GSTR 9 and GSTR 9C for F.Y. 2020-21

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Central Government has introduced Section 110 and 111 of Finance Act, 2021 to amend GST Laws to ease the compliance requirement in relation to GST Audit. CBIC vide its Notification No. 29/2021 – Central Tax dated 30th July 2021 has notified Section 110 and 111 of Finance Act, 2021 to be applicable from 01st August 2021.

Section 110 of Finance Act, 2021 omits the subsection 5 of Section 35 of CGST Act, 2017 which requires the audit of accounts of specified person by chartered accountant or cost accountant. Now GST Audit will not required for F.Y. 2020-21 onwards.

Section 111 of Finance Act, 2021 substitutes the Section 44 of CGST Act, 2017 which requires submission of annual returns by specified persons under GST. Now specified persons are required to submit annual return which may include a self-certified reconciliation statement, reconciling the value of supplies declared in the return furnished for the financial year, with the audited annual financial statement for every financial year. Hence requirement of furnishing reconciliation statement in form GSTR 9C has not been removed. Only the requirement of getting accounts audited under GST has been removed. Specified Taxpayers are still required to furnish GSTR 9 and GSTR 9C for every financial year.

 

Who is required to file GSTR 9 , GSTR 9A, GSTR 9B and GSTR 9C?

Type of Taxpayer Aggregate Turnover Nature of Form Required to be filed
Every registered person, other than an Input Service Distributor, a person paying tax under section 10 or 51 or section 52, a casual taxable person and a non-resident taxable person Upto 2 Crore Optional to file GSTR 9
More than 2 Crore but upto 5 Crore Mandatory to file GSTR 9
More than 5 Crore Mandatory to file GSTR 9 and GSTR 9C
Person paying tax under section 10 NA Mandatory to file GSTR 9A
Every electronic commerce operator required to collect tax at source under section 52 NA Mandatory to file GSTR 9B

What is due date for filing GSTR 9, GSTR 9A, GSTR 9B and GSTR 9C?

For F.Y. 2020-21 due date for filing GSTR 9, GSTR 9A, GSTR 9B and GSTR 9C is 31st December 2021.

 

What are the relaxations in filing of various Table of GSTR 9?

Particulars Relaxation
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.
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.
Table 5H to 5K The registered person shall have an option to fill Table 5A to Table 5F net of credit notes, debit notes and amendments in case there is any difficulty in reporting such details separately in Table 5.
Table 6B 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
Table 6C and 6D 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 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.

 

It is to be noted that Table 6E is for Import of goods, however for F.Y. 2019-20 and F.Y. 2020-21, 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 to 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.
Table 12, 13, 15A to 15G, 16A to 16C, 17 and 18 The registered person shall have an option to not fill this table.

 

It means it is optional for taxpayers to fill HSN summary of Inward supplies and outward supplies in Table 17 and 18.

It may be noted that for GSTR 9 of F.Y. 2019-20, GSTR 2A generated as on 01st November 2020, was notified to be auto-populated in Table 8A of GSTR 9. However, for Financial Year 2020-21, it is not notified that 2A data of which date will auto-populated in Table 8A of GSTR 9.

 

What are the relaxations in filing of various Table of GSTR 9C?

Particulars Relaxations
Table 5B to 5O 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.
Table 12B, 12C and 14 The registered person shall have an option to not fill this table.

 

It means it is optional for taxpayers to fill expense wise Input details in Table 14.

Part- B Certification by Chartered Accountant or Cost Accountant has been omitted.

 

Notification No. 30/2021 – Central Tax Dated 30-07-2021 notifying annual return forms (GSTR 9, GSTR 9A, GSTR 9B and GSTR 9C-Reconciliation Statement) and there due date.

Notification No. 31/2021- Central Tax Dated 30-07-2021 notifying GSTR 9 as option for taxpayer having turnover upto 2 crore.

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