, deduct ITC derived on inputs and capital goods as above.

• The balance ITC should be related to expense which is to be apportioned as Input/Input
Services.
c. Table -6C - Inward supplies received from unregistered persons liable to reverse charge
(other than B above) on which tax is paid & ITC availed
Instruction:
6C Aggregate value of input tax credit availed on all inward supplies received
from unregistered persons (other than import of services) on which tax is
payable on reverse charge basis shall be declared here. It may be noted that
the total ITC availed is to be classified as ITC on inputs, capital goods and
input services. Table 4(A)(3) of FORM GSTR-3B may be used forfilling
up these details.
Source: Table 4(A)(3) of FORM GSTR-3B

Analysis:
a) This table contains the aggregate value of input tax credit availed on all inward supplies
received from unregistered Person (other than import of services) on which tax is payable
on reverse charge basis. Tax paid on supplies received from unregistered person and on
which input tax credit has not been availed, will not be reported under this clause.
b) Only the aggregate value of GST paid under reverse charge u/s 9(3) and 9(4) on supplies
procured from unregistered persons shall be disclosed here.
c) Notification No. 38/2017 – CT(R) dated 13.10.2017 was issued by the Government to
provide exemption from payment of tax under reverse charge for supplies received from
unregistered Persons. Therefore, clause 6C of GSTR 9 will contain data relating to inward
supplies received from unregistered Persons liableto GST u/s 9(4) from 1stJuly 2017 to
12thOctober 2017 only. However, the data related to the inward supplies received from
unregistered Persons liable to GST u/s 9(3) shall be for the entire period to be reported.
d) GST paid on import of services should not be reported here. It is required to be reported
in Table 6F.
e) Inward supplied received from Registered Persons liable to reverse charge u/s 9(3) should
not be disclosed under this Table.
Remarks:
a) Data disclosed in Table 6C and 6D should not exceed the data disclosed in Table 4G of
GSTR 9.
b) Inward supplies received from unregistered persons on which GST is paid under section
9(3) but subsequently where such supplies are being reflected in Form GSTR-2A, then
the same is required to be reported in Table 6D instead of this table.
For example, where GST is paid on GTA services u/s 9(3) on the presumption that the
supplier is unregistered because the supplier did not raise the tax invoice at time of supply
and subsequently such transactions are being reflected in GSTR-2A, then the same is not
required to be reported here. It shall be reported in next table.

d. Table – 6D - Inward supplies received from registered persons liable to reverse charge
(other than B above) on which tax is paid and ITC availed
Instruction:
Source: Table 4(A)(3) of FORM GSTR-3B.

Analysis:
a) This clause requires reporting of the aggregate value of input tax credit availed on all
inward supplies (of input, input services and capital goods) as received from registered
persons on which tax is payable under reverse charge as per section 9(3) of CGST Act.
b) The list of goods liable to GST under reverse charge u/s 9(3) is notified in Notification
No. 4/2017-Central Tax (Rate), dated 28.06.2017. Further, in respect ofservices, the list
of services has been notified in Notification No. 13/2017- CT(R) dated 28.06.2017and
Notification No. 10/2017- IT(R) dated 28.06.2017.
c) GST paid on import of services should not be reported here. It is required to be reported
in Table 6F.
d) Inward supplied received from unregistered persons should notbe disclosed under this
Table.
Remarks:
a) Data disclosed in Table 6C and 6D should not exceed the data disclosed in Table 4G of
GSTR 9.
b) Data disclosed in Table 6C and 6D should also not exceed the data disclosed in Table –
4(A)(2) and 4(A)(3) of GSTR-3B filed for the period 2017-18.
c) Inward supplies received from registered persons on which GST is payable under section
9(3), then the eligibility of ITC on such supplies is subject to fulfilment of the invoice
details required in accordance with Rules 46 to 55A read with Rule 36(2).
d) Inward supplies received from unregistered persons on which GST in paid under section
9(3) but subsequently where such supplies are being reflected in Form GSTR-2A, then
the same is required to be reported in Table 6D instead of this table. Further the eligibility
of ITC on such supplies is subject to fulfilment of the invoice details required in
accordance with Rules 46 to 55A read with Rule 36(2).

e. Table – 6E- Imports of goods (Including supplies from SEZ)
Instruction:
6E Details of input tax credit availed on import of goods including supply of

goods received from SEZs shall be declared here. It may be noted that the
total ITC availed is to be classified as ITC on inputs and capital goods.
Table 4(A)(1) of FORM GSTR-3B may be used for filling up these details.

Analysis:
a) This table requires reporting of the aggregate value of input tax credit availed on all
imports (for inputs and capital goods) from outside India or SEZ units.
b) Such data can also be validated from the bill of entry or other similar document
prescribed under the Customs Act, Customs Tariff Act or rules made there under for the
assessment of Integrated tax on imports.
As per clarification issued, Table 8 has no row to fill in credit of IGST paid at the time of
import of goods but availed in the return of April 2018 to March 2019. Due to this, there are
apprehensions that credit which was availed between April 2018 to March 2019 but not
reported in the annual return may lapse. For this particular entry, taxpayers are advised to fill
the entire credit availed on import of goods from July 2017 to March 2019 in Table 6(E) of
FORM GSTR-9 itself.
f. Table – 6F- Import of services (excluding inward supply from SEZ)

Instruction:
6F Details of input tax credit availed on import of services (excluding inward

supplies from SEZs) shall be declared here. Table 4(A)(2) of FORM GSTR-3B

Analysis:
a) Aggregate value of input tax credit availed on all import of services received from outside
India needs to be reported here.
b) Data for this clause can also be corroborated with the details disclosed in the notes to
accounts in the Financial Statements.
c) ITC claimed on services received from SEZ unit need not be reported here.

g. Table – 6G- Input Tax received from ISD
Instruction:

Analysis:
In this Table, the Registered Person should report aggregate value of input tax credit availed
on all invoices raised by ISD. The Registered Person should be in possession of invoice
issued by ISD u/r 54(1) of CGST Rules. It is also relevant to note that the ineligible portion
of ITC distributed should not be availed as ITC.
h. Table – 6H- Amount of ITC reclaimed (other than B above) under the provision of the act.
Instruction:
Source: Table-4(A)(5) of FORM GSTR-3B

Analysis:
Details of all ITC claimed, reversed and reclaimed during the FY 2017-18 needs to be
reported in this table.
Illustration – ITC reversed on account of non-payment to vendor within one hundred and
eighty days. When payment is made, the registered person is eligible to reclaim thecredit.
Such credits are to be reported in Table 6H.
Remarks:
a) Only those ITC which has been reclaimed till March 2018 needs to be reported here.
Where any ITC pertaining to FY 2017-18 becomes eligible to be reclaimed after March
2018, then the same need not be reported in this form being filed for the FY 2017-18.
Same would then be reported in the annual return of FY 2018-19.
b) Any ITC which was required to be reclaimed till March 2018 but the same has been
reclaimed in subsequent period, then the same needs to be reported in Table 8C and 13
respectively.
c) ITC disclosed in Table 6B and 6H should be equal to the data disclosed in Table 4(A)(5)
of GSTR 3B.
d) Any ITC which has been reclaimed is required to be claimed in GSTR-3B in Table
4(A)(5) along with all other ITC which have been claimed for the very first time. So, the
ITC which has been reclaimed in the said table need to be recognized from the said table
which suggests that there is a necessity to have a pinpoint working of the ITC claimed in
GSTR-3B for all the tax periods. In the absence of such working papers, spotting the ITC

which has been reclaimed in the returns might prove to be a challenge. Precaution on
given point should be kept.
i. Table – 6I- Sub-total (6B to 6H above)

The said table auto-calculates the summation of the details declared in table 6B to 6H above.
j. Table – 6J- Difference (I-A above)

Instruction:
Analysis:
This table auto-calculates the difference between the ITC auto populated in Table 6A above
from Table-4(A) of GSTR-3B for the entire period and the aggregate of ITC being auto-
populated in the Table 6I above.
Remark:
a) The figure in this table should always be equal to zero as Tables 6B to 6H above requires
exactly to punch the data filed in GSTR-3B and therefore there appears to be no reason as
to there would be any difference in this table.
b) This table is a cross check for the taxpayers to ensure that they have declared all the
details filed in GSTR-3B for the period for which such annual return is being filed.
k. Table – 6K- Transition credit through TRAN-I (including revision if any)

Instruction:
Source: Credit entry appearing in the Electronic Credit ledger with the description
“Transition Cenvat Credit/VAT credit”.
Analysis:
Amount of credit received in the Electronic credit ledger through Form GST Tran-1 should
be reported here. Where the registered tax payer has revised GSTTRAN-1, the credit claimed
in the revised TRAN-1 should be disclosed in this Table.
l. Table – 6L-Transition credit through TRAN-II

Instruction:

Source: Electronic Credit ledger under the head of Transition cenvat credit/vat credit
Analysis:
This table shall contain the aggregate value of credit availed by the registered person through
TRAN-II. The credits availed through Form TRAN-II are credited directly into the Electronic
credit ledger of the Registered Person.
Remark:
GSTN is auto-populating the details of transitional credit received in the ECL after March
2018 in this table. But since the said credit was not available for utilization during the FY
2017-18, whether the same should be reported in this table is a debatable issue. Hence the
registered person and the auditor need to take the necessary caution.
m. Table – 6M - Any other ITC availed but not specified above

Instruction:
Source: Credit entry in Electronic Credit Ledger pertaining to ITC-01 or ITC-02 during the
period for which the annual return is being filed.
Analysis:
This table contains the details of the ITC availed but not covered in any of heads specified
under 6B to 6L above. ITC availed on the basis of section 18(1) or 18(3) through ITC-01 or
ITC-03 should be reported here.
n. Table – 6N-Sub-total (K to M above)

The said table auto-calculates the summation of the details declared in table 6K to 6M above
i.e. other than the ITC availed in GSTR-3B.
o. Table – 6O-Total ITC availed (I+N above)

This table is the summation table 6I and 6N above i.e. the ITC availed in GSTR-3B (Tables
6B to 6H) and other ITC not claimed in GSTR-3B (Tables 6K to 6M)
B. TABLE-7 - Details of ITC reversed and ineligible ITC for the Financial Year
This table shall contain the information relating to ITC reversed in the monthly returns
(GSTR-3B) for the FY 2017-18 i.e. July-March 2018, be it under Rule 37 or Rule 39 or
Rule 42 or Rule 43. This table also requires reversing blocked credits u/s 17(5) of the CGST
Act along with reversals of ineligible transitional credits.
One important point to be noted here is that this table contains the details of only those
reversals which have been made in the monthly returns (GSTR-3B) of July-March 2018.

Any reversal of ITC availed during FY 2017-18 done after 31st March 2018 i.e. during
the monthly returns of April-March 2019 shall be reported in a separate table (Table-
12) and not under this table.
Instruction:
7A, 7B, Details of input tax credit reversed due to ineligibility or reversals required
7C, 7D, under rule 37, 39, 42 and 43 of the CGST Rules, 2017 shall be declared
7E, 7F, here. This column should also contain details of any input tax credit
7G and reversed under section 17(5) of the CGST Act, 2017 and details of ineligible
7H transition credit claimed under FORM GST TRAN-I or FORM GST TRAN-
II and then subsequently reversed. Table 4(B) of FORM GSTR-3B may be
used for filling up these details. Any ITC reversed through FORM ITC -03
shall be declared in 7H. If the amount stated in Table 4D of FORM GSTR-
3B was not included in table 4A of FORM GSTR-3B, then no entry should
be made intable 7E of FORM GSTR-9. However, if amount mentioned in
table 4D of FORM GSTR-3B was included in table 4A of FORM GSTR-
3B, then entry will come in 7E of FORM GSTR-9.
II. CLAUSE WISE ANALYSIS OF TABLE 7:

a. Table – 7A – As per Rule 37
Source: Table 4(B)(2) of GSTR-3B
Analysis:
a) Reversal of ITC done case of failure in payment of consideration within 180 days from
the date of issue of invoice by the supplier is required to be reported in this table.
b) Such condition of 180 days is required to seen on 31st March 2018. If any ITC appears
liable to be reversed on the said date which has actually been reversed till GSTR-3B of
March 2018 should be reported here.
c) ITC which was reversed in 2018-19 pertaining to FY 2017-18 should be reported in Table
12.
b. Table -7B – As per Rule 39

Analysis:
a) Rule 39 deals with the procedure for distribution of input tax credit (ITC) by Input Service
Distributor (ISD). ISD is required to distribute ITC in the manner prescribed in the sub
rule 39(1). The ISD shall as per rules 39(1)(d), separately distribute the amount of
ineligible input tax credit as per section 17(5) of the Act.
b) If any supplier gives credit note to the ISD then input tax credit is required to be reduced
and shall be apportioned to each recipient in the same ratio in which the input tax credit
contained in the original invoice was distributed in terms of clause (d).

c) Consequently, ISD is required to issue a credit note to give effect to the above adjustment
to each of the recipient of the original invoice. Recipient of such credit notes is required to
reverse the credit received from ISD in GSTR-3B in Table 4(B)(2) which is required to be
reported in this table.
d) Another instance for reversal of ISD credit may arise when the credit is distributed by the
ISD either to the wrong unit or in wrong proportion.
c. Table – 7C & 7D – Reversal as per Rule 42 & 43

Analysis:
a) Reversal of ITC pertaining to FY 2017-18 done under Rule 42 & 43 in Form GSTR-
3B filed for the said period is required to be done in this table.
b) Credit reversal reporting requirement in GSTR 3B is consolidated for Input, Input
services and capital goods. Reporting requirement in Table 7C of GSTR 9 requires
reporting of the reversal of credit availed on inputs and input services and Table 7D
requires reporting of reversal of credit availed on capital goods respectively.
Bifurcation of these amounts reported in Table 4(B)(1) would be required to identify
amount to be reported in Table 7C andTable 7D.
c) Any ITC pertaining to FY 2017-18 reversed subsequent to the filing of March 2018
GSTR-3B is not required to be reported here. It should be reported in Table-12.
d) Further, in case it is found that the ITC required to be reversed has not been reversed
in any of the return, then in that case it can be paid through Form DRC-03.
e) Some of the possible situations of ITC reversal under Rule 42 & 43 and their reporting
requirement in Form GSTR-9 is discussed below (Correlation of Table 7C, 7D with
Table 12):
Situations Reporting requirement in Form GSTR-9
ITC Reversed in 2017-18 Table 7C (for input and input service) and Table-
7D (for capital goods)
ITC Reversed by mistake in 2018- ITC Reversal in Table 7C& 7D (for capital
18 and re-availed in2017-18 goods) and re-availed ITC to be reported in
Table 6H above.
ITC Reversed in 2018-19 Table 12
ITC Reversed by mistake in 2018- ITC Reversed in Table 12 and re-availed ITC in
19 and re-availed in 2018-19 Table 13.
d. Table – 7E – As per Section 17(5)

Source: Table 4(B)(2) Form of GSTR-3B
Analysis:
After a lot of debate over the reporting requirement under this table in the original form,
the government has come up with the much needed clarification in the revised form.

