All about Relaxation in GSTR 9 & 9C for F.Y. 2019-20

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Under GST, every registered person who are supplying goods or services or both are required to furnish an annual return (GSTR 9 and GSTR 9C) for every financial year electronically on or before the 31st December following the end of such financial year. Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person are not required to filed annual returns.

For Financial Year 2019-20, government has extended the due date of GSTR 9 from 31-12-2020 to 28-02-2021 – Notification No. 95/2020 – Central Tax dated 30-12-2020.

Government had made optional to file GSTR 9 for the taxpayers having aggregate turnover up to 2 crore rupees for Financial Year 2019-20 – Notification No. 77/2020 – Central Tax dated 15-10-2020.

Thus, GSTR 9 for F.Y. 2019-20 is mandatorily required to file by registered taxpayers supplying goods or services or both only when their aggregate turnover during the financial year exceeds 2 crore rupees.

For F.Y. 2019-20, only the taxpayers whose aggregate turnover exceeds 5 crore rupees are required to get their accounts audited and furnish copy of audited annual accounts and a reconciliation statement, duly certified, in FORM GSTR-9C – Notification No. 79/2020 – Central Tax dated 15-10-2020.

Thus, GSTR 9C for F.Y. 2019-20 is mandatorily required to file by registered taxpayers supplying goods or services or both only when their aggregate turnover during the financial year exceeds 5 crore rupees.

 

Specific provisions regarding 9C for Foreign Airlines

Foreign companies which are airlines company covered under the notification issued under sub-section (1) of section 381 of the Companies Act, 2013 and who have complied with the sub-rule (2) of rule 4 of the Companies (Registration of Foreign Companies) Rules, 2014, are not required to file GSTR 9C if they furnish statement of receipts and payments for the financial year in respect of its Indian Business operations, duly authenticated by a practicing Chartered Accountant in India or a firm or a Limited Liability Partnership of practicing Chartered Accountants in India is submitted for each GSTIN before 30th September of the year succeeding the financial year. – Notification No.09/2020– Central Tax dated 16-03-2020.

 

GSTR 9 and GSTR 9C for F.Y. 2019-20

Government has notified GSTR 9 and GSTR 9C for F.Y. 2019-20 via Notification No. 79/2020- Central Tax dated 15th November 2020. There are certain changes in the relaxations provided for F.Y. 2019-20 from relaxations provided in F.Y. 2018-19. Detailed comparison of relaxations provided in GSTR 9 of F.Y. 2019-20 with GSTR 9 for F.Y. 2018-19 is provided as under

Particulars

F.Y. 2018-19 F.Y. 2019-20 Comments
Table 4 The registered person shall have an option to fill Table 4B to Table 4E net of credit notes in case there is any difficulty in reporting such details separately in Table 4. The registered person shall have an option to fill Table 4B to Table 4E net of credit notes, debit notes and amendments in case there is any difficulty in reporting such details separately in Table 4. No Change.
Table 5D to 5F The registered person shall have an option to either separately report his supplies as exempted, nil  rated and Non-GST supply or report consolidated information for all these three heads in the “exempted” row only. The registered person shall have an option to either separately report his supplies as exempted, nil rated and Non-GST supply or report consolidated information for all these three heads in the  “exempted” row only. No Change.
5H The registered person shall have an option to fill Table 5A to Table 5F net of credit notes in case there is any difficulty in reporting such details separately in Table 5. The registered person shall have an option to fill Table 5A to Table 5F net of credit notes in case there is any difficulty in reporting such details separately in Table 5. No Change.
5I The registered person shall have an option to fill Table 5A to Table 5F net of debit notes in case there is any difficulty in reporting such details separately in Table 5. The registered person shall have an option to fill Table 5A to Table 5F net of debit notes in case there is any difficulty in reporting such details separately in Table 5. No Change.
5J & 5K The registered person shall have an option to fill Table 5A to Table 5F net of amendments in case there is any difficulty in reporting such details separately in Table 5. The registered person shall have an option to fill Table 5A to Table 5F net of amendments in case there is any difficulty in reporting such details separately in Table 5. No Change.
Table 6B The registered person shall have an option to either report the breakup of input tax credit as inputs, capital goods and input services or report the entire input tax credit under the “inputs” row only. The registered person shall report the breakup of input tax credit as capital goods and have an option to either report the breakup of the remaining amount as inputs and input services or report the entire remaining amount under the “inputs” row only For F.Y. 2019-20, there is an additional exercise to be done by taxpayers to make breakup of their ITC as capital goods and other.

