# Annual Returns – GSTR 9 & 9A + Audit GSTR 9C # By SN Panigrahi

SN Panigrahi 3
One Day Interactive & Practical Oriented
Workshop on
GST Reconciliation – Audit & Annual Return
On 19th May’2019
(Sunday) by
Ni MSME (Govt. India)
Covering Detailed Analysis, Relevant Provisions
of GST Law, Annual Returns (GSTR 9 & 9A), GST
Audit (GSTR 9C), Checklist for Audit, Key Focus
Areas, Important Facts & Easy Tips with Practical
Presentations & Discussions

SN Panigrahi
5
GSTR
9
To be filed by
the Regular Taxpayers
Sec 44(1) of CGST Act
Rule 80(1) of
CGST Rules
Foramat as per Notification
No. 39/2018 – Central Tax
dated September 4, 2018
GSTR
9A
To be filed by Persons
Registered under
Composition Scheme
Proviso to Rule 80(1)
of CGST and SGST
Rules, 2017
Format as per Notification
No. 39/2018 – Central Tax
dated September 4, 2018
GSTR
9B
To be filed by the
e-commerce
operators
Rule 80(2) of
CGST and SGST
Rules, 2017
Tax Collector u/s 52 (Not
applicable for 2017-18 since it
came into force on 01-10-
2018)
GSTR
9C
To be filed by Persons
taxpayers whose annual
turnover is exceeds Rs 2
crores during the financial
year.
Proviso to Rule 80(1)
of CGST and SGST
Rules, 2017
Notification No. 49/2018 –
Central Tax dated
September 13, 2018
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Who
Should
File
GSTR 9
By When
It Should
be Filed
Whether
Auto
Populated
What if
Not Filed
Every Normal
Registered
Person other
than those
Specified in
Rule 80 of
CGST Rules
Who
Should
Not File
GSTR 9
Annual Return
GSTR 9
By 31st Dec of
Succeeding
FY;
For FY
2017-18,
Due Date
30-06-2019
Data from
GSTR 1 & 3B
are Auto
Populated into
GSTR 9
It is Editable
Except Some
Tables
Persons
Registered under
ISD, TDS, TCS,
Casual Taxable
Person, Non-
Resident
Taxable Person;
Composition
Dealer &
e- Commerce
Operator
Notice with
15 days' time
to file;
• Late fee:
Rs.200/day
(max. 0.5%
of State
Turnover)
Section 47 (2)
of CGST Act
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Additional
Liability can’t
be Paid
through
Credit
Ledger
Last Chance
to Rectify
Mistakes
done in
GSTR 1 & 3B
Data from
GSTR 1 & 3B
Auto
Populated to
GSTR 9
Auto
Populated
Data in GSTR
9 can be
Edited
Except Some
Additional
Liability
should be
Deposited
through
DRC 03
SN Panigrahi
Compare
Auto
Populated
GSTR 9 with
Audited
Financial
Statement
Editable
Except Table
6A, 8A, and
Payment
Entries in
Table 9
System
computed
GSTR-9 as
PDF is
Available for
Reference
Consolidated
Summaries
of GSTR-1
and GSTR 3B
are also
available
Edit
Wherever
Required &
Find
Additional
Liability
Values
Modified by
More / Less
than 20%,
Highlighted
in ‘Red’ for
reference
Some
Information
not furnished
in GSTR-1 &
3B required to
be furnished in
GSTR-9
Updates upto
28/02/2019
Auto
Populated
cannot claim
input tax
credit unclaim
ed during FY
2017-18
through
GSTR 9
Mandatory to
file all your
FORM GSTR-1
and FORM
GSTR-3B for
the FY 2017-18
before filing
GSTR 9