Section 17(5) of the CGST Act provides for the list of certain inward supplies commonly
known as “Blocked Credits”, the input tax credit in respect of which is not available.
There can be two possible scenarios of reporting of blocked cred its in the GSTR-3B
adopted by the taxpayers all over the country:
Scenario-I: Since the law itself provides that the input tax credit is not available for the
inward supplies listed under section 17(5), therefore there is neither any need to claim the
ITC in relation to the same in GSTR-3B in Table 4(A) (as Table 4(A) requires to report
only those inward supplies on which ITC which is available), nor reverse the same under
Table 4(B)(2). Rather only disclosing the same in Table 4(D)(1) is enough.
Scenario-II: ITC in respect of the inward supplies listed u/s 17(5) should be claimed in
GSTR-3B in Table 4(A)(5) and then subsequently reverse the same in Table 4(B)(2) and
finally disclosing the same in Table 4(D)(1).
However, the FORM GSTR-9 requires reporting the figures of ITC blocked u/s 17(5) in
Table 7(E), being ineligible ITC which is ultimately reduced from the Total ITC
calculated in Table 6(O).
Therefore, depending on the fact that whether the taxpayer has adopted Scenario-I or
Scenario-II, the taxpayer is required to report the figures of blocked credits in the
following manner:
Particulars Scenario I Scenario II
Situation Where the blocked credits were Where the blocked credits were
not availed in Table-4A of availed in Table-4A of GSTR-3B
GSTR-3B and consequently no and consequently reversed in Table-
reversal made in Table-4B. They 4B. Also disclosed in Table 4D.
were only disclosed in Table 4D.
Source Table 4(D)(1) of GSTR-3B Table 4(B)(2) of GSTR-3B
Reporting Not required to be reported in ITC reversed in Table 4(B)(2) is
requirement in Form GSTR-9. required to be reported in Table 7E.
Form GSTR-9
Remark:
a) Whatever may be the approach in filing of Form GSTR-3B, the sum and substance of
the above reporting requirement is that no ITC blocked u/s 17(5) should have been
availed and utilized by the taxpayer. In case it is availed, then the same is required to
be reversed. In other case, where it is not availed, then the same is not required to be
reversed.
b) Since this revised form no longer confines itself to report only those figures which
have been reported in the periodic returns, hence the taxpayer and the auditor needs to
apply its wisdom to ensure that all the blocked credits which have been availed but not
reversed are eventually reversed by way of filing of form DRC-03. Auditor can also
report such instances in Form GSTR-9C.
e. Table -7F & 7G - Reversal of TRAN-I and TRAN-II credit


Analysis:
a) This Table requires details of reversal of transitional credit claimed and reported
earlier in 6K and 6L. Transfer of taxes paid under earlier tax regime would flow into
GST regime through self-declaration. And there may be reasons to reverse some or all
this credit due to arithmetical errors, clarity of law or by omission and commission by
the registered parson. Revision was permitted through GSTR 3B filed.
b) Illustrative list of instances where TRAN-I credit needs to be reversed:
a. Clerical errors made at the time of filing of Form TRAN-I.
b. Credit of Krishi Kalyan Cess, / Education Cess and / Secondary and Higher
education Cess brought forward from earlier laws have to be reversed as they have
been made ineligible duties retrospectively w.e.f. 1st July 2017 vide CGST
Amendment Act.
c. Any other transitional credit reversed subsequent to the direction by the
department.
c) Illustrative list of instances where TRAN-II credit needs to be reversed:
a. For failure to pass on the benefit of such transition credit allowed under GST.
b. Excess / wrongly availed credit in TRAN-II by mistake.
c. Reversal made on the direction by the department.
Remark:
If the reversal of transitional credit is done in the GSTR-3B filed for the period July –
March 2018, then the same needs to be reported here. In case the reversal is done
subsequent to the filing of March 2018 GSTR-3B, then the same is required to be reported
in Table 12 and not in this table.
f. Table 7H – Other Reversals (pl. specify)

Analysis:
a) This table shall contain all the other instances where the credit is required to be
reversed but which are not covered in the Table 7A to 7G above. So, this is a residuary
table meant to contain the details of all the ITC reversed other than the ones covered
above.
b) Illustrative list of instances that can be covered here:
a. Violation of Section 16(1) & 16(2) – Specifies conditions for eligibility of ITC.
b. Violation of Rule 36(2) – Rule 36(2) provides that ITC shall be availed only if all
the information required in the invoice in contained in it.
c. Section 18(4) – Where any registered person opts to pay the tax under section 10 or
where the goods or services supplied by the registered person becomes exempt, it
shall be required to pay an amount equivalent to the credit of input tax in respect of

inputs held in stock and inputs contained in SFG or FG held in stock and capital
goods reduced by such percentage points prescribed in the law.
d. Section 18(6) – Supply of capital goods or plant and machinery on which ITC has
been claimed.
e. Invoice containing the Place of Supply of other state.
f. Differences arising on account of reconciliation of ITC claimed with GSTR-2A.
g. Excess ITC claimed earlier.
h. Reversal of ITC owing to the credit note issued by the supplier.
c) Any ITC reversed after filing of March 2018 GSTR-3B should be reported in Table
12.
g. Table – 7I - Total ITC Reversed (Sum of A to H above)

Analysis:
This table shall contain the aggregate value of all the ITC reversed above in Tables 7A to
7H above and shall be auto-calculated.
h. Table – 7J – Net ITC Available for Utilization (6O – 7I)
Analysis:
The figure in this table shall be auto-calculated. It shall reflect the difference between the
Total ITC availed and the Total ITC reversed in Tables 6O and 7I respectively.
Remark:
Although the figure in this clause is auto-populated, but the figure in this clause have
immense significance as this figure is taken forward in Form GSTR-9C in Table no. 12E
and 14S wherein the ITC booked in the annual audited financial statements are reconciled
with the ITC appearing in this clause of Form GSTR-9. Hence, one needs to be very
particular of the figure appearing in this clause as this is required to be reconciled with the
ITC booked in the annual accounts and the difference, if any, shall then be paid in cash.
i. Table-8 - Other ITC Related Information

Table 8 of GSTR 9 contains two sections. The first section relates to comparison of credit
availed by the tax payer with the credit available as per inward supply uploaded by the
suppliers in GSTR 1, duly reflected in GSTR 2A (Clause A to F of Sl. No.8). The second
section relates to comparison of IGST paid on import of goods with IGST availed on import
of goods (Clause G to J of Sl. No. 8). The differences in both the cases (Clause K of Sl. No.
8) is sought ‘to be lapsed’. However, this is only a statistical data and will have no impact on
the ECL.

Clause wise analysis of Table 8:
j. Table-8A - ITC as per GSTR-2A (Table 3 & 5 thereof) (Auto-populated)
Instruction:
Source: Table 3 & 5 of GSTR-2A of July-March 2018.

Analysis:
a) Table 3 of Form GSTR-2A contains the details of the inward supplies received from a
registered person other than the supplies attracting reverse charge whereas Table 5
contains the details of Debit / Credit notes (including amendments thereof).
b) The purpose of this table is to compare the credit availed by the taxpayer with the credit
uploaded by the suppliers in their GSTR-1.
c) Form GSTR-2A is a static document to the extent that it doesn’t gets updated subsequent
to any addition or amendment made by the suppliers in the subsequent GSTR-1 in
respect of the supplies already declared in their earlier GSTR-1. It gets finalized for the
FY 2017-18 once the GSTR-1 for the month of March 2018 is filed by supplier. Hence, it
may not lead to a true picture of the comparison and there may be possibility of variances
between Table 8A and aggregate of 8B & 8C. Eventually, such differences would
become the reconciling items in Form GSTR-9C.
For example, where any correction or addition is made by the supplier pertaining to
supplies made during FY 2017-18 in the subsequent GSTR-1, then the same does not
gets updated in the GSTR-2A for FY 2017-18.
Also figures of Input Tax Credit (ITC), as pre-populated in table 8A of Form GSTR-9, do not
match with the figures as appearing in their Form GSTR-2A, the reason for variation has
been clarified by the portal. The issues clarified are as here under:
a) Figures in GSTR-2A are auto populated based on filed/ saved / submitted Form
GSTR-1 of the supplier taxpayer. But figures in table 8A of Form GSTR-9 are auto-
populated only on the basis of filed Form GSTR-1 by the supplier taxpayer. In case,
Form GSTR -1 is not filed by your supplier, then credit related to those invoices will
not appear in table 8A of your Form GSTR-9.
b) Figures in table 8A of Form GSTR 9 are auto populated only for those Form GSTR-1,
which are filed by the supplier taxpayer by due date of its filing i.e. 30th April, 2019.
Thus, ITC on supplies of the financial year 2017-18, if reported beyond 30th April,
2019, will not get auto-populated in table 8A of Form GSTR-9.
c) In table 8A of Form GSTR-9, only latest values have been auto-populated based on
filed Form GSTR-1, taking into account all the amendments made, if any.

d) In table 8A of Form GSTR-9, ITC related to all such invoices have been excluded in
which place of supply lies in supplier’s taxpayers State, instead of State of the
receiver taxpayer. These figures will be shown in Form GSTR-2A of the recipient.
For example if a taxpayer of State A visits State B and stays in a hotel in State B, the
tax paid by him to the hotel in State B will appear in his Form GSTR-2A, but the
same will not be reflected in table 8A of Form GSTR-9. (It means when CGST &
SGST levied of other state, which cannot be claimed as ITC)
The Figures in table 8A of Form GSTR-9 do not contain ITC for the period during which the
recipient taxpayer was under composition scheme
k. Table -8B - ITC as per sum total of 6(B) and 6(H) above
Instruction:
Analysis:
The data in this table shall be auto-populated based on the data punched in Table 6B & 6H
above.
l. Table 8C - 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 during April to September 2018
Instruction:

Analysis:
a) This clause reflects the figures of input tax credit pertaining to 2017-18 availed through
GSTR 3B filed for the period April 2018 to September 2018.
b) The values entered under this table are required to be extracted from Table 4(A)(5) of
GSTR3B for April 2018 to September 2018. Therefore, it is necessary to have a pinpoint
working of the ITC availed in these tax periods.
c) ITC claimed in the subsequent returns should be compared with the input tax credit
register of the subsequent period. The excess ITC claimed in the FY 2018-19 upto
September 2018 over the ITC appearing in input tax register can be said to be the ITC
pertaining to FY 2017-18 claimed in 2018-19 (up to September 2018).

Further, considering the invoice wise details of such excess ITC claimed, the one can
verify the same from data appearing in input tax credit register of FY 2017-18 and
GSTR-2A.
d) Only the ITC claimed in the April-September 2018 GSTR-3B on the GST paid under
forward charge is to be reported here.
e) Last but not the least, although the instruction of this table required to report only those
ITC which has been availed in April-September 2018 GSTR-3B, but since the time limit
for availing the ITC has been extended by Order no.2 as discussed above, a view can be
taken that any ITC already appearing in GSTR-2A of 2017-18 in Table 8A above, but
claimed in GSTR-3B in October-March 2019 should also be reported here. The purpose
is to reconcile the ITC appearing in GSTR-2A and ITC claimed in 3B to the maximum
extent possible.
f) Also ITC on inward supplies declared during the period April 2018 to March 2019 shall
be reported here.
m. Table-8D – Difference (8A-8B-8C)

Instruction:
Analysis:
a) Ideally the value in this clause ought to be positive, since all inward supplies as reported
in GSTR 2A may not be eligible input tax credit. In majority of circumstances GSTR 2A
will also contain blocked credit under section 17(5) and non-business credits under
section 17(1), in addition to eligible credit. There could be credits used exclusively/
partially for exempt supplies, which will have to be dealt as per section 17(2), (3) of
CGST Act, 2017 r/w Rule 42 and Rule 43 of CGST Rules, 2017. Hence this clause ought
to generally declare a positive value.
b) However, in many cases this clause would derive a negative value, because ITC has been
availed by the recipient, but the supplier has failed to upload the invoices in his GSTR 1,
leading to absence of corresponding credits and values in GSTR 2A of the registered
person. In some cases, the credit may be appearing in GSTR-2A of the next financial
year. In such cases, there is no need to panic as the Government has already vide its press
release dated 18.10.2018 has made it clear that “furnishing of outward details in FORM
GSTR-1 by the corresponding supplier(s) and the facility to view the same in FORM
GSTR-2A by the recipient is in the nature of taxpayer facilitation and does not impact the
ability of the taxpayer to avail ITC on self-assessment basis in consonance with the
provisions of section 16 of the Act. The apprehension that ITC can be availed only on the
basis of reconciliation between FORM GSTR-2A and FORM GSTR-3B conducted before

the due date for filing of return in FORM GSTR-3B for the month of September 2018 is
unfounded as the same exercise can be done thereafter also.”
c) Negative values in this clause, in exceptional circumstances could also indicate errors or
omissions/ commissions/duplication on the part of registered person while availing credit,
availing excess credits due to typographic errors which must be taken care of by the
auditor.
d) Hence, it is stressed that working sheets must be prepared on the basis of ledger accounts/
invoice to determine and find out the exact cause of difference.
Remark:
The registered person ought to consider possible ramifications where this clause discloses a
negative figure. The department may automatically issue notices/ letters to the registered
person alleging that excess credit has been availed or seeking information why value in this
clause is negative.
n. Table-8E – ITC available but not availed (Out of Table 8D)

Table-8F – ITC available but not eligible (Out of Table 8D)
Instruction:
Analysis:
a) This clause seeks to lapse eligible credit, which has not been availed within the time limit
specified under section 16(4) of CGST Act, 2017.
b) Any Input tax credit appearing in books but not availed in GSTR-3B should also to be
reported in Table-8E irrespective of the fact whether it is appearing in Table 8A above or
not.
c) Even if the value in Table – 8D comes put to be negative or zero, the values in these
tables should be correctly shown. It is not necessary that the summation of these tables
has to be equal to Table 8D.
d) Table 8F shall in addition to the ineligible credits include the details of blocked credits
u/s 17(5) in case the same has neither been claimed in Table 4(A) of GSTR-3B nor
reversed in Table 4(B) but merely disclosed in Table 4D.
1. Possible instances (illustrative only) where the ITC is available in 2A but not
claimed:
a) Capital goods where entire amount (including GST) is capitalized in the books.
b) Omission in claiming the ITC pertaining to FY 2017-18 in GSTR-3B not only till GSTR-
3B of March 2018 but also in subsequent months GSTR-3B.

c) Where the supplier has mistakenly entered the details of outward supplies in its GSTR-1
more than once.
d) Technical Error on the common portal at the time of filing of GSTR-3B of March 2018 or
September 2018.
2. Possible instances (illustrative only) where ITC is available but not eligible:
a) Any ITC which is neither used nor intended to be used in the course or furtherance of
business (Section 16(1)).
b) ITC availed in contravention of Section 16(2).
c) Long Term Service Agreements which due to non-fulfillment of condition of receipt of
service, the availment of ITC is delayed
d) Where the supplier has mistakenly entered wrong GSTIN in its GSTR-1 as a result of
which the ITC which does not belong to the taxpayer is appearing in its GSTR-2A.
Again, its violation of Section 16(2) only.
e) Where the invoices are not in accordance with provisions of Rule 36(2) read with Rule 46
of the CGST Rules 2017.
f) Where the PoS in respect of the inward supply does not belong to the state in which the
taxpayer filing annual return is registered. (Different state POS).
g) Where the inward supply on which ITC is appearing in GSTR-2A is used exclusively in
non-business purpose or exempt supplies.
o. Table – 8G - IGST paid on import of goods (including supplies from SEZ)

Instruction:
Source: Bill of Entry or ICEGATE portal.