 

[Such requirement may have been inserted due to different reversal treatment required for ITC of inputs/ input services and of capital goods]

Table 6C and 6D The registered person shall have an option to either report the breakup of input tax credit as inputs, capital goods and input services or report the entire input tax credit under the “inputs” row only.

 

The registered person shall have an option

to either report Table 6C and Table 6D separately or report the consolidated details

of Table 6C and 6D in Table 6D only.

The registered person shall report the breakup of input tax credit as capital goods and have an option to either report the breakup of the remaining amount as inputs and input services or report the entire remaining amount under

the “inputs” row only.

 

The registered person shall have an option

to either report Table 6C and Table 6D separately or report the consolidated details

of Table 6C and 6D in Table 6D only.

Table 6E The registered person shall have an option to either report the breakup of input tax credit as inputs and capital goods or report the entire input tax credit under the “inputs” row only. The registered person shall report the breakup of input tax credit as capital goods and have an option to either report the breakup of the remaining amount as inputs and input services or report the entire remaining amount under the “inputs” row only. For F.Y. 2019-20, there is an additional exercise to be done by taxpayers to make breakup of their ITC as capital goods and other.

 

[Such requirement may have been inserted due to different reversal treatment required for ITC of inputs/ input services and of capital goods]

 

It is to be noted that Table 6E is for Import of goods, however for F.Y. 2019-20, Government has mentioned breakup of remaining amount as inputs and input services. However, in case of Table 6E, it should be only inputs.

Table 7A, 7B, 7C, 7C, 7D, 7E, 7F, 7G and 7H The registered person shall have an option to either fill his information on reversals separately in Table 7A to 7E or report the entire amount of reversal under Table 7H only. However, reversals on account of TRAN-1 credit (Table 7F) and TRAN-2 (Table 7G) are to be mandatorily reported. The registered person shall have an option to either fill his information on reversals separately in Table 7A to 7E or report the entire amount of reversal under Table 7H only. However, reversals on account of TRAN-1 credit (Table 7F) and TRAN-2 (Table 7G) are to be mandatorily reported. No Change
Table 8A to 8D The registered person shall have an option to upload the details for the entries in Table 8A to Table 8D duly signed, in PDF format in FORM GSTR-9C (without the CA certification).

For F.Y. 2019-20, Registered persons will not have any option to upload details of Table 8A to 8D along with GSTR 9C.
Table 12, 13, 15, 16, 17 & 18 The registered person shall have an option to not fill this table. The registered person shall have an option to not fill this table.

No Change

 

From the above table it can be seen that Government has provided similar relaxation for F.Y. 2019-20 as provided for F.Y. 2018-19 except for Table 6 and Table8. Also, government earlier issued Press release on 09th October 2020 for GSTR 9 of F.Y. 2018-19 which states that for Table 4 to 7 of GSTR 9, the taxpayers shall report the values pertaining to the financial year only for which GSTR 9 is to be filed.

Now government had made mandatory to report value pertaining to financial year in Table 4 to 7 of GSTR 9. The value pertaining to preceding Financial Year shall not be reported in Table 4 to 7. Thus, Taxpayers have to take due care while filing Table 4 to 7 of GSTR 9 of F.Y. 2019-20 that they report only figures pertaining to F.Y. 2019-20.

 

For GSTR 9C of F.Y. 2019-20, government has provided all relaxations as available in F.Y. 2018-19, which are as follows:

  • For Table 5, the registered person shall have an option to not fill this table. If there are any adjustments required to be reported then the same may be reported in Table 5O.
  • For Table 12B and 12C, the registered person shall have an option to not fill this table.
  • For Table 14, the registered person shall have an option to not fill this table.

 

Thus, taxpayers are not required to do any extra work on identification nature of various adjustment as required to be done with turnover of Financial Statement to arrive at Annual Turnover for the purpose of GST. Also, Taxpayers are not required to do any additional exercise to prepare the breakup of expense wise Input Tax Credit.

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