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Multiple Registrations GSTR 9 to be filed for Every GSTIN Separately
During the Same Financial
Year
Certain Period under
Composition Dealer & Some
Period as Normal Registered
Both GSTR 9A + 9 to be Filled
Period Under Composition Scheme : GSTR 9A
Period Under Normal Registration : GSTR 9
Nil Return
Even Nil Return of GSTR 9 to be filed
if you have
a. Not made any outward supply (commonly known as sale); AND
b. Not received any inward supplies (commonly known as
purchase) of goods/services; AND
c. No liability of any kind; AND
d. Not claimed any Credit during the Financial Year; AND
e. Not received any order creating demand; AND
f. Not claimed any refund. during the Financial Year
April – June 2017
Transactions
April – June 2017 Transactions of Sales / Purchases Should not be
Filled in GSTR 9

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Registered Businesses : Same Legal Entity – Same PAN
Different GST Registrations
Unit - 1 Unit - 2 Unit - 3 Unit - n
Separate GSTR 9
to be Filed
Separate GSTR 9
to be Filed
Separate GSTR 9
to be Filed
Separate GSTR 9
to be Filed
Is Form GSTR-9 return is needed to be filed at the entity level or GSTIN level?
•Yes, Form GSTR-9 return is needed to be filed at GSTIN level i.e. for every single registration. In
the case when the taxpayer has acquired more than one GST registrations, under the same PAN,
irrespective of the same (either due to separate business vertical or SEZ unit etc) or different
States, he/she is required to file annual return for each registrations individually.
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GSTR 9
Part I
Part II
Part III
Part IV
Part V
Part VI
Basic Info
Liability
Input Tax Credit
Tax Paid Details
Amendments
Others
Tax on Outward Supply
Tax on Inward RCM
Availed
Reversed
Reconciliation 2A
Format Prescribed vide Notification No. 39/2018 – Central Tax; 4 th September, 2018
6 Parts 19 Tables
Table 1-3
Table 4-5
Table 6-8
Table 9
Table 10-14
Table 15-19
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Part I Table 1-3 Basic Information
Part II Table 4 & 5
Details of Outward and Inward supplies declared during the financial
year
Table – 4: Details of Advances, Inward and Outward supplies on which
tax is payable as declared in returns filed during the financial year
Table – 5: Details of Outward supplies on which tax is not payable as
declared in returns filed during the financial year
Part III Table 6,7,8 Details of ITC as declared in returns filed during the financial year
Table – 6: Details of ITC availed as declared in returns filed during the
financial year
Table – 7: Details of ITC Reversed and Ineligible ITC as declared in
returns filed during the financial year
Table – 8: Other ITC related information ( Comparison with GSTR 2A)
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Part IV Table 9 Details of Tax Paid as declared in returns filed during the financial year
Part V Table 10 - 14
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
Table 10
Supplies / tax declared through Amendments (+) (Net of Debit
Notes)
Table 11
Supplies / tax declared through Amendments (-) (Net of Credit
Notes)
Table 14
Differential tax paid on account of declaration in 10 & 11
above
Table 12 Reversal of ITC availed during previous financial year
Table 13 ITC availed for Previous Financial Year
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Part VI Table 15-19 Other Information
Table 15 Particulars of Demands and Refunds
Table 16
Information on supplies received from composition taxpayers, deemed
supply under section 143 and goods sent on approval basis
Table 17 HSN Wise Summary of Outward Supplies
Table 18 HSN Wise Summary of Intward Supplies
Table 19 Late Fee Payable and paid
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Total Tax Liability Table 4
Total Turnover
Total Tax Payment
Input Tax Credit
Table 10 Table 11
Table 9 Table 14
Table 6 Table 7
Table 4 Table 5
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GSTR 9 : Table 4
 Details of advances, Inward and Outward supplies made during the financial year on which Tax is Payable
GSTR 9 : Table 5
 Details of Outward Supplies made during the financial year on which Tax is not Payable
GSTR 9 : Table 6A
 Total amount of Input Tax Credit availed through FORM GSTR-3B (sum total of Table 4A of FORM GSTR-3B)
GSTR 9 : Table 6G
 Input Tax Credit Received from ISD
GSTR 9 : Table 6K
 Transition Credit through TRAN-I (including revisions if any)
GSTR 9 : Table 6L
 Transition Credit through TRAN-II
GSTR 9 : Table 9
 Details of Tax Paid as declared in returns filed during the financial year