Analysis:
a) Supplies of goods or services or both to or by a SEZ unit or SEZ developer is treated as an
inter-State supply as per section 7(5) of IGST Act, 2017. Hence, supplies from SEZ unit/
developer to DTA would be liable to IGST. Further as per section 30 of SEZ Act, 2005
any goods removed from SEZ to Developer ‘shall be chargeable to customs duty’, as
leviable on such goods when imported. IGST paid on procurement of goods from SEZ
unit/developer is also required to be reported here.
b) This table requires only to report the details of IGST paid on import of goods or
procurement of goods from SEZ and not the IGST availed on such imports or
procurements.

p. Table 8H - IGST credit availed on import of goods (as per 6(E) above)
Instruction:
Analysis:
Clause 6E covers only inputs and capital goods. Input services are not the subject to 6E since
import of services is specifically covered under 6F of GSTR 9 and only data from 6E is auto-
populated into Table H. Another reason import of services is not included for reconciliation
in8G & 8H is because there is no parallel data available with the department (similar to
ICEGATE) to compare the tax paid on import of service under reverse charge.
q. Table 8I& 8J – Difference (8G-8H) / ITC available but not availed on import of goods
(Equal to 8I)
Analysis:
a) Although these two are separate tables but interestingly that the information sought in both
the table is same.
b) These tables shall calculate the difference in the IGST paid on import of goods vis-à-vis the
ITC claimed in GSTR-3B. This difference shall then be carried forward to Table-8K.
c) The difference may arise in the case where the goods are although cleared for home
consumption after payment of IGST and applicable duties but the same have not been
received in the premises/factory of the taxpayer till 31st March 2018 as a result of the ITC on
IGST paid on such imported goods is eligible to be claimed in the next FY i.e. in 2018-19 and
not in 2017-18.
r. Table 8K - Total ITC to be lapsed in current financial year (8E + 8F + 8J)

Instruction:
Analysis:
a) The figure in this table shall be auto-populated and it shall be the summation of the figures
reported in tables:
a. Table 8E – ITC available but not availed
b. Table 8F – ITC available but not eligible
c. Table 8J – ITC available but not availed on import of goods (Equal to 8I)
b) Although any figure in this table will not actually impact the credit lying in the Electronic
Credit Ledger as the balance in the said ledger doesn’t gets effected with the amount
appearing in GSTR-2A. Only whatever has been claimed or reversed through GSTR-3B can
have an impact on the balance lying in this ledger. Therefore, it can be said that any amount
appearing in this table is only statistical data and has nothing to do with the balance lying in
the ECL.

4. Part IV- Table 9
Details of tax paid as declared in returns filed during the financial year
Instructions: Part IV is the actual tax paid during the financial year.
Reference Table of GSTR-3B – Table 6.1 of GSTR-3B
Analysis:
• Though Table 9 of GSTR-9 requires the details of tax payable and tax paid, instructions
only indicate reference of Table 6.1 of FORM GSTR-3B for payment of tax.
• In the auto-populated draft of GSTR-9 at portal, the amount of tax payable in Table 9 is
the total amount of tax payable as self-assessed, declared and paid (through cash or ITC)
in GSTR-3B for the relevant financial year.
• The important point to note is that the amounts of tax paid through cash or ITC in Table 9
of GSTR-9 are blocked for editing at portal but the amount auto-populated in tax
payable column is editable.
• Due to lack of clarity in the Instruction for fetching amount of Tax payable, there are two
views prevalent for fetching information in given Column:
1. Details of Tax Payable should be summation of Total Tax Liability self-assessed and
disclosed in monthly GSTR-3B returns for the Financial Year 2017-18 (as auto-
populated)
2. Tax payable in Table 9 of FORM GSTR-9 should be derived from details of

advances, inward and outward supplies on which tax is payable as declared in Table
4underPart-II of GSTR-9.
Remarks:
If Instruction 4 and 7 and are followed strictly and transactions are reported in Part II
and Part V on basis of tax payment in GSTR-3B:
In this case, tax payable in Table 9 will be same as tax liability reported in GSTR-3B for the
relevant financial year. Any transaction on which tax is paid after filing of GSTR-3B for
March 2018 till GSTR-3B for March 2019 will be reported in Table 10 and 11 of Part V of
GSTR-9.
If supplies with tax payable are reported in Table 4 of Part II of GSTR-9:
The total tax liability as per Part II Table 4 should be reported in Table 9 of GSTR-9 and
since such amount may be at a variance from GSTR-3B for the relevant financial year, the
amount of tax liability so deduced should be reported in tax payable column of Table 9 of
GSTR-9 by editing the figures auto-populated therein.

Further particulars of the transactions for FY 2017-18 declared in returns between April 2018
to March 2019 shall be declared in Pt. V of FORM GSTR-9. Such particulars may contain
details of amendments furnished in Table 10 and Table 11 of FORM GSTR-1
5. Part 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
Instruction to Part V:
Part V consists of particulars of transactions for the previous financial year but paid in the
FORM GSTR-3B of April to September of current FY or date of filing of Annual Return
for previous financial year (for example in the annual return for the FY 2017-18,the
transactions declared in April to September 2018 for the FY 2017-18 shall be declared),
whichever is earlier.
As per clarification, particulars of transaction for FY 2017-18 declared in return between

April 2018 to March 2019 shall be declared in Part V.
Table 10 and 11
Supplies / tax declared through Amendments (+) (net of debit notes)
Supplies / tax reduced through Amendments (-) (net of credit notes)
Instruction:
Details of additions or amendments to any of the supplies already declared in the returns of
the previous financial year but such amendments were furnished in Table 9A, Table 9B
and Table 9C of FORM GSTR-1 of April to September of the current financial year or
date of filing of Annual Return for the previous financial year, whichever is earlier shall be
declared here.
Analysis:
The items which should be reported in Table 10 are:
a) Additional invoices related to 2017-18 reported in GSTR-1 for April to September 2018;
b) Debit notes dated up to 31st March 2018 omitted to be reported in 2017-18 and reported in
the returns for April to September 2018
c) Amendments to invoices related to 2017-18 reported with errors in the GSTR-1 for 2017-
18 but now amended in the GSTR-1 for April to September 2018.
The items which should be reported in Table 11 are:
a) Credit notes dated during 2017-18 and omitted to be reported in GSTR-1 ‘for’ 2017-18 but
reported in the returns for the months April 2018 to September 2018
b) Amendments to invoices related to 2017-18 and reported (with errors) in the GSTR1
for2017-18 but now amended in the returns for April 2018 to September 2018.

Remarks:
The above instructions to Pt. V and Table 10 and 11 are contrary in a sense that Pt. V instruct
to include only such transactions on which tax is paid through GSTR-3B for April to
September 2018 but Table 10 & 11 instructs only to include additions or amendments
made through Table 9A, 9B, 9C of GSTR-1.
As already discussed above, there is a disjunct between GSTR-1 and GSTR-3B and it is not
necessary in all cases that tax on addition or amendment to any invoice pertaining to FY
2017-18 made in April to September 2018 is paid through GSTR-3B of April to September
only.
The following situations for invoices of a previous FY declared current FY may arise due to
variance (For example, invoice of FY 2017-18 declared in April to September 2018):
1. Transaction of previous FY on which correct tax is paid through GSTR-3B during
April to March of previous FY only but such invoice declared or amended in GSTR-1
of April to September of current FY.
In such cases, since tax is paid through GSTR-3B up to March of relevant FY only, such
invoice should be taken in Table 4 in view of Instruction No. 4 to Part II.
2. Transaction of previous FY on which correct tax is paid through GSTR-3B for April to
September of current FY and invoice declared or amended in GSTR-1 of April to
September of current FY.
In such cases, since tax is paid through GSTR-3B for April to September of current FY,
such invoice should be taken in Table 10 or 11 in view of Instruction No. 7 to Part V.
Further, the heading and instruction to Part V refer to transactions for the previous FY
declared in returns of April to September since proviso to Section 37(3) of CGST Act, 2017
allowed such additions or amendments up to September only.
However, above reproduced ROD 2 extends such time limit up to due date of furnishing of
GSTR-1 for March 2019.
Hence there are two prevalent views for reporting of rectification of errors or omission of
invoices pertaining to FY 2017-18 made in returns for October 2018 to March 2019:
1. Rectification of error or omission of invoices of FY 2017-18 made in GSTR-1 for
October to March 2019 as allowed by ROD 2 should be declared as under:
• Invoices for which tax liability has been paid through GSTR-3B up to March
2018should be declared in Table 4 and tax liability and tax paid would form part of Table
9 of GSTR-9.
• Invoices for which tax liability has been paid through GSTR-3B for April 2018 to
September 2018should be declared in Table 10 or 11. Such tax paid should be reported
in Table 14.
• Invoices for which tax liability has been paid through DRC-03 up to March 2019
should be declared in Table 10 or 11. Such tax paid should be reported in Table 14.
2. Since the heading of Pt. V states for transactions for the previous FY declared in returns
of April to September only, the other view is that all additions or amendments to supplies

declared in returns of FY 2017-18 made in October to March 2019 should be declared
Table 4 of GSTR-9. In this case, tax payable on such supplies will be added to auto-
populated values of tax payable in GSTR-9.
For computing values to be declared in Part V, GSTR-1 of April to September of current
Financial Year has to be referred and values declared in these returns for transactions of the
previous FY have to be extracted from invoice level detail of GSTR-1 which is also available
at GST portal in Json format.
Remarks:
As per the Instruction for this clause, only amendments to supplies already declared in
returns of previous Financial Year furnished in Table 9A, 9B, 9C of GSTR-1 shall be
declared in this Table 10 & 11 of GSTR-9.
1. There will be a deviation from the instructions in our view since as per the instruction to
Table 10 & 11, only amendments or additions to supplies already declared in returns are
to be considered here and accordingly, the supplies pertaining to the previous Financial
Year not declared in the returns for the previous FY but declared later in April to
September of current FY are neither included in Table 10 & 11 nor anywhere else in
FORM GSTR-9.
2. Also, amendment to B2C (Others) supplies already declared in previous returns is made
in Table 10 of GSTR-1 and the Instruction for Table 10 & 11 does not include Table 10
of GSTR-1. Such amendments made in April to September 2018 will be left out as per
instruction.
3. In addition to this, it is important to note that option of amendment of B2C (Others)
already declared in previous returns was not present at GST portal initially and such
amendment in Table 10 was introduced later. Therefore, a practice has been followed
where amendments in B2C supplies have been given effect by adding or reducing the
values from B2C others in Table 7 of GSTR-1 of subsequent months. Effect of such
amendments made in Table 7 from April to September of current FY is not considered in
Table 10 or 11 of FORM GSTR-9.
In view of the disclosures required in GSTR-9 and their linking with GSTR-9C, it seems
logical as well as essential to include the following amendments in GSTR-9 in addition to
the Tables referred in Instruction:
1. Supplies of previous FY omitted in GSTR-1 of previous FY but declared in April to
March of current FY.
2. Supplies of previous FY declared in GSTR-1 of previous FY but declared in GSTR-
3B and tax paid on such transaction in April to March of current FY.
3. Amendment to B2C (Others) of previous FY already declared in returns
(Differential taxable value and taxes):
a. Declared through Table 10 of GSTR-1
b. Declared through addition or reduction in Table 7 of GSTR-1

Table – 12 – Reversal of ITC availed during previous financial year
Instruction:
Source: Table 4(B) of Form GSTR-3B

Analysis:
a) Going strictly by the above instruction, it can be said that this table contains the summary
of the input tax credit availed during 2017-18 but reversed during April – September 2019.
The data to be tabulated relates to the input credit that was taken in the previous financial
year and reversed during the period April 2018 to September 2018. The reversal may be
for various reasons like erroneously taken credit or failure to make payments within
stipulated time period. The amount of credit that needs to be reversed is to be disclosed in
this column.
b) Without prejudice to the above paragraph, the illustration given in the instruction of
Part V simply states that the transaction declared in April – September 2018for the FY
2017-18 should be declared in Part V. Therefore, going by the intent of Part V, it simply
means that any ITC required to be reversed in FY 2017-18 but reversed actually in April –
September 2018 should only be reported here. In other words, any which was not required
to be reversed in FY 2017-18 or it can also be said as if the liability to reverse any ITC
pertaining to 2017-18 triggered in 2018-19, then the same should not be reported here.
c) Therefore, if the approach mentioned in Paragraph (b) above is adopted, then it would be
reported in the Table – 7 of the GSTR-9 of FY 2018-19. If that be the case, then the net
ITC available for utilization computed in Table – 7J shall not compute the correct figure of
ITC available for utilization as the form does not consider the opening balance of ITC.
Calculation of Net ITC in Table 7J only considers the ITC availed during a particular
financial year and the ITC reversed during that financial period. Therefore, considering
this disjunct in the form, it is advised that one should strictly go by the instruction
provided for this table and any ITC availed in 2017-18 reversed in April-September 2018
should be reported here only. Consequently, the ITC reversal to be shown in Table 7 of
GSTR-9 of 2018-19 would be restricted to the extent of the reversal pertaining to the ITC
availed in 2018-19.
d) Proper working of GSTR-3B must be maintained so that the amount of ITC reversed in
April to September 2018 can be bifurcated into 2 parts:
a. Reversal of ITC pertaining to the FY 2017-18;
b. Reversal of ITC pertaining to the FY 2018-19.

Table – 13 – ITC availed for the previous financial year
Instruction:
Analysis:
a) This Table requires the taxpayer to declare the details of ITC claimed by him in the
subsequent year (April to September2018) which relates to the previous year 2017-
18.This information would be available in Table 4(A) of the said GSTR 3B of April –
September 2018.
b) Taxpayer must have the bifurcation of the ITC pertaining to the FY 2017-18 and the ITC
pertaining to the FY 2018-19 claimed in the GSTR-3B for April – September 2018.
Remarks:
a) To verify the accuracy of the figure reported in this table, the auditor should compare the
ITC claimed in the subsequent returns with the input tax credit register of the subsequent
period. The excess ITC claimed in the FY 2018-19 upto September 2018 over the ITC
appearing in input tax register of 2018-19 can be said to be the ITC pertaining to FY 2017-
18 claimed in 2018-19 (up to September 2018). Further, considering the invoice wise
details of such excess ITC claimed, the auditor can verify the same from input tax credit
register for the FY 2017-18 and the data appearing in GSTR-2A of 2017-18.
For instance, if a registered person fails to claim input tax credit, say, for the tax period
February 2018 but declares the same in the return relating to May 2018, then as stated
above, this information is to be validated with GSTR 3B for the tax period May 2018 and
GSTR 2A for the tax period February 2018 and reported in this Sl.No.13.
IMPLICATION OF SECTION 16(4) READ WITH REMOVAL OF

DIFFICULTIESORDER NO. 2/2018 DATED 31.12.2018 AND PRESS RELEASE
DATED 18.10.2018 ON ITC IN VARIOUS SCENARIOS
a) Ideally, all the credit claims for each month are required to be reported in the GSTR-3B of
that particular month. However, the law vide section 16(4) has provided the time limit of
availing the ITC which was originally the due date of filing the GSTR-3B for the month of
September 2018 or the due date of filing of the annual return, whichever is earlier. Further,
the Order No. 2 as discussed above has extended the time limit provided u/s 16(4) to the
due date of filing of GSTR-3B for the month of March 2019 provided that the details of
such invoice or debit note relating to such invoice has been uploaded by the supplier in its
GSTR-1 till the due date of filing of Form GSTR-1 for the month of March 2019.

b) Therefore, the time limit for availing the ITC in Form GSTR-3B has been extended to the
due date of filing the GSTR-3B of March 2019 subject to the condition that the ITC
claimed during the October – March 2019 GSTR-3B must be reflecting in the GSTR-2A
of the recipient.
c) This order gives rise to two situations:
a. Where credits are already appearing in Form GSTR 2A (of financial year 2017-18)
but omitted to be claimed by the recipient for the financial year 2017-18 (in Form
GSTR 3B of the financial year 2017-18; or in Form GSTR 3B of the financial year
2018-19 up to Sept 2018); or
b. Where credits are newly appearing in GSTR 2A (of 2018-19) and not forming part of
credits claimed in any earlier Form GSTR 3B either for the financial year 2017-18 or
for the financial year 2018-19 (up to Sept 2018) by the recipient,
In both the above situations, all these new credits can now be claimed by the recipient
only in Form GSTR 3B to be filed by the recipient in the financial year 2018-19 within
the due date for filing of March 2019 return.
d) The condition of ITC reflection in GSTR-2A is not necessary for claiming ITC pertaining
to the FY 2017-18 in the GSTR-3B for July - March 2018 or April - September 2018
(Refer Press Release dated 18.10.2018)
e) Therefore, the reporting requirement pertaining to ITC in GSTR-9 has been summarized in
the following situations below:
S. Period of Whether Claimed in Reporting in Remark

