GSTR 9 & 9C Filing Changes for FY 2021-22

Department would have initiated providing the notices and asking for the details by comparing the information shown in GSTR 9/9C Vs GSTR 3B. Acknowledging distinct amendments in the GST law in the recent former time. The article discusses furnishing transparency on annual returns (Form GSTR 9) filing and reconciliation statement (Form GSTR 9C) including needed reconciliations, best practices, advanced issues & solutions, and tips as applicable for the financial year (FY) 2021-22.

Last date: 31st Dec 2022. The last date which was extended in the former years would not be anticipated to get extended for FY 2021-22.

Latest Amendments in GSTR 9 Form Annual Returns for FY 2021-22

  1. Table 4 – revisions, credit notes, and debit notes could not be displayed as net figures in B2B, B2C, etc. now. Tables 4I to 4L are to be disclosed separately from FY 21-22.
  2. Table 5 – Exempted and Nil-rated would get consolidated in the ‘Exempted’ column. Table 5F – Non- GST would be mentioned separately from FY 21-22.
  3. Table 17 – HSN outward information mandated from FY 2021-22 onwards. (GSTR 1 consolidated data can be used for table 17)
  4. HSN disclosures are to be performed at a 6-digit level (when T/o > Rs. 5 crores) and 4-digit level (when T/o < Rs. 5 crores for B2B only)
  5. Clarification that disclosures in GSTR 1 tables 9A, 9B & 9C must be disclosed in tables 10 & 11 of GSTR 9.

Below mentioned are the exemptions made from before time:

Below mentioned are the exemptions made from before time:

  1. Table 5 – Revisions, credit notes, and debit notes could be displayed as net figures in table 5.
  2. Table 6 – ITC bifurcation into ‘inputs’/’input services’ is not compulsory, total value could get consolidated under ‘Inputs’. From FY 2019-20 – under ‘Inputs’ & ‘Capital Goods.
  3. Table 6 – It might consolidate ITC beneath the GST RCM from registered and unregistered individuals beneath the registered persons’ table.
  4. Table 7 – All ITC reversals might be consolidated beneath Table 7H, but TRAN reversals are to be displayed in a separate way.
  5. Part V – Reversal/claim of Input tax credit in the former year might not be filled (T12 & T13)
  6. Table 15, 16 & 18 – Information on the Refund, data on inward supplies and deemed supply, HSN inward information would remain optional.

Points to be Noted While GSTR 9 & 9C Filing for FY 2021-22

  • The assessee would not require to file the yearly return in FORM GSTR-9/9A for FY 2021-22 if their aggregate yearly turnover is up to Rs. 2 crores. (If 9 and 9C are not required)
  • According to table 4, the liability should acknowledge as a final liability (as per books) no matter what the liability disclosed in GSTR 3B + Form DRC-03 during the FY is.
  • In various places, it has been cited as ‘April – September’, but the same should be read as ‘April-November’ treating the current postponement of timelines vides NN 18/2022-CT.
  • Via Form DRC-03 the payment is to be made. Using the ITC under CGST rules would be restricted but the same could be disputed as per the interpretation that came from section 49(4) r/w Rule 86(2). Further, the GST portal permits the same Input tax credit usage.

Latest Changes in GSTR 9C Form (Reconciliation Statements)

There are no revisions in the relaxation furnished:

  1. Table 5B – 5N – Can regard all turnover corresponding adjustments in Table 5O
  2. Table 12B & 12C – Optional to fill this ITC information.
  3. Table 14 – Optional to fill expense-wise ITC claim information.

Note-1: Pre-requirement to 9&9C – all GSTR 1 & GSTR 3B for FY 2021-22 should be filed.
Note-2: From FY 2020-21 GSTR 9C would not be required to get signed via CA/CMA and would be acknowledged as an assessee furnished the form on its own. Hence, Part B (Auditor Certification) and Management Representation Letter does not need.
Note-3: Form GSTR 9 & Form GSTR 9C – once filed could not get amended.

Requirement for the Proper Reconciliation

  • Turnover – Audited Financial Statements (AFS/Books) vs Table 5A (regard all GSTINs)
  • Table 5N Vs Table 17 – As table 17 is now compulsory, the same reconciliation can be an internal check process.
  • Outward taxes – Liability according to the Books Vs Liability under GSTR 3B + DRC-03 (if any) [ensure RCM liability is comprised]
  • Outward taxes – Rate-wise liability according to workings Vs Rate-wise Liability under the books.
  • GSTR 1 Vs GSTR 3B (the same shall support update GSTR 9)
  • Inward taxes – Credit under the books Vs Credit under GSTR 3B
  • Closing balance [Cash + Credit] – Books Vs GST portal (acknowledge all GSTINs)
  • Confirm and furnish for Spillover transactions of former Financial year and hold tracker for subsequent Financial year.
  • Find out the rectification and revisions performed above the 30th November timeline. (Revised from 20th September).

Note: Generate invoice-level reconciliations- It proves to be an effective practice to assessees that would support the filing process of the yearly returns however it indeed detects the errors and furnished the details to the department in the forthcoming time.

Useful Tips for FY 2021-22 GSTR 9 & 9C Filing

  • Maintain 9 & 9C workings with links to all the related information. Avoid keyed-in workings.
  • Maintain separate information of ITC claimed, reversed, and re-claimed when the assessee meets the conditions stated u/s 16.
  • For the revisions, the outward register is to be maintained with original values, so that the same shall be supported while tables 4 & 5 of GSTR 9.
  • Invoice level GSTR 2B Vs ITC under books reconciliation is to be achieved for Table 8 disclosure in GSTR-9.
  • Credits under books – unclaimed because of non-matching with GSTR 2A/2B. Pass as expense in books of accounts of FY 2022-23 and confirm option of recovery from continuing vendors.
  • Furnishing the “Annual GST – Management Report” which comprises the following:
    • Folder with final workings and filed Form GSTR 1, 3B, GSTR 9 & 9C for the FY.
    • Reconciliations for the FY – Outward, Inward & RCM – birds’ eye view
    • Causes for variances and action is taken (summarily)
    • In which the other liability was seen- summary details + payment documentation
    • Suggestions on internal accounting/processes/reporting going forward

Note- Fill both forms concurrently, verify the precision, and make pending payments, and after that proceed to file.

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