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GSTR 9 : Table 6A
 Total amount of Input Tax Credit availed through FORM GSTR-3B (sum total of Table 4A of
FORM GSTR-3B)
GSTR 9 : Table 8A
 Input Tax Credit as per GSTR-2A (Table 3 & 5 thereof)
GSTR 9 : Table 9
 Details of Tax Paid as declared in returns filed for the financial year
(Except Tax Payable column)

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Must be Normal Registered Taxable Person,
other than those Specified in Rule 80
Even though No Transactions during the FY, “Nil” Return should be Filled
GSTR – 1 & 3B for All the Months Must be Filled
In case of Conversion from Normal Registration to Composition Scheme or
Vise-versa, then both GSTR 9A shall be Filled only for Respective Period
under Composition Scheme & GSTR 9 for the Period under Normal
Registration
Form GSTR-9 Return is Needed to be Filed at GSTIN level (Not at the Entity
Level) i.e. for Every Registration, Separate GSTR 9 need to be Filed
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All the information must be cross checked with the books of accounts before declaring in the annual
returns. The Outward Supply Details can be Modified to Register the Actual Supplies made as per
Audited Financial Statement and Not just the Outward Supplies Reported in the GSTR 1 Returns.
Additional Liability Not Reported Earlier in Form GSTR-3B can be Declared in Form GSTR-9 & this
Additional Liability Declared in Form GSTR-9 is to be Paid through Form GST DRC-03.
The Form GSTR-9 doesn’t require certification. The Return cannot be Revised
after Filing
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 Information of July 17 to Mar 18 to be reported in this form, except Part V.
No information of April 17 to June 17 is to be provided in this report
In the Part V of Form GSTR 9, information with respect to
Corrections made from Apr’18 – Sep’18 (upto 31 Mar’19) are captured
Due Date for Filling GSTR-9 for FY 2017-18 is 30th June’2019

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 Bifurcation of ITC on Inward Supplies from registered persons, Inward supplies subject to RCM,
imports into Inputs, Input Services & Capital Goods
 ITC pushed by TRAN-1 and TRAN-II
 ITC pushed by ITC-01 and ITC-02 (Whether it is routed through 3B or directly goes to credit ledger)
 Bifurcation of ITC reversals (Table 7)
 Particulars of Demands and Refunds (Table 15)
 Deemed Supply u/s 143 (Table 16B) (Job Work)
 Goods Sent on Approval (Table 16C)
 HSN wise summary of inward supplies