No. ITC appearing in 3B of which GSTR-9
GSTR-2A? period
1 2017-18 Appearing in July – March Table 6 & No inconsistency
2017-18 2018 consequently
in Table 8B
of FY 2017-
18
2 2017-18 Neither July – March Table 6 & Reflection in 2A is not
appearing in 2018 consequently necessary.
2017-18 nor in Table 8B [Refer Press Release
in 2018-19 of FY 2017- dated 18.10.2018]
18
3 2017-18 Appearing in April – Table 13 & No inconsistency
2017-18 September 8C of GSTR-
2018 9 of FY
2017-18
4 2017-18 Neither April – Table 13 & Reflection in 2A is not
appearing in September 8C of GSTR- necessary.
2017-18 nor 2018 9 of FY [Refer Press Release
in 2018-19 2017-18 dated 18.10.2018]
5 2017-18 Appearing in October – GSTR-9 of Refer Order No.2/2018
2017-18 March 2019 FY 2018-19 dated 31.12.2018
6 2017-18 Appearing in October – GSTR-9 of [Refer Order No.2/2018

2018-19 March 2019 FY 2018-19 dated 31.12.2018]
7 2017-18 Neither October – GSTR-9 of Ineligible ITC as the
appearing in March 2019 FY 2018-19 supplier has not uploaded
2017-18 nor the details in GSTR-1.
in 2018-19 [Refer Order No.2/2018
dated 31.12.2018]
8 2017-18 Appearing in Not claimed NA Unclaimed ITC cannot
2017-18 be claimed in this form.
[Refer Instruction No. 3]
9 2017-18 Appearing in Not claimed NA Unclaimed ITC cannot
2018-19 be claimed in this form.
[Refer Instruction No. 3]
Table 14 - Differential tax paid on Account of Declaration in 10 & 11 Above
No instruction has been given for filing of details in this Table.
Analysis:
The purpose of said Table 14 in Part V is to get consolidated value of differential tax liability
self-assessed and discharged in the monthly returns filed during April 2018 to September
2018 for the period for which Annual Return is being filed. The given details along with
details of tax payable in Table 9 shall deduce the total tax liability for the financial year
declared and discharged up to September 2018. The given details shall be useful while filing
reconciliation statement in Form 9C for the Registered Person in calculating the deviation
from the actual tax liability for the financial year.
In the column of Payable, net amount of IGST, CGST, SGST, Cess and interest payable on
account of transactions reported above in Table 10 and Table 11 has to be disclosed.
Tax Paid has to be derived from GSTR-3B of April to September of current FY.
In Table 6.1 of GSTR-3B of April to September of current FY, total amount of Tax paid for
liability of the month for which GSTR-3B is filed and differential tax paid pertaining to FY
2017-18 will be shown as consolidated figures. The tax payment relating to previous
Financial Year can be extracted on basis of working of GSTR-3B only.
1. Transactions on which tax payable has been reported in Table 4 but tax paid in
April to September of current FY
As already discussed, there is a disjunct between GSTR-1 and GSTR-3B. There have
been cases where some invoices have been correctly disclosed in GSTR-1 in relevant FY
but the values furnished in GSTR-3B were incorrect. The differential amount has been
added or reduced from outward supplies declared in GSTR-3B of subsequent months and
output tax liability has been accordingly paid in such subsequent months. Since such
amendments(bearing effect in GSTR-3B only) are reported in Table 4 at correct values
only, they are not required to be declared in Table 10 & 11 above. Tax paid in April to
September on account of such amendments(tax liability correctly reported in Table 4
but tax paid in April to September)shall be restricted from disclosure as Tax paid in

Table 14 according to its heading ‘Differential tax paid on account of declaration in
10 & 11 above’.
Example
An invoice of Taxable value Rs. 1,00,000 and tax liability of 18,000 has been correctly
declared in GSTR-1 of March-18 but the values have been mistakenly reported as taxable
value 10,000 and tax Rs. 1800 in GSTR-3B of March-18. In GSTR-3B of April-18,
differential taxable value of Rs. 90,000 and tax of Rs. 16,200 have been added in outward
taxable supplies and tax has been accordingly paid.
Now, since such amendment is not required to be furnished in Table 9A/9B/9C of GSTR-1, it
will not be declared in Table 10 & 11 of GSTR-9C as per Instruction. Since such amendment
is not declared in Table 10 & 11, tax paid on such amendment will also not be declared in
Table 14.
Remarks:
1. On above interpretation, tax paid as per GSTR-9 will not include amount of tax
already paid in April to September and it will be reflected as a difference between
amount of Tax payable and tax paid. Disclosure of such difference will warrant re-
payment of taxes already paid.
Hence a fair view can be taken, although in deviation from the heading of Table 14, that tax
paid on transaction of previous FY during April to September of current FY will be disclosed
in Table 14 even if liability of such transactions have been reported in Table 4 only (and not
in Table 10 and 11).
2. Robust working and reconciliations should be maintained for GSTR-3B of April to
September of current FY whereby figures of tax paid relating to current FY and previous
FY can be separately identified.
Cases of variance between GSTR-1, GSTR-3B and books of accounts with examples:
S. No. Treatment in GSTR- Action in Reporting in GSTR-9

3B and GSTR-1 up to subsequent GST
March 2018 Returns during
Apr 18 - Mar 19
Declared in GSTR-3B and
1. GSTR-1 Not required Part II
Part II
(This invoice will not be reflected in
GSTR-1 summary for 2017-18 so it
Declared in GSTR-3B but Declared in GSTR-1 should be added for reporting values
2. missed in GSTR-1 for April 2018 in Table 4 of Part-II of GSTR-9.
Part II
This amendment will be part of
GSTR-1 summary for 2017-18 but
Declared in GSTR-1 but Declared in GSTR-3B tax has been paid in GSTR-3B after
2. missed in GSTR-3B of April 2018 March 2018.
− Missed in GSTR-3B Declared in GSTR-1 Part V
3. − Missed in GSTR-1 and GSTR-3B for

April 2018
Part II at correct values
This invoice will be reflected at
incorrect values in GSTR-1
summary for 2017-18, but
corrections should be made in auto-
populated figures to include such
− Reported at correct transaction at correct values in Part-
values in GSTR-3B Amendment done in II of GSTR-9 since tax on such
− Reported at incorrect GSTR-1 for April correct values has been paid through
4. values in GSTR-1 2018 GSTR-3B of March 2018 only.)
5. − Reported with Correction in tax Part II at correct values as per
CGST+SGST liability liability made in GSTR-1
in GSTR-3B GSTR-3B for April
− Reported correctly with 2018
IGST liability in GSTR-
1.
6. − Missed in GSTR-3B Not declared in Part II
− Missed in GSTR-1 GSTR-3B and
GSTR-1 in April
2018 to March 2019,
but recorded in
financials.
7. − Declared in GSTR-3B Amendment done in As per GSTR-1 upto March 2018
at high value Rs. GSTR-1 but in Part II and amendment as per
10,00,000 correction could not GSTR-1 in Part V.
− Declared in GSTR-1 be made in GSTR-
at high value Rs. 3B because negative Excess tax paid which could not
10,00,000 figures are not be adjusted in subsequent GSTR-
allowed. 3B should be claimed as refund
of excess payment of tax.
6. Part VI - Other Information
Table 15 - Particulars of Demands and Refunds
Clause Detail Explanation

15A Total Refund claimed Aggregate value of all the refund claims filed in the
financial year including refunds which have been
sanctioned, rejected or are pending for processing.
15B Total Refund sanctioned It shall include only such amount of refunds for
which sanction order has been made. Provisional
refunds (90%) should not be declared here.
15C Total Refund rejected It shall include such amount of refunds for which
rejection order has been made.
15D Total Refund pending Aggregate amount in all refund application for

which acknowledgement has been received. The
amount declared here shall be excludingprovisional
refunds received.
15E Total demand of taxes Aggregate value of demands of taxes for which an
order confirming the demand has been issued by the
adjudicating authority shall be declared here.
15F Total taxes paid in respect Aggregate value of taxes paid out of the total value
of E above of confirmed demand as declared in 15E above shall
be declared here.
15G Total demands pending Aggregate value of demands pending recovery out of
out of E above 15E above shall be declared here.
Table 16
Information on supplies received from composition taxpayers, deemed supply under
section 143 and goods sent on approval basis
16A 16B 16C

Instruction Aggregate value of Aggregate value of all Aggregate value of all
supplies received deemed supplies from the deemed supplies for
from composition principal to the job-worker goods which were sent on
taxpayers in terms of Section 143(3) approval basis but were
and 143(4) of the CGST not returned to the
Act. principal supplier within
one eighty days
Reference Table 5 of FORM
Table GSTR-3B
Table 17
HSN Wise Summary of outward supplies
Instruction:
Summary of supplies effected and received against a particular HSN code to be reported only
in this table.
It will be optional for taxpayers having annual turnover upto ₹ 1.50 Cr. It will be mandatory
to report HSN code at two digits level for taxpayers having annual turnover in the preceding
year above ₹ 1.50 Cr but upto ₹ 5.00 Cr and at four digits‘ level for taxpayers having annual
turnover above ₹ 5.00 Cr. UQC details to be furnished only for supply of goods. Quantity is
to be reported net of returns.
Table 12 of FORM GSTR1 may be used for filling up details in Table 17
Table 18
HSN Wise Summary of Inward supplies
Instruction:

It may be noted that this summary details are required to be declared only for those inward
supplies which in value independently account for 10 % or more of the total value of
inward supplies.
Analysis:
Input Register maintained as per GST Rules should be used for reporting HSN Summary of
Inward Supplies.
Table 19 - Late fee payable and paid

Instruction:
Late fee will be payable if annual return is filed after the due date.
Analysis:
As per Section 47 (2) of CGST Act, 2017, late fees for failure to furnish annual return by due
date is lower of -
a. Rs. 100 per day of default
b. 0.25% of turnover in State or UT

Audit under GST: Certification & Scope of GST Audit
1. Introduction
Indirect tax is a system of taxation wherein the incidence of tax is being passed to the
ultimate consumer. The term audit is not new when in comes to financial statement; however,
with the introduction of Goods and Services Tax (‘GST’), it has become an integral part of
central indirect tax. It is for the first time the independent audit provisions has been
prescribed in central indirect tax with a definition prescribed thereof. In general, an audit is a
systematic and independent examination of books, accounts, statutory records, documents,
vouchers and other relevant information of an organization to ascertain how far the financial
statements, as well as non-financial disclosures, present a true and fair view of the concern.
It also attempts to ensure that the books of accounts are properly maintained by the business
concern as required by the law.
According to Section 2(13) of Central Goods and Services Tax Act (hereinafter referred as
CGST Act), 2017, audit is defined as under:
(13) “audit” means the examination of records, returns and other documents maintained or
furnished by the registered person under this Act or the rules made there under or under any
other law for the time being in force to verify the correctness of turnover declared, taxes
paid, refund claimed and input tax credit availed, and to assess his compliance with the
provisions of this Act or the rules made there under;
It is pertinent to note that as per the cited definition of audit in the CGST Act, it requires the
auditor to verify the correctness of turnover declared, taxes paid, refund claimed and input tax
credit availed along with the compliance with provisions thereof.
Audit is something different from the certification in reference to meaning, objective, scope
etc.
Certification is related to confirmation of accuracy of the facts stated therein without any
estimate or opinion. As far as the scope of audit is concerned, it is wide and in case of
statutory audit, the scope is determined by the relevant provisions of the law. Whereas in case
of certification, the scope is specific to the subject matter stated therein. Para 2.2 of the
‘Guidance Note on Audit Report and certificate for Special Purpose’ issued by the ICAI
provides the meaning of the terms ‘certificate’ and ‘report’ as under:
- “A Certificate is a written confirmation of the accuracy of facts stated there in and
does not involve any estimate or the opinion.”
- “A report on the other hand, is a formal statement usually made after an enquiry,
examination or review of specified matters under report and includes the reporting
auditor’s opinion thereon.”
Thus, where a certificate is issued, the Chartered Accountant would be responsible for factual
accuracy of what is stated therein; whereas in case of a report, he is responsible for ensuring
that the report is based on the factual data, true and fair (or in some cases true and correct) to
the best of his belief, knowledge and information furnished to him.

2. Practices to be adopted for GST Audit:
The following practices may be followed by the auditor while conducting GST audit of any
taxpayer:
 Internal Control questionnaire must be designed and used in the course of audit in
order to understand the business process of the auditee;
 Obtaining knowledge of business such as geographical presence and GST
registrations, Nature of Business, its products and services, method of compiling the
data for the purpose of filing GST returns, internal SOP’s of the organization for
Accounting reporting of transactions for GST etc.
 Preparation of the audit plan and implementation thereof in order to conduct the GST
audit smoothly;
 Checklist should be prepared for the documents to be checked and must be modified
from time to time depending upon the areas to be verified;
 Assessment of the audit risks i.e. planning and performing the assurance engagement,
including determining the nature, timing and extent of procedures and evaluation of
the subject matter w.r.t. material misstatement;
 Audit documentation and working thereof;
 Obtaining the Management Representation Letter wherever required;
 Obtaining the comments of the management on the observations of the auditor.
 Key Checks and Balances:
o Extracting GSTIN wise Trial Balance;
o Ensuring relevant GSTR 1 and GSTR 2A are matched, wherever applicable;
o Securing confirmation letter where GSTR 1 and GSTR 2A remain unmatched
together with reconciliation thereof to the extent possible;
o Valuation of inter locational transactions where there can be an input tax
restriction in the hands of the recipient
3. Certification:
A certificate is a written confirmation of accuracy of facts stated therein and does not involve
any estimate or opinion. It is certification of factual accuracy of whatever is stated therein.
So, furnishing the reconciliation statement along with certificate in part B of GSTR 9C may
be treated as an attest function whereby auditor is confirming the accuracy of the facts stated
in the reconciliation statement.
4. Auditors’ Note:
There are 2 formats of Certificate one of which is required to be given by the auditor
undertaking the GST Audit. It has to be properly determined which format should be applied
when. As evident from formats itself, the headlines are:
I. Certification in cases where the reconciliation statement (FORM GSTR-9C) is

drawn up by the person who had conducted the audit
II. Certification in cases where the reconciliation statement (FORM GSTR-9C) is
drawn up by a person other than the person who had conducted the audit of the
accounts

Part B of GSTR 9C requires GST Auditor to issue a certificate along with the reconciliation
statement in PART A. It may be noted that the Audit certification also requires GST auditor
to confirm the examination of financial and review of books of accounts maintained.
Accordingly, he has to issue the audit report with opinion and qualifications, if any that is
qualified conclusion, adverse opinion or disclaimer of opinion.
I. Certification in cases where the reconciliation statement (FORM GSTR-9C) is

drawn up by the person who had conducted the audit
As per the contents of the certificate, the auditor needs to perform the following in order to
furnish the certificate in the format as required, where he himself has conducted the audit
under the GST Law and the other law being Income Tax or Companies Act or any other law
for the time being in force.
− Examine the financial statements being Balance Sheet, Statement of Profit and Loss
account and Cash Flow Statement
− Based on such examination he needs to report for the books of accounts in accordance
with the GST law and he needs to separately provide the list of accounting records not
maintained by the registered person as required by the provision of section 35 and rules
made there under. In case there is any discrepancy, observation, comment, inconsistency
is there in the accounts and records maintained by the registered person, such reporting
has to be done separately in the certificate.
− Auditor is required to report the information regarding the matching of books of accounts
with that of the financial statements maintained at the place of business and additional
place of business.
− Whether the registered person has kept the proper books of accounts is to be reported by
the auditor. Here it would be important for the auditor to keep in mind the extent of the
proper books of accounts as far as the GST law is concerned.
− It is important for the auditor to report that whether he has received all information/
documents which was required for the purpose of conduction and completing the audit.
− The auditor is required to certify the truth and correctness of the particulars contained in
the reconciliation statement. Here the primary objective is to certify the truth and
correctness of the reconciliation statement, which in turn broadcast the absolute liability
of the auditor for certification. Absolute assurance about the particulars of 9C can be
there only if the records and documents forming part of the books of account, which is
the basis for certification herein are risk free and or not misstated.
II. Certification in cases where the reconciliation statement (FORM GSTR-9C) is

drawn up by a person other than the person who had conducted the audit of the
accounts
As per the contents of the certificate, the auditor needs to perform the following in order to
furnish the certificate in the format as required, where any other auditor has conducted the

audit the other law being Income Tax or Companies Act or any other law for the time being
in force:
− The auditor is required to state that the audit of the books of accounts and the
financial statement was conducted by any other auditor along with his details and
audit report thereto.
− Reporting with regard to the maintenance of books of accounts in terms of GST law is
required to be done, whereby the registered person has not maintained any record in
accordance with GST law.
− The auditor is required to certify the truth and correctness of the Reconciliation
Statement and particulars contained therein based on his examination of books of
accounts and explanations subject to the qualification/ observations if any. Absolute
assurance about the particulars of 9C can be there only if the records and documents
forming part of the books of account, which is the basis for certification herein are
risk free and or not misstated.
5. Vigilant aspects of the Certificate:
a. Cash Flow Statement
An auditor has to report that he has examined Balance Sheet, Profit and Loss account and
Cash Flow Statement of the auditee. Cash Flow Statement is mandatory only for a subset of
companies and not all the registered persons. Although where Cash Flow Statement is neither
a mandatory document in general parlance of accounting nor it has an important nexus to the
outward supplies, inward supplies, tax liability or Input tax credit, a GST Auditor has been
compelled to examine Cash Flow Statement.
b. Assertion on maintenance of books of accounts, records and documents as per law

Further the auditor has to report that the registered person has maintained the books of
accounts, records and documents as required by the IGST/CGST/Respective SGST Act,
2017 and the rules/notifications made/issued there under. Such an assertion has not been a
part of traditional tax audit reports. Thus, a GST Auditor has to carefully determine the
records and documents required to be maintained by the auditee as per provisions of GST
Law and ensure that either they have been maintained or non-maintenance of such records or
documents has been reported by the auditor in the Certificate.
c. True and Correct View

The auditor has to report that in his opinion, particulars given in the said Form No.GSTR-
9C are true and correct. So far as audits are concerned, there has always been a debate
between a true and correct view and a true and fair viewsince giving a true and correct
view places an extensive onus on the auditor to make sure that whatever is reported in the
certified document is correct and accurate whereas a true and fair view perhaps permits a
limitation in terms of an overall picture of the organization rather than the sanctity of every
number being certified.
Further, it is also important to note that the auditor is expected to give the true and correct
assertion only for the particulars given in Form GSTR-9C and no assertionis required by
the GST Auditor on the books of accounts maintained by the assesse.

The column for true and correct view also contains the space for observation/ qualifications if
any. In this regard it is crucial to note that deemed supplies under schedule I has always been
the allure for the business as well as auditors. So, while giving the certification it might be the
case that entity must not have done cross charge, wherever required. The auditor may have an
opinion for the cross charge. In such case, it will be prudent for the auditor to report such
supplies under the observation column in case the auditee does not pay tax on such deemed
supplies.
6. Scope of GST Audit
In view of the Certification Format as discussed above, a logical understanding comes up that
a GST Auditor has to certify whether the particulars furnished in Form GSTR-9C are true and
correct or not. GSTR-9C is a reconciliation of two aspects which have already been frozen
before coming up at the desk of a GST Auditor and the responsibility of the auditor is to
certify that the journey from figures reported in audited financial statements to the figures
reported in GSTR-9, as depicted in GSTR-9C is true and correct.
It is crucial to understand that the auditor is neither certifying the start point of the
reconciliation, i.e. figures from audited financial statements or books of accounts nor the end
point, i.e. GSTR-9. The auditor is not responsible to play the role of an adjudicating authority
and explore what has not been disclosed in books of accounts or what has not been disclosed
in books of accounts at all. The auditors’ role is to certify the adjustments made to reconcile
the turnover of audited financial statements to reach to GSTR-9 and the un-reconciled
differences which remain uncovered. Thus going by this analogy, there appears a contrast
between the intended scope as per given definition u/s 2(13) of CGST Act, and the format of
reconciliation as discussed herein above.
Now having an understanding of the assertions required to be made by an auditor, the scope
and responsibilities brought in with GST Audit, there is a requirement to have an in-depth
understanding of the Form on which a true and correct view has to be expressed. It is
expedient to mention here that it is mandatory to file GSTR 1, GSTR 3B and GSTR 9 before
drawing up the reconciliation statement. It is also important to note that law does not mandate
to file GSTR 1, GSTR 3B prior to filing of GSTR 9. Howbeit the instruction no. 2 annexed to
Reconciliation statement makes it mandatory to do with such requirement

GSTR 9C - Reconciliation Statement
(Sec. 44(2) of CGST Act, 2017 read with Rule 80(3) of CGST Rules, 2017)
1. Basics –GSTR 9C – Reconciliation Statement

Form GSTR-9C is divided into 2 parts as follows:
Form GSTR-9C
Part A - Reconciliation Statement Part B - Certification
Broad Heads of Reconciliation Statement I. Certification in cases where the

reconciliation statement (FORM GSTR-
9C) is drawn up by the person who had
conducted the audit
• Reconciliation of gross turnover
• Reconciliation of taxable turnover
• Reconciliation of tax paid
• Reconciliation of Input Tax Credit (ITC) II. Certification in cases where the
• Reconciliation of ITC declared in GSTR9 reconciliation statement (FORM GSTR-
with ITC availed on expenses as per
9C) is drawn up by a person other than
books
• Auditor's recommendation on additional the person who had conducted the
Liability due to non-reconciliation audit of the accounts
Although, the order of the Form places Part – A - Reconciliation Statement as the former part
and Part – B - Certification as the latter but for better understanding we have discussed Part-B
Certification first, since for an auditor it shall be the basis for designing scope of audit and
course of actions to be undertaken for the GST Audit assignment.
2. Suspicious Issues arising on account of disjunct between Act and Rules

a. Aggregate Turnover vs. Turnover in State
The above mentioned provisions along with rule envisages that every registered person
whose turnover during a financial year exceeds Rs. 2 Crore shall get his accounts audited by
a chartered accountant or a cost accountant and submit a copy of the audited annual accounts,
the reconciliation statement under sub- section (2) of section 44 and such other documents as
may be prescribed. The above rule prescribes a limit of turnover of 2 crores for the
determination of applicability of GST Audit. But an ambiguity has crept in due to the

variance in terms used in Section 35(5) of CGST Act, 2017 and Rule 80 (3) of CGST Rules,
2017. In Section 35(5) as stated above, a term ‘Turnover’ has been used which is not defined
in the CGST Act, 2017 whereas in Rule 80(3), the term ‘aggregate turnover’ has been used.
The terms “Aggregate Turnover” and “Turnover in state” have been defined. If aggregate
turnover, which is computed on PAN basis, is taken as a base to decide applicability of GST
Audit, there may be instances where distinct person having turnover below the specified limit
may also become liable for audit. In this backdrop, it is reasonable to interpret that the word
turnover in section 35(5) as an aggregate turnover. However, it may be noted that GST Audit
has to be conducted GSTIN wise.
For example, X Ltd. has a turnover of PAN India turnover of Rs. 5 crores. It has registration
in Rajasthan and Maharashtra where; the Turnover in State of Rajasthan is 4.5 crores and
Turnover in State of Maharashtra is 50 lacs. Now, in given case, as the aggregate turnover is
more than Rs 2 cr, for X Ltd, the GST audit is required to be conducted for both X Ltd.
Rajasthan and X Ltd. Mumbai.
b. Turnover for April – March 2018 or July – March 2018

The GST was implemented with effect from 01.07.2017; so for the financial year 2017-18,
the GST was in force for 9 Months. However, the provision of section 35(5) uses the terms
financial year. In this regard, it has now been clarified that Turnover of complete year i.e.
from Apr 01,2017 to Mar 31, 2018 has to be considered for determining the liability of GST
Audit.
c. CTP & NRTP – Not required to file GSTR-9?

Based on aforesaid an interesting scenario arises in case of the casual and non-resident
taxable person whereby being registered person, they are required to get their accounts
audited in terms of section 35 but are not required to file GSTR 9. Rule 80 specifically
excludes them from filing GSTR 9. So, how their audit report will be submitted is an open
issue and clarification from government is required.
The reference of reconciliation statement has been made in Section 44(2)of CGST Act, 2017,
which reads as under:
Every registered person who is required to get his accounts audited in accordance with the
provisions of sub-section (5) of section 35 shall furnish, electronically, the annual return
under sub-section (1) along with a copy of the audited annual accounts and a reconciliation
statement, reconciling the value of supplies declared in the return furnished for the
financial year with the audited annual financial statement, and such other particulars as may
be prescribed.
A perusal of the above provisions infers that the deliverables of GST Audit required to be
submitted by the auditee are:
• Annual Return under section 44(1)

• A copy of the audited annual accounts
• Reconciliation statement, duly certified

The annual return is prepared based on the audited annual accounts whereas other periodic
returns are prepared based on the various transactions recorded prior to final auditing. There
is a possibility that the details as declared in the audited financial statements in respect of
outward supplies i.e. Turnover/ Sales or inward supplies i.e. expenses would have difference
with that of the details submitted in the annual return filed for the reason of the definition
‘supply’ in the context of CGST Act, and therefore one needs to submit the reconciliation
statement in Form GSTR 9C to reconcile the difference in value of supplies as declared in the
audited financial statements vis a vis the annual return as furnished for the financial year.
Here it is worthwhile to mention that annual return allows the taxpayer to furnish the correct
turnover in the annual return and such additional liability can be discharged by way of DRC-
03. However, the taxpayer cannot claim any new input tax credit in the annual return.
Therefore, the adjustments w.r.t. availing of input tax credit missed out or mapping of the
credits with the details as declared by the vendors as reflected in form GSTR 2A has to be
done on or before due date for filing GSTR 3B for the month of March, 2019. While
preparing the reconciliation statement, special heed must be given to transactions not
appearing in the financial accounts such as deemed supplies i.e. stock transfers, free samples,
gifts or any other transaction or activity with related person etc. This would be very crucial
for the auditor in the entire reconciliation activity and most importantly, it would be difficult
to comment to what extent the auditor can take shelter under the principle that things not
bypassing the books of accounts, cannot be called upon to have caused any professional
negligence if not dug out in the normal course of the audit since the responsibility is casted
upon to state that the details submitted thereon is TRUE and CORRECT. It is also important
to note that the reconciliation statement is limited upto the journey between the annual return
and books of accounts. However, the definition of audit travels beyond the reconciliation
statement and the law casts the responsibility on the auditor to verify the correctness of:
• Turnover Declared;
• Taxes Paid;
• Refund claimed;
• Input Tax Credit availed; and
• Compliance with the provisions of GST law.
3. Accounts and Records:

Section 35 and 36 of CGST Act, 2017 infers the provision regarding maintenance of accounts
and records and period of retention of accounts. The nature of records will vary depending
upon the business activities carried out by the person. The main objective of the record is to
ensure that the person is able to compute the tax liability properly and make payment of the
same. As per section 35(1) of CGST Act, 2017, the registered person shall maintain a true
and correct account of:
- Production or manufacture of goods;
- Inward - outward supply of goods or services;
- Stock of goods;
- Input Tax credit availed;
- Output tax payable and paid;

Such other records as may be prescribed.
4. Consequence of failure to submit annual return and reconciliation statement:

Section 47(2) anticipates that in case of failure to submit annual return within the specified
time (for now, 31st August 2019 for the FY 2017-18), a late fee would be leviable @ Rs. 100
per day during which such failure continues subject to maximum of 0.25% of the turnover in
state. It may be noted that the given penalty is under the CGST Act, 2017. The same penalty
is also there in the state law as well. Thus, the penalty shall be lower of Rs. 200 per day or
0.50% of the turnover in state.
It is expedient to mention that there is no specific penalty laid down in the GST enactment for
not getting the accounts audited and furnishing the reconciliation statement thereof.
Therefore, the provision of section 125 i.e. general penalty may become applicable
amounting to Rs. 25,000/- under the CGST Act, 2017. Thus, the effective general penalty
may extend upto Rs. 50,000/-.

.FORM GSTR-9C
See rule 80(3)
1. PART – A - Reconciliation Statement
On the common portal, currently, the option for preparing the reconciliation statement has
been enabled but it cannot be prepared online. The offline utility has been made accessible.
Further, it is mandatory to file GSTR 9 prior to filling details in GSTR 9C on the common
portal. The clause wise analysis of the reconciliation statement is as under:
I. Part I – Basic Details
a. Clause 1 -Financial Year

The reference to current financial year in this statement is July 2017 to March 2018 for which
reconciliation statement is being prepared.
b. Clause 2 -GSTIN
GSTIN of the registered person whose accounts are audited to be furnished
c. Clause 3A - Legal Name:
Legal Name for the GSTIN shall be auto populated after entering GSTIN. Assessee needs to
re-validate the details so auto populated.
d. Clause 3B -Trade Name (if any):
Trade Name for the GSTIN shall be auto populated after entering GSTIN. Assessee needs to
re-validate the details so auto populated.
e. Clause 4 - Are you liable for audit under any Act?
The provision in section 35(5) envisages for the requirement of the auditing of accounts and
submission of the same with the reconciliation statement. In case, his accounts are not audited
under any law, then audit is required to be conducted under the GST law. Further, in case the
assessee is required to get his accounts audited under any law being the Companies Act or
Income Tax Act, there is a need to mention in this clause the law under which accounts are
audited. It is also possible that an entity might be subject to audit under more than one statue.
So, the auditor may write the name of all such statues, in which audit has already been
conducted. In case, audit is not conducted under any other statue, the GST law mandates to

get the taxpayer his accounts audited provided his aggregate turnover in such financial year
exceeds the threshold of Rs. 2 Crores.
II. PART II - Reconciliation of Turnover declared in Audited Annual Financial
Statement with Turnover declared in Annual Return (GSTR 9):
Part II consists of reconciliation of the annual turnover declared in the audited Annual
Financial Statement with the turnover as declared in the Annual Return furnished in
FORM GSTR-9 for this GSTIN. Where the audit has been conducted by the auditor who is
not certifying the reconciliation statement that in such case, the GST auditor may have to rely
on the working of the erstwhile auditor. GST auditor is also required to pay special attention
to the observation or qualification of the auditor who has conducted the audit of registered
person under the law other than GST Law.
a. Table 5
Reconciliation of Gross Turnover:
This field requires reconciliation of the turnover on gross basis i.e. without considering
taxable and non-taxable supplies separately.
b. Clause 5A
Turnover (including exports) as per audited financial statements for the State / UT (For
multi-GSTIN units under same PAN the turnover shall be derived from the audited
Annual Financial Statement)

Instruction:
Table No. Instruction:
5A The turnover as per audited Annual Financial Statement shall be declared here.
There may be cases where multiple GSTINs (state wise) registrations exist on
the same PAN. This is common for persons/ entities with presence over
multiple states. Such persons/ entities, will have to internally derive their
GSTIN wise turnover and declare the same here. This shall include export
turnover (if any). It may be noted that reference to books of accounts in case of
persons / entities having presence over multiple states.
 The instruction - provides for deriving the state wise Trial Balance for those who have
presence in more than one state. However, it will be a challenge to rely on the turnover
for the state for entities having multi presence on PAN India basis.
 In case of entities having multiple presence across India, it will be prudent for the auditor
to derive correct turnover for the Branch. It might be possible that multiple auditors
engaged in the audit of branches of such entity, in that case it will be the joint
responsibility of all the auditors to derive the correct turnover in order to conduct audit.
 It is to be noted that the details of the turnover must be disclosed on Gross basis i.e.
before deduction on account of discounts. Trade discounts would be adjusted later in
subsequent fields.
 Though the given form shall be prepared only for 9 months but turnover for the year i.e.
from April 2017 to March 2018 should be reported here. The starting point should not be
from July 2017.
 Following documents can be obtained by the auditor for the purpose of turnover:
o Audited financial statements for the financial year to derive the total turnover of the
registered person;
o Registrant wise Trial Balance for getting the figure to be filled in column 5A.
o Communication with other auditors to reconcile the turnover with that of audited
financial statements.
o Income Tax Returns
Contentious Issue(s):
Whether Turnover as per audited Financial Statements in Clause 5A should include incomes
other than Revenue from operations?
There are divergent views whether only Revenue from operations should be reported in this
Clause or total revenue including other income should be reported. Such conflict arises for
the reason that revenue from the perspective of generally accepted accounting principle is
different than the revenue as envisaged under GST in context of supply.
Auditor’s Note:
− In cases where the auditor is not able to rely of the figures appearing in books of
accounts, the auditor may obtain a MRL (Management Representation Letter) from

the auditee mentioning that the figures appearing in the unaudited books of accounts are
true and correct. Thereafter it can rely on the figures appearing in the unaudited books of
accounts of the auditee.
− According to common accounting parlance, the term turnover is construed as the
Revenue from operations and therefore it seems logical to report only Revenue from
Operations in Clause 5A and report other incomes as adjustments.
c. Clause 5B - Unbilled Revenue at the beginning of the financial year (+)

Instruction:
Table No.
5B Unbilled revenue which was recorded in the books of accounts on the basis of
accrual system of accounting in the last financial year and was carried forward
to the current financial year shall be declared here. In other words, when GST
is payable during the financial year on such revenue (Which was recognized
earlier), the value of such revenue shall be declared here.
(For Example, if Rupees Ten Crores of unbilled revenue existed for the
financial year 2016-17, and during the current financial year, GST was paid on
rupees four crores of such revenue, the value of rupees four crores rupees shall
be declared here)
 There may be instances where revenue is recognized in the books of accounts, but
invoice has not been raised as Time Of Supply (TOS) according to GST law has not
arisen in such cases. So unbilled revenue at the beginning of July, 2017 should be
added in this field.
Not to be included:
- Unbilled revenue at the beginning of April 2017 should not be disclosed here in cases
where invoice for such unbilled revenue has been raised in Pre-GST Regime. As the
financial year for the purpose of 2017-18 is deemed to be from July 2017 to March
2018.
- Unbilled revenue at the beginning for which invoice has not been issued in the current
financial year, would not be entered into this column.
d. Clause 5C - Unadjusted Advances at the end of the Financial Year (+)

Instruction:
Table No.
5C Value of all advances for which GST has been paid but the same has not been
recognized as revenue in the audited financial statement shall be declared here.
 The liability to pay tax arises in accordance with the provision of time of supply as
envisaged under section 12 (for supply of goods) or section 13 (for supply of services), as
the case may be. The liability arises on the earlier of receipt of advance or raising of
invoice.
 However, it may be noted that in case of supply of goods, liability to pay tax on advances
prevailed upto 14.11.2017 for assessees having turnover more than 1.5 crore in preceding

financial year. Similarly, for assessees whose turnover was upto 1.5 crore, the liability of
paying taxes on advance prevailed upto 12.10.2017. Accordingly, currently, liability to
pay taxes on advance is applicable only in case of services.
 Hence, where invoice has not been raised for receipt of advance has to be reported in this
column.
 Advances which are received in current Financial Year and Invoice for which have been
raised in subsequent Financial Year shall be reported in this column.
 Partial adjustment of advances with the invoice in subsequent FY would also be reported
in this column.
Not to be included:
 Adjustment of advances with the invoice in current financial year would not be reported in
this column.
 Such advances, which were received during pre GST regime, and invoice for the same has
been raised in GST regime shall not be entered into this column.
 Advances, on which tax was liable to be paid, but has not been paid erroneously by the
taxpayer is not required to be reported in this column.
 Advances received on export supplies on which no tax paid shall not be included in this
column.
 Deposits and Financial Advances will not form part of this information.
Reference in Financials/ Returns:
 Auditor can obtain information from various sources i.e. in case the liability to pay
GST is separately accounted for and adjusted in books of accounts, then the details
can be taken from the books of accounts.
 The information can be obtained from column 4F of the GSTR 9.
 The details of advance is separately disclosed in Column 11A(1) & (2) of GSTR 1
and details of adjustment of advances is disclosed in column 11B(1) & (2).
Accordingly value of unadjusted advances can be derived by deducting values in
column 11B from column 11A and can be reported in this column.
e. Clause 5D - Deemed Supplies under Schedule I (+)

Instruction:
Table No.
5D Aggregate value of deemed supplies under Schedule I of CGST Act, 2017 shall
be declared here. Any deemed supply which is already part of the turnover
declared in the audited Annual Financial Statement is not required to be
included here.
 In terms of provision of section 7, supplies inferred by Schedule I are constituted as
deemed supplies, whereby such supplies are liable to levy of tax even when there is no
consideration.
 The following transaction would be covered in this column:

- Permanent Transfer/ Disposal of Business Asset where ITC has been availed
- Supplies between related/ distinct person without consideration such as stock
transfers
- Supply of Goods between principal to his agent or vice versa
- Import of services from related person/ establishment outside India
Not to be included:
 Import of services for consideration, which have already been recognized in the books
of accounts along with financial statements would not be required to be reported in
this column.
 Supplies which have been recognized in audited financial statements as revenue
would not be added again.
The ambiguous issue is that whether the auditor is required to assess the deemed supplies
which are neither reported in books nor in GST Returns. Is it a responsibility of the auditor to
identify any supply beyond books of accounts or GSTR-9 while certifying FORM GSTR-9C.
From the perspective of reporting in Form 9C, a view can be taken that transactions which
are neither recorded in books of accounts and monthly GSTR, need no reporting in
reconciliation statement only. After all since reconciliation is a journey between start point to
end point and when nothing is part of both sides, then adding an unnecessary un-reconciling
item shall be incorrect. The auditor may consider reporting same in Part-B i.e. certification
under the observation/ qualification. He may not insist the taxpayer to pay taxes, as taxpayer
may have different view or managerial decision with regard to such supply. The auditor
cannot step into the shoes of the adjudicating authority for such supplies and payment of
taxes thereon.
Reference in Financials/ Others:
 In case accounting has been done cost center wise, in such case, the details of deemed
supplies between distinct person can be identified through inter branch adjustment
accounts.
 The details for employer employee transaction can be obtained through the
appointment letters.
 The expenditure can be explored into in order to identify such expenses which are
incurred for the distinct or related person.
 GSTR 1 may be helpful in extracting details to distinct person or related person
through GSTIN wise details from B2B column.
f. Clause 5E - Credit notes issued after the end of the Financial Year but reflected in
Annual Return (-)
Instruction:
Table No.
5E Aggregate value of credit notes which were issued after 31st of March for any

supply accounted in current financial year but such credit notes were reflected
in the annual return (GSTR 9) shall be declared here.
 Credit notes which are declared after 31st March of the relevant FY, but upto the month of
September of the next FY, are required to be declared here. It is expedient to mention that
all such credit notes which are declared through amendments would also be declared here.
 It is uncommon, for credit notes dated beyond 1st April 2018 to be given effect in the
financial accounts.
Not to be included:
There is no requirement to disclose or adjust the details of debit note issued after the end
of FY.
g. Clause 5F
Trade Discount accounted for in audited Annual Financial Statement but are not
permissible under GST. (+)
5F Trade discounts which are accounted for in the audited Annual financial
statement but on which GST was leviable (being not permissible) shall be
declared here.
 Details of trade discount given in the normal course of business, but are not permissible to
be deductible from the value of supply for the sake of non-compliance of condition of
reduction as envisaged in sec. 15(3) must be added here.
Not to be included:
 Discounts which are shown on the face of invoice will not form part of this column, as
such discounts are allowable to be included in the value of supply in terms of provision of
section 15(3) of CGST Act, 2017
Might be included:
 Cash Discount/ Volume discounts might be included here in this column, as there is no
any other column in the reconciliation statement to deduct such value of discounts.
h. Clause 5G - Turnover from April 2017 to June 2017 (-)

Instruction:
Table No.
5G Turnover included in the audited Annual Financial Statement for April 2017 to
June 2017 shall be declared here.
Turnovers forming part of the tax periods 01.04.2017 to 30.06.2017 which were liable to tax
under the erstwhile laws as per the provision relating to the point of taxation rules should be
deducted from the turnover.
Auditor’s Value Addition:
To reach to a correct value, the term turnover should be read as invoices issued for the period
of April 2017 to June 2017 on which no GST has been charged. The temporary provisions

made between April 2017 to June 2017 which are subsequently reversed in July 2017 or at
later period in the year should not be considered.
Another documents which can be referred by the auditor are service tax return, excise return
and VAT returns furnished by the taxpayer. Again in case of entities having centralized
registration, it will be imperative for auditor to get the figures of turnover for the subject
period state wise.
i. Clause 5H - Unbilled Revenue at end of Financial Year (-)

Instruction:
Table No.
5H Unbilled revenue which was recorded in the books of accounts on the basis of
accrual system of accounting during the current financial year but GST was not
payable on such revenue in the audited Annual Financial Statement shall be
declared here.
According to the accounting standards it is possible that criteria for recognition of revenue
has been complied with, but TOS is still to arrive, meaning thereby, invoice has not been
raised. In such cases, since invoice in respect of such revenue shall be raised in current FY
and revenue has already been recognized in books of accounts, accordingly it shall be
deducted so as to arrive at the value of supplies declared in GST returns.
Reference from Financials:
The Unbilled revenue can be obtained from the notes of accounts of the financial statements
or from the head of debtors.
j.Clause 5I - Unadjusted advances at the beginning of the Financial Year. (-)

Instruction:
Table No.
5I Value of all advances for which GST has not been paid but the same has been
recognized as revenue in the audited Annual Financial Statement shall be
declared here.
 The liability to pay tax in GST arises according to provision of sec. 12 & 13. However, it
may be noted that liability to pay tax in case of goods was there till 12.10.2017, after that
the same was exempted for taxpayers whose turnover was upto Rs. 1.5 Cr, which was
further relaxed for all taxpayers supplying goods w.e.f. 15.11.2017.
 Only such advances, where GST has been paid and no invoice has been raised in such
financial year would be reduced here.
 The detail can also be extracted from Table 4F of GSTR 9.
 Column 11A and 11B of GSTR 1 would also be helpful in extracting details of such
advances.
Not to be included:
 In case of supplies on which GST is paid on the basis of advance and invoice has also
been raised in the same financial year would not be deducted.

 Since, GST was implemented from the middle of the year, so there may be some
unadjusted advances on 01.04.2017, such advances would not be considered here, as there
was no implication of GST on such advances.
k. Clause 5J - Credit notes accounted for in the audited Annual Financial
Statement but are not permissible under GST. (+)
Instruction:
Table No.
5J Aggregate value of credit notes which have been accounted for in the audited
Annual Financial Statement but were not admissible under section 34 of the
CGST Act shall be declared here.
 Credit notes are raised in terms of section 34 of CGST Act, 2017 for the purpose of
reduction in the output tax liability and only the said credit notes are permissible under
GST.
 On the other hand, in Industry, there is trend of raising commercial credit/ debit notes so
as to give the effect of the same into financial statements. It is expedient to mention that
such credit notes does not affect the tax liability of the taxpayer in any manner and
accordingly, such credit notes are not permissible in GST.Hence, differences on account
of such credit notes which are raised for commercial purpose would be added in order to
arrive at the turnover as declared in the GSTR 9.
 Segregation of adjustments to turnover on account of credit note with GST and without
GST has to be done carefully.
Not to be included:
 Credit notes raised in terms of sec. 34 which reduce the output tax liability would not be
reported here.
l. Clause 5K - Adjustments on account of supply of goods by SEZ units to DTA units

(-)
Instruction:
Table No.
5K Aggregate value of all goods supplied by SEZs to DTA units for which the
DTA units have filed bill of entry shall be declared here.
 It is worthwhile to note that supply of goods by SEZ units into DTA Units are treated as
import of goods as premises of SEZ units are treated to be outside the taxable territory
according to SEZ Act. Accordingly such supplies would not be reported by the SEZ units
in to Column 4A of GSTR 1. Further, the same shall be recorded by recipient units as
import of goods under the cover of bill of entry.
 This transaction would be a sale for the purpose of financial statement of SEZ unit but
would not be considered as supply for GST purposes and hence needs to be deducted
from the turnover of financial statement for the purpose of arriving at the turnover as per
GSTR 9.

Not to be included:
 It is pertinent to note here that only SUPPLY OF GOODS is covered by this entry as
supply of services by SEZ units are to be treated at par with any other supply and SEZ
units are required to discharge liability of tax on such supplies.
 Transaction where bill of entry is filed by the SEZ unit on authorization from the DTA
unit, will be outward supply or sale for the purpose of financial statement of the SEZ
unit and inward supply for purposes of GST. Thus, this will not be included in the
information in column 5K.
m. Clause 5L - Turnover for the period under composition scheme (-)

Instruction:
Table No.
5L There may be cases where registered persons might have opted out of the
composition scheme during the current financial year. Their turnover as per the
audited Annual Financial statement would include turnover both as
composition taxpayer as well as normal taxpayer. Therefore, the turnover for
which GST was paid under the composition scheme shall be declared here.
 Due to limit of the turnover as inferred by provision of sec. 10 of CGST Act, there may
be taxpayers who would have shifted from composition to normal tax scheme. So in
such cases, the turnover during the period of composition would be reduced here so as
to arrive at taxable turnover.
 However, it may be noted that, there may be instances, where taxpayers would have
opted out of composition either due to ineligibility or voluntarily.
 A person registered under the composition scheme who has opted out of the scheme
should file both GSTR 9 and GSTR 9A as annual return.
 The following reconciliations be carried out for reporting correct values:
o Value as declared in the bill of supply and those declared in the books of accounts
o Value as declared in books of accounts and in GSTR 4
o Value of advances declared in the books of accounts and value as advances declared
in GSTR 4.
 During the course of preparation of GSTR 9C, if any outward supply is omitted in any
GSTR 4 pertaining to financial year 2017-18, a revision should be done. But
information pertaining to GSTR 4 cannot be made through GSTR 4 as the taxable
person has opted out of the composition. In that case the auditor is required to report
such observation in their report. Such turnover shall also form part of the unreconciled
turnover.
 Time of supply for the composition scheme includes advances received on supply of
goods but under the regular scheme advance received is excluded from time of supply.

n. Clause 5M - Adjustments in turnover under section 15 and rules there under
(+/-)
Instruction:
Table No.
5M There may be cases where the taxable value and invoice value differ due to
valuation principles under section 15 of the CGST Act, 2017 and rules there
under. Therefore, any difference between the turnover reported in Annual
Return (GSTR 9) and turnover reported in the audited Annual Financial
Statement due to difference in valuation of supplies shall be declared here.
 Sec. 15 defines the value of supply to be the transaction value where the price paid or
payable is the only monetary consideration and person are not related to each other. If
the said condition is not satisfied then valuation rules have to be referred.
 Any taxes, duties charged under any law for the time being in force, incidental expenses
to such supply, interest if linked to consideration shall form part of value of supply.
 Below mentioned transaction would attract special attention of the auditor:
o Transactions between related person
o Transactions between distinct person
o Supplies involving consideration in non-monetary terms
o Transaction in case of Money Changing Business, Air Travel Agency etc
o Transactions where some supplies are made by recipient to supplier to facilitate
supply
 Auditor may obtain following documents:
o Vendor contracts to understand the expectations from the supplier. Any free supplies
undertaken by the recipient which was the responsibility of the supplier would be
required to be included in the valuation.
o Outward invoices issued to the customers.
o Contracts of pure agent
o List of related and distinct person
Reference from Financials:
 Disclosures made in terms of AS 18 and IND AS 24 would help the auditor to
recognize the transaction with related parties and their values.
o. Clause 5N - Adjustment in turnover due to foreign exchange fluctuations (+/-)

Instruction:
Table No.
5N Any difference between the turnover reported in Annual Return (GSTR 9) and
turnover reported in the audited financial statements due to foreign exchange
fluctuations shall be declared here.
IND AS 21 or AS 11 “The effect of changes in Foreign exchange rates” laid down the
principles for treatment of fluctuation in financial statements on year ending

 Rule 34 of CGST Rule requires the value of taxable goods to be determined on the basis
of exchange rate notified under section 14 of the customs Act.
 The value of taxable services is to be determined on the basis of applicable rate of
exchange determined as per GAAP for the date of time of supply of such services in
terms of section 13 of the CGST Act.
 However, such fluctuation may affect the turnover to be reported in the financial
statements and difference may arise in the value of supply and revenue declared in the
financial statements. Accordingly, the difference on account of foreign exchange
fluctuation would be adjusted here in this column.
p. Clause 5O - Adjustment in turnover due to reasons not listed above. (+/-)

Instruction:
Table No.
5O Any difference between the turnover reported in the Annual Return (GSTR 9)
and turnover reported in audited Annual Financial Statement due to reasons not
listed above shall be declared here.
 Practically for given tab separate working papers shall be required to be kept and it
should include all those transactions which tantamount to difference in turnover as per
books of accounts and outward supplies in GSTR-1 but will not trigger any tax
liability. Further the reason for same should also be identified and is not a suspense
item.
 Some examples:
o Reporting on Profit and Loss on Sale of Capital Assets if made part of revenue
from operations.
o Reimbursement of expenses which are made part of Balance Sheet but on which
GST has been discharged
o Dividend, if made part of turnover reported under Table 5A.
o Goods which were purchased prior to 1-7-2017 and have been returned after 17-
2017.
o High Sea sales and Merchant Sales
o Notice pay recovery from employees, if considered as taxable supply by the
registered person but not reported in the statement of profit and loss account
o Goods sent on approval basis which have not been received back within 6 months
and are not reported in the financial statements.
o Inputs and capital goods sent for job work and received within the prescribed
period.

q. Clause 5P - Annual Turnover after adjustments as above
This column would be auto populated.
The figure which is arrived after making the adjustment in turnover as per the audited annual
financial statements in this column is termed as Annual Turnover after adjustments as above.
The turnover arrived shall comprise the following:
A) Taxable turnover of outward supply of goods/services
B) Exempt turnover of outward supply of goods/services
C) Non GST outward supplies turnover
D) Export of goods/services turnover
E) Outward supplies liable to GST under reverse charge mechanism.
The auto populated turnover arrived here ideally be the turnover to be declared in 5Q it the
turnover is reckoned in terms of the provision of the GST law and is declared appropriately in
GSTR 1 and GSTR 9. In the event of the difference, the same should be reconciled and the
reasons are to be mentioned in table 6.
r. Clause 5Q - Turnover as declared in Annual Return (GSTR 9)

Instruction:
Table No.
5Q Annual Turnover as declared in the Annual Return (GSTR 9) shall be declared
here. This turnover may be derived from Sr. No. 5N, 10 and 11 of Annual
Return (GSTR 9).
 Details in this column would be auto populated from Sr. No. 5N, 10 and 11 of Annual
return GSTR 9.
Where table 5N belongs to total turnover declared in returns filed during the financial
year.
 Table 10 and 11 belongs to supplies adjusted through amendments in returns of April
to Septembers in Table 9B and 9C of GSTR 1 for the invoices declared in returns
pertaining to July, 2017 to March, 2018 in
The aggregate of turnovers from the above tables will be the outward supplies effected by the
taxable person under the GST regime. It will not include inward supplies liable to reverse
charge.
s. Clause 5R - Un-Reconciled Turnover (Q-P)

Where there is difference between the turnover of GSTR 9 and financial statements as
adjusted above, the difference of the same shall be reflected in this column. There can be two
possibilities, one of them is turnover reported in 5P is higher than as reported in GSTR 9. In
that case, it might be possible that turnover is not reported. The value of taxable supplies
forming part of the difference should be declared in Part III SI No. 11 and the applicable
taxes should be paid. The difference in exempted supplies should be reported in SI No. 7B or
7C as the case may be.

Another possibility is that turnover in 5P may be lower than that of 5Q, the reason may be
that the turnover is erroneously reported higher in returns and therefore in GSTR 9.
t.Table 6 - Reasons for Un- Reconciled difference in Annual Gross Turnover

Instruction:
Table No.
6 Reasons for non- reconciliations between the annual turnover declared in the
audited Annual Financial Statement and turnover as declared in the Annual
Return (GSTR 9) shall be specified here.
Auditor’s Value Addition
Specific instances for reporting in given table can be as under:
1. Invoices/Debit notes not declared in the GSTR-1 and 3B both
2. Credit notes not declared in GSTR-1 and 3B both
3. Invoices cancelled in books of accounts after issue but credit note not issued in time
u. TABLE 7 - Reconciliation of Taxable Turnover

Instruction:
Table No.
7 The table provides for reconciliation of taxable turnover from the audited
annual turnover after adjustments with the taxable turnover declared in Annual
Return (GSTR 9) .
Once the reconciliation of above turnover is done on gross basis which may also include
certain exempt supplies or non-taxable supplies on which no tax is paid, in order to arrive at
reconciliation of taxable turnover, the below reconciliation would be performed:

v. Clause 7A - Annual Turnover after adjustments (from 5P above)
Instruction:
Table No.
7A Annual turnover as derived in Table 5P above would be auto populated here.
This figure shall be auto reflected.
w. Clause 7B - Value of exempted, Nil- Rated, Non-GST Supplies, No Supply

turnover
Instruction:
Table No.
7B Value of exempted, nil rated, non-GST and no-supply turnover shall be
declared here. This shall be reported net of credit notes, debit notes and
amendments if any.
 Exempted Supplies: Supplies which are leviable to GST but are exempted under section
11 or sec. 6 of IGST Act shall be reported here. Reference of Notification No. 02/2017
CTR dated 28.06.2017 as amended from time to time and notification No. 12/2017 CTR
dated 28.06.2017 as amended from time to time can be taken.
 Non-GST Supply: Supply of alcoholic liquor for human consumption and petroleum
products, if any would be reported here.
 No-Supply: This supplies has not been reported into any of the returns being GSTR 3B or
GSTR 1 as the case may be. But the reference has been made to Schedule III of CGST Act
and this would include sale of land, high sea sales transactions etc. The GSTR 9 also
requires the registered person to fill this figure in the said return.
It is mentioned again that these figures are to be reported on the basis of figure of exempted,
nil rated or non-GST Supplies as shown in the books of accounts. Since comparison shall be
made from Annual Return hence reporting in given tab should not be from GSTRs.
x. Clause 7C - Zero Rate Supplies without payment of tax

Instruction:
Table No.
7C Value of zero rated supplies (including supplies to SEZs) on which tax is not
paid shall be declared here. This shall be reported net of credit notes, debit
notes and amendments if any.
 Zero Rated Supplies which have been made under the cover of LUT are to be reported
here.
 In case of export of goods, the tax invoices are issued prior to the issuing of shipping
bill for entering goods into custom area. The recognition of revenue in the financial
statement would depend upon the terms of agreement with the buyer. In case of FOB
contracts the revenue is recognized on the date of actual shipment or filing of bill of
lading as the risk of title and ownership is transferred to the foreign buyer when the

goods are boarded on the conveyance. In case of CIF contracts the revenue is
recognized on the date of receipt of delivery by the foreign buyer. So the timing
difference may arise on the zero rated supplies, which auditor is required to pay
attention while arriving the figure to be reported in this column.
y. Clause 7D - Supplies on which Tax is to be paid by the recipient on Reverse

charge basis
Instruction:
Table No.
7D Value of reverse charge supplies on which tax is to be paid by the recipient
shall be declared here. This shall be reported net of credit notes, debit notes and
amendments if any.
The supplies under this column can be procured from returns into 2 categories-
1. Supplies subject to provision of section 9(3): i.e. GTA services, advocate services,
insurance agent services etc. and;
2. On the other hand, supplies subject to provision of section 9(4): i.e. inward supplies from
unregistered person. This provision was in force till 12.10.2017, so the care should be
taken, while extracting data for putting into this column.
z. Clause 7E - Taxable Turnover as per adjustments above (A-B-C-D)

Instruction:
Table No.
7E The taxable turnover is derived as the difference between the annual turnover
after adjustments declared in Table 7A above and the sum of all supplies
(Exempted, non GST, reverse charge etc.) declared in Table 7B, 7C and 7D
above.
This column would be auto calculated.
aa. Clause 7F - Taxable Turnover as per liability Declared in Annual Return (GSTR
9)
Instruction:
Table No.
7F Taxable turnover as declared in Table (4N-4G)+(10-11) of the Annual Return
(GSTR 9) Shall be declared here.
 Details for this column would be extracted from column 4N- 4G of GSTR 9, which
reflects the details of taxable turnover declared in return filed during the financial year.

Amount in Table 4G reflects the inward supplies liable to reverse charge. Thus, the same
shall not form part of the turnover.
It may be noted that this column does not contain the details of missed invoices pertaining to
the said relevant FY and such invoices are declared in the return from April 2018 to
September 2018. Also amendments reported in April 2018 to September 2018 are not
reported here. Hence any outward supply reported after March 2018 shall become part of
Table 4G.

bb. Clause 7G - Un-reconciled Taxable Turnover (F-E)
Where there is difference between the turnover of GSTR 9 and financial statements as
adjusted above, the difference of the same shall be reflected in this column.
cc. Table 8 - Reasons for Un-reconciled turnover

Instruction:
Table No.
8 Reasons for non-reconciliation between adjusted annual taxable turnover as
derived from 7E above and the taxable turnover declared in table 7F shall be
specified here.
Reasons for above un reconciliation would be disclosed in this column and may include
following reasons:
- Unreconciled turnover itself at column 5R
- Incorrect disclosure in any of the column of table 5 of GSTR 9C which is
considered as the base for further adjustments
- Incorrect disclosures in the annual return with respect to any turnover.
III. PART III - Reconciliation of Taxes paid
Part III Consist of reconciliation of tax payable as per declaration in the reconciliation
statement and the actual tax paid as declared in Annual Return (GSTR 9).
a. Table 9 - Reconciliation of Rate wise Liability and amount payable thereon

Instruction:
Table No.
9 The above provides for reconciliation of tax paid as per reconciliation statement
and amount of tax paid as declared in Annual Return (GSTR 9). Under the head
labelled “RC”, supplies where tax was paid on reverse charge basis by the
recipient (i.e. the person for whom reconciliation statement has been prepared)
shall be declared.
This table requires breakup of the tax liability based on the various rates of taxes and based
on the nature of tax i.e. forward charge & reverse charge. It shall help the auditor to
recommend in Part V of the GSTR 9C, the additional tax liability to be paid by the registered
person due to non-reconciliation of taxable value in the books of accounts and GSTR 9.

From the scheme of Table 9 it is clear that auditor is required to report the GST Rate Wise
dissected total Taxable Turnover calculated in Table 7E under Part II of Form GSTR 9C.
Hence the base values according to which reporting is to be done in Table 9 should be
Taxable Value as reported under Table 7E of Form GSTR 9C i.e. Adjusted Total Turnover
for the FY 2017-18 under GST and amount of tax (rate wise) should be derived
mathematically.

The details of adjusted Total Turnover needs to be broken down in accordance with GST
Rates based on the reports generated from books of accounts and necessary adjustments made
in Part II of GSTR-9C which have not impact in the books of accounts of the registered
person should also be considered rate wise for the purpose of finding the taxable value.
The base in given case should be Taxable Value only and the amount of tax shall be sub-set
and will be derived accordingly.
b. Clause 9L - Interest
 Where the person is liable to pay tax fails to pay tax within the due date to pay then
interest at specified rate shall be levied on the outstanding tax payable from
succeeding day of due date till the date of payment.
 In case of calculation of Interest under given column, the Rate Wise Taxable Value as
reported under column 2 of Table 9 should be further bifurcated month wise from July
2017 to March 2018. Only in such case after comparison of monthly tax liability
calculated accordingly with details of Tax paid reported in monthly GSTR-3B, the
correct amount of interest shall be calculated and reported.
c. Clause 9M - Late Fees

 Sec. 47 of CGST Act provides for levy of late fees if any person fails to file the
returns required u/s 37, 38, 39 by the due date. The details of Late fees shall be
reflected in this column.
 GSTR 1: Date for the same has been extended till 31stMarch 2019.
GSTR 3B: If tax liability exists, then in such case Late fees of Rs. 50 per day is liable
to be paid. In case of NIL returns Rs. 20 per day is liable to be paid. No late fees to be
paid if GSTR 3B for the period July, 2017 to March 2018 filed between 22.12.2018 to
31.03.2019.
d. Clause 9Q - Total amount paid as declared in Annual Return (GSTR 9)

Instruction:
Table No.
9Q The amount payable as declared in Table 9 of the Annual Return (GSTR 9)
shall be declared here. It should also contain any differential tax paid on Table
10 or 11 of the Annual Return (GSTR 9).
 Details of tax paid as declared in returns filed during the financial year along with
differential tax paid (As per column 14 of GSTR 9) on account of declaration of the
transactions for previous FY declared in returns of April to September of Current FY
or upto the date of filing of annual return of previous FY which ever is earlier shall be
declared here.
Not to be included:
 Amount of service tax paid or adjusted before June 2017 shall not form part of this
column.

 Once the frequency on which the data should be fetched for adjusted turnover is
decided, for purpose of Table 9, through books of accounts and related reports to be
generated, each of the such details should be further broken down under various GST
Rates to which it is mapped to in the books of accounts on monthly or yearly basis as
the case maybe.
 In case of deemed supplies under Schedule-I, there can be a situation that tax amount
in relation to said deemed supplies is becoming part of the Tax Liability Register but
might not be a part of overall turnover of the registered person in the books of
accounts. In such cases, if possible after tracking of such specific instances, the rate
wise taxable value of said transactions should be calculated either on the basis of
Invoice issued under Section 31 of the CGST Act 2017 and respective SGST Acts
2017 or can be calculated by reverse method. (i.e. calculating the value of taxable
supply from the rate of tax). Same shall be applicable in case where the adjustments
of Section 15 or valuation Rules is made for tax purpose.
 During the FY 2017-18 the rate of Tax on supply of goods and services have changed
many times. To keep a track of same, the updated consolidated rate notification is
hosted on the CBIC Website under the Tab GST Rates Ready Reckoner. The same
tracks down the dates on which the changes were brought in various clauses of the
Rate Notification. The same should be referred for identifying the Tax Rate changes
and its effect given by registered person in the books of account.
e. Table 10 - Reason of unreconciled payment of amount

10 Reasons for non-reconciliation between payable/ liability declared in Table 9P
above and the amount payable in Table 9Q shall be specified here.
 For each identified non reconciliation shall be, reason shall be provided. The reason
may result into additional tax liability for the taxpayer if there is any short payment of
tax.

The Auditor needs to identify the various reasons due to which there is some amount
reflected in Table 9R. The various reasons can be as under
a. Form GSTR 3B shows less/more tax paid
 Form GSTR 1 matches with the audited financials with regard to the tax payable
 Form GSTR 3B is having a difference as compared to the books of accounts with
regard to the tax paid.
In this situation, even though Table 6 and 8 may not show any differences as given in
point (i) above, but Table 10 will show a difference of the amount of tax to be paid and
tax actually paid.

So, any tax payable occurring due to this will automatically form part of Table 11 and
thereby auditor’s recommendations in Part V.
In case any excess tax is paid, no reporting shall be done in Table 11. There is no
provision of negative reporting in Table 11.
b. GSTR 1 and GSTR 3B inter se matching but not with Audited Financials
 Form GSTR 3B and GSTR-1 are matching with each other
 Matched GSTR-1 and GSTR-3B is different with regard to the audited financial
statements.
Such differences will be depicted under all the Table 6, 8 and 10 as such turnover if
lesser than audited financials may result in short payment of tax, if differences thereof
are not explained. The cause of the differences need to be clearly identified. Table 10
while taking the values after considering the audited financial statements will be
compared with the actual tax paid as per Form GSTR 3B. As there is a difference
between the audited financial statements and Form GSTR 3B, an unreconciled
difference will be shown in Table 10.
c. Taxable Turnover as per books matching in GSTR 1 and GSTR 3B but Tax is
not matching.
 Value of taxable supply in Form GSTR-3B matches with that in GSTR-1
 Tax payable as self-assessed in GSTR-3B is different from shown in GSTR-1.
The possible reason for same can be difference in classification of supply in GSTR 1
and GSTR 3B. The reporting shall be required in Table 10 only in such cases where
the error has occurred in Form GSTR-3B due to reasons of classification like as
following
• HSN Disputes
• GST Rate disputes
• Inter State vs Intra State Supply
• Place of Supply
• Type of Supply Dispute- Taxable, Exempt, Nil Rated
As the amount of Tax in Table 9P shall be calculated on the basis of turnover reported
which shall be treated as correct hence any deviation from same shall be disclosed in
Table 10.
f.Table 11 - Additional amount payable but not paid

Instruction:
Table No.
11 Any amount which is payable due to reasons specified under table 6, 8 and 10
above shall be declared here.
The amount in this column may not be greater than the reason in table 6, 8 and 10.

Reasons for un-reconciliation may be due to timing difference or due to a permanent
difference in Turnover as per Books of Accounts and GST Returns. However every un-
reconciliation might not lead to a situation where there is a requirement to pay tax on said
difference.
Few Examples where un-reconciliation is reported in Table 6 in Form GSTR-9C but shall
not require any additional tax payment are illustrated as under:
 Difference in Turnover where Time of Supply is postponed but revenue is recognized
in books of accounts (Supply between Developer and Landlord in light of Notification
No 04/2018-CT Rate)
 Difference in Value of Export Turnover reported in books of accounts on basis of
Invoice Value shown in Shipping Bill whereas Turnover reported in GSTR-1 on the
basis of Invoice prepared in INR on basis of Exchange Rate as applicable on date of
preparation of Invoice.
 Difference in Turnover of Services due to Tax paid on advances and shown in GSTR-
1 but not required to be disclosed as Turnover in Audited Financial Statements.
 Difference in Turnover due to disclosure of Profit / Loss on Sale of Fixed Assets in
Audited Financial Statements whereas disclosure of whole sale proceeds in GST
Returns.
In given cases, no reporting is required to be done in Table 11.
Further in other sets of un-reconciliations reported in Table 6, there shall be impact on the
Tax Liability to be paid. The instances for same shall principally cover such cases where
there is difference in Taxable Turnover in GST Returns and Adjusted Total Turnover.
These set of differences which shall have impact on Tax Liability shall actually be part of
Table 8 again.
However, out of such un-reconciliation filtered out and reported in Table 8, a further filter
of un-reconciliation shall be reported in Table 10 regarding Tax Liability which was
ought to be paid on un-reconciled turnover reported in Table 8, but same was not paid as
declared in GSTR-9 i.e. Annual Return.
Since Table 11 requires the disclosure of Additional Tax Liability payable and not paid
on un-reconciliations, it is evident that such details shall be reported in Table 10 also.
IV. PART IV - Reconciliation of Input Tax Credit (ITC)

a. Table-12 - Reconciliation of Net Input Tax Credit

b. Clause 12A
ITC availed as per audited Annual Financial Statement for the State/ UT (For multi-
GSTIN units under same PAN this should be derived from books of accounts)
12A ITC availed (after reversals) as per the audited Annual Financial Statement
shall be declared here. There may be cases where multiple GSTINs (state wise)
registrations exist on the same PAN. This is common for person/ entities with
presence over multiple states. Such persons/entities, will have to internally
derive their ITC for each individual GSTIN and declare the same here. It may
be noted that reference to audited Annual Financial Statement includes
reference to books of accounts in case of persons/ entities having presence over
multiple states.
ITC availed during July 2017 - March 2018 as per the audited Annual Financial Statements
net of reversals, if any to be reported here.
Shall not come: Balance of cenvat credit transferred to ITC ledgers during the FY 2017-18
in the books of accounts as it is to be specifically instructed to be included in Clause 12B.
• In cases where the auditor is not able to rely of the figures appearing in books of
accounts, the auditor may obtain a MRL (Management Representation Letter)
from the auditee mentioning that the figures appearing in the unaudited books of
accounts are true and correct. Thereafter it can rely on the figures appearing in the
unaudited books of accounts of the auditee.
c. Clause 12B
ITC booked in earlier Financial Years claimed in current Financial Year

12B Any ITC which was booked in the audited Annual Financial Statement of
earlier financial year(s) but availed in the ITC ledger in the financial year for
which the reconciliation statement is being filed shall be declared here. This
shall include transitional credit which was booked in earlier years but availed
during Financial Year 2017-18.

• Since the FY 2017-18 being the historic year of implementation of GST, there may not be
any instance particularly in this year as the ITC was booked in the audited annual FS in
the earlier financial year(s) and availed in the ITC ledger in the FY 2017-18 except for the
transitional credits.
• Transitional credit claimed in terms of section 140(1), 140(2), 140(5), 140(8) and 140(9)
shall be declared here.
Contentious Issues:
• Since the heading of clause 12B requires to report only those ITC which have been
booked in previous FY but claimed in current FY, there may be few instances in
transitional credits (listed below) which would not have been booked in the previous FY
in the books and hence should not be reported here also inspite of the fact that the
instruction provided for this clause requires to add transitional credits here.
a) Section 140(3): This provision provides for Credit of taxes paid in erstwhile law, but
was not available as credit to the taxpayer, which has now been made available as
transitional credit to taxpayers. Since the ITC in relation to such inputs or input
services were never booked in earlier FY, reporting of the same in this table seems
uncertain.
b) Section 140(4): Where a registered person was engaged in manufacture of exempted
goods or in providing exempted services which are liable to tax under GST, it shall be
entitled to take the credit of the amount of CENVAT credit of eligible duties in
respect of inputs held in stock and inputs contained in semi-finished or finished goods
held in stock on the appointed day, relating to such exempted goods or services. Since
the ITC in relation to such inputs or input services were never booked in earlier FY,
reporting of the same in this table seems unsure.
c) Section 140(6): The taxpayers who were under the composition scheme under the
erstwhile laws and migrated as normal taxpayers in GST regime, they were allowed
the credit of duties contained in their stock.
d. Clause 12C
ITC booked in current Financial Year to be claimed in subsequent Financial Years
Instruction:
Table No.
12C Any ITC which has been booked in the audited Annual Financial Statement
of the current financial year but the same has not been credited to the ITC

ledger for the said financial year shall be declared here.
Auditor’s Note:
Possible instances where ITC can be booked in current FY to be claimed in subsequent
FY:
Long term service agreements
Omissions in claiming ITC in the GST returns till the date of filing of March 2018 GSTR-
3B.
e. Clause 12D
ITC availed as per audited financial statements or books of account
12D ITC availed as per audited Annual Financial Statement or books of accounts as
derived from values declared in Table 12A, 12B and 12C above will be auto-
populated here.
[12D = 12A + 12B - 12C]
f.Clause 12E - ITC claimed in Annual Return (GSTR9)

Instruction:
Table No.
12E Net ITC available for utilization as declared in Table 7J of annual return
(GSTR 9) shall be declared here.
The figure in this clause is to be picked from Table 7J of Form GSTR-9.

Contentious Issue: Table 7J of Form GSTR-3B contains only that information of ITC which
has been claimed or reversed during the period July-March 2018. That it does not take into
effect ITC availed in GSTR-3B during April – September 2018 or during October – March
2019 pursuant to ROD-2 dated 31.12.2018 or the ITC reversed in GSTR-3B during April –
September 2018 pertaining to ITC of 2017-18. On the contrary, the figures being reflected in
Tables 12A, 12B, 12C are the final figures pertaining to 2017-18. Thus, this would always lead
to a situation where there would be difference in the Net ITC reconciliation.
Auditor’s Note: Table 7J of Form GSTR-9 contains only the details of ITC availed in GSTR-
3B during the period July-March 2018, transitional credits, credits claimed through ITC-01 &
ITC-03, reversals thereof done during July-March 2018. Hence, the auditor is advised to also
take into account the net impact of Table 12 & 13 of Form GSTR-9 while punching the figure
in this clause, failing which there shall always be unreconciled difference in ITC in
reconciliation statement.

g. Clause 12F - Un-reconciled ITC
No instruction provided for this clause in Form GSTR-9C.
This amount in this clause seems to be auto-calculated on the basis of figures appearing in
Table 12D & 12E.
h. Table13 - Reasons for un-reconciled difference in ITC

Instruction:
Table No.
13 Reasons for non-reconciliation of ITC as per audited Annual Financial
Statement or books of account (Table 12D) and the net ITC (Table12E)
appearing in the Annual Return (GSTR9) shall be specified here.
Important point to note here is that the reasons for such difference is not required to be
quantified in this table.
i. Table 14 - Reconciliation of ITC declared in Annual Return (GSTR9) with ITC

availed on expenses as per audited Annual Financial Statement or books of account
14 This table is for reconciliation of ITC declared in the Annual Return (GSTR9)
against the expenses booked in the audited Annual Financial Statement
orbooks of account. The various sub-heads specified under this table are
general expenses in the audited Annual Financial Statement or books of
account onwhich ITC may or may not be available. Further, this is only an
indicative list of heads under which expenses are generally booked.
Taxpayers may add or delete any of these heads but all heads of expenses
on which GST has been paid / was payable are to be declared here.

Auditor’s Note:
• This tables does the reconciliation of Net ITC (ITC availed less reversals) appearing in
Form GSTR-9 in Table 7J vis-à-vis the ITC booked in the books of accounts expense
wise. All such expenses on which GST is paid or payable are required to be reported in
this table.
• This table requires expense wise reporting of total ITC and eligible ITC.
• Since this table does the reconciliation of aggregate amount of eligible ITC reported in
Column 4 with the Net ITC (Total ITC availed less reversals) appearing in Form GSTR-
9, so the amount required to be reported in column 2 under “Amount of Total ITC”
should although be net of reversals but should be summation of eligible as well as
ineligible credits.

• The auditor needs to apply the ratio of reversals computed under Rule 42 & 43 for the
ITC availed in respect of each such expenditure and compute the amount of total and
eligible ITC separately net of reversals.
• Any such expense which is not taxable under GST or on which no tax is paid or payable
need not be reported here.
• Both direct and indirect expenses shall be covered here.
j.Table 15 - Reasons for un-reconciled difference in ITC
Instruction:
15 Reasons for non-reconciliation between ITC availed on the various

expenses declared in Table 14R and ITC declared in Table 14S shall be
specified here.
Important point to note here is that the reasons for such difference is not required to be
quantified in this table.
k. Table 16 - Tax payable on un-reconciled difference in ITC (due to reasons
specified in 13 and 15 above)
Instruction:
Table No.
16 Any amount which is payable due to reasons specified in Table 13 and
15above shall be declared here.
Auditor’s Note:
The reasons for the differences reported in Table 13 & 15 need to be considered here to
identify if any tax is payable on account of such differences which shall then be required to
be paid in cash.

V. Part V - Auditor’s Recommendation on Additional Liability due to Non-
Reconciliation
 The reconciliation statement is required to be certified by the chartered accountant or a

cost accountant. Therefore, once reconciliation statement is drawn up by the auditor and
after noticing the non-reconciled differences in the turnover, ITC etc he needs to provide
his recommendation on these differences observed and the tax payable in cash there on
has to be disclosed.
Auditor is required to recommend about following:
- If there is any amount to be paid for supplies not disclosed in GSTR 9.
- Details of erroneous refund.
- Any other outstanding demand.

 The auditor needs to exercise his professional diligence, skill, legal knowledge and care
in determining any additional tax liability which is payable by the registered person. The
registered person has the option to accept, reject or partially reject the recommended
additional tax liability.
Auditors are advised to give their membership number without prefixing ‘0’ in their
membership number.
Issues:
 Option of paying liability is with the assessee whereas the auditor can only
recommend regarding payment of tax liability, if any.
 The amount has to be paid in cash only and no other option is available in GSTR 9C.
Here once, the auditor completes the reconciliation statement, he needs to certify the truth
and correctness of such reconciliation statement. Further after amendment in GSTR 9C
format has been made on 31.12 2018 which requires the taxpayer to give his verification for
the facts contained therein prior to furnishing the reconciliation statement.

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Central India Regional Council

The Institute of Chartered Accountants of India

Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 1

First Edition : July, 2019

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We at CIRC is proactively & continuously working towards furtherance of profession and

Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 3

It is a matter of pleasure and opportunity to serve for the professionas Co-

Jai Hind ..Jai ICAI !!

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CA Shashank Gupta is a practicing Chartered Accountant & is also a Lawyer by qualification.

CA Yash Dadha is a practicing Chartered Accountant and is a fellow member of ICAI. He

CA Raghav Dangayach is a practicing Chartered Accountant and has an experience of Indirect

Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 5

Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 6

Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 7

2. Relevant Provisions of GST Act(s) and Rules

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3. What is the time limit to file Annual Return?

4. Consequences of failure to submit the annual return

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Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 10

1. Check Points to be considered before filing Form GSTR-9 (Annual Return)

2. Important amendments having impact on Annual Return

(Relevant for Input Tax Credit)

(Relevant for Outward Supplies, particularly GSTR-1)

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1. Part I – Basic Details

The given part of the Form is divided in two Tables:

Table 4 (Turnover and Liability Table)

Clause 4A: Supplies made to un-registered persons (B2C)

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Reference Table of GSTR-3B: Table 3.1(d) of FORM GSTR-3B

g. Table 4 – Clause I and Clause J

Instruction:Aggregate value of credit notes/debit notes issued in respect of B to B supplies

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h. Table 4 – Clause K and Clause L

Clause-wise Cross referencing of GSTR-9 and GSTR-1

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Background Material on Annual Return & GST Audit http://www.circ-icai.org/ Page 18

Source of GSTR-9 – GSTR-3B or GSTR-1?

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Further, Instruction 7 provides that Part V consists of particulars of

2. Red Alert on variation in auto-populated figures more than 20%

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Clarified by council that it may be noted that auto-population is a functionality provided to

3. Disjunct between GSTR-1 and GSTR-3B – Impact on reporting in GSTR-9

j. Table 5 (Turnover without liability)

Clause 5A - Zero rated supply (Export) without payment of tax

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l. Clause 5D, 5E and 5F

The value of no supply shall be declared under Non-GST supply (5F).

In clause5D, the taxpayer is expected to furnish information in relation to supplies on

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Instances of transactions which can be categorized as no supply on the basis of general

• Services by employee to employer in course of employment

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3. Part – III - Details of ITC for the Financial Year

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Source: Table 4(A)(5) of Form GSTR-3B.