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Is it possible to revise FORM GSTR-9?
No, it is not possible to revise FORM GSTR-9 thus it is much important to file an annual return in FORM
GSTR-9 accurately since any mistake can result in tax liability.
What is the mode of filing of an annual return in FORM GSTR-9?
Annual return in FORM GSTR-9 can be filed through both online and offline mode. However, it is pertinent
to note here that, with regard to annual return in FORM GSTR-9, at present only the online mode is made
available on the GST portal. Hopefully, offline mode (offline utility) would soon be made available on the
GST portal.
OnlineModes of
Filling
GSTR 9 Offline
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Online
 Based on GSTR-1 and GSTR-3B filed during the year, facility to download system
computed GSTR-9 as PDF format will be available.
 Based on GSTR-1 filed, consolidated summary of GSTR-1 will be made available as PDF
download.
 Based on GSTR-3B filed, consolidated summary of GSTR-3B will be made available as
PDF download.
 In each table of GSTR-9, values will be auto-populated to the extent possible based on
GSTR-3B and GSTR-1 of the year. All the values will be editable with some exceptions
(table 6A, 8A and tax payment entries in table 9).
 ‘Nil’ return can be filed through single click.
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Offline
 Offline tool to be downloaded from the portal.
 Auto-populated GSTR-9 (System computed json) to be downloaded from the portal before
filling up values.
 Table 6A and table 8A will be non-editable.
 Other values will be editable barring tax payment entries in Table 9.
 After filling up the values, json file to be generated and saved.
 After logging on the portal, the json file to be uploaded.
 File will be processed and error if any will be shown.
 Error file to be downloaded from the portal and opened in the Excel tool.
 After making corrections, file will again be uploaded on the portal.
 Correction can be made online also except table 17 & 18 if the number of records exceeds
500 in each table.
 After filing, return can be downloaded as PDF and/or Excel.
 Revision facility is not there, therefore, return should be filed after reconciling the information
provided in the return and in the books.
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What is the due date for filing of first annual return in FORM
GSTR-9?
The due date for filing of first annual return in FORM GSTR-9 has
been extended several times, however, as per Order No. 03/2018-
Central Tax dated 31st December, 2018 the same has been
extended till 30th June, 2019.
In short, the due date for filing of first annual return in FORM
GSTR-9 is 30th June, 2019.
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Payment:
1.Except Late Fee, if any, no payment is to be made with annual return.
2.Payment can be made on voluntary basis through GST DRC-03, if required.
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“FORM GSTR-9
(See rule 80)
Annual Return
Pt. I Basic Details
1 Financial Year
2 GSTIN
3A Legal Name
3B Trade Name (if any)
Part - 1
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Table 4 (A – N)
Transactions having
Tax Implications
Part II
Table 5 (A – N)
Transactions
Not having Tax
Implications
Details of
• Advances,
• Inward Supplies RCMand
• Outward Supplies on
which Tax is Payable
Details of
• Outward Supplies
on which Tax is Not Payable
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Table 4 (A – N)
Transactions having
Tax Implications
Details of
• Advances,
• Inward Supplies RCM and
• Outward Supplies on
which Tax is Payable

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Table
4
4A
4B
4C
4D
4E
4F4G
Supplies Made toB2C
Supplies made to Unregistered
Persons.
(Table 5,7,9 & 10 of GSTR -1)
Supplies Made to B2B
Supplies made to Registered
Persons
(Table 4A & 4C of GSTR 1)
Exports
Zero Rated supply (Export) on
payment of tax (except supplies
to SEZs)
(Table 6A with Pay of GSTR 1)
Deemed Exports
Supplies to AA / EPCG /
EOUs
(Table 6C of GSTR -1)
Advances
Advances on which tax has
been paid but invoice has not
been issued (not covered
under (A) to (E) above)
(Table 11 of GSTR -1)
Supplies to SEZ
Supplies made to SEZ on
Payment of Tax
(Table 6B with Pay of GSTR -1)
RCM
Inward Supplies on which Tax
is to be Paid on RCM
Table 3.1(d) of Form GSTR 3B
4H Sub-Total A to G
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S.N HAEADING COMMENT
4 Details of advances, inward and outward supplies on which tax is payable as declared in returns filed
during the financial year
Only Tax Payable supplies/receipts to be mentioned under this Para
A Supplies made to un-registered persons
(B2C)
▪ Reported from Table 5 (B 2C Large category : POS is in
different State & Value more than Rs 2.5 lakhs),
▪ Table 7 ( B 2C Small category),
▪ Table 9 ( Amendment of Table 5),
▪ Table 10 of GSTR 1 ( Amendment of Table 7 )
▪ Net of Debit / credit note to be reported
▪ These will include details of supplies made through E-
Commerce operators
B Supplies made to registered persons (B2B) ▪ Reported from Table 4A ( B2B) and Table 4C ( Supply through
E- commerce) of GSTR 1
▪ Debit / credit note to be reported separately
▪ Doesn’t include supplies on which tax is payable under RCM
Pt. II Details of Outward and inward supplies declared during the financial year
(Amount in ₹ in all tables)
Nature of Supplies Taxable Value CGST SGST IGST Cess
1 2 3 4 5 6
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C Zero rated supply (Export) on
payment of tax (except supplies to
SEZs)
▪ Reported from Table 6A of GSTR 1
▪ Export under LUT is not to be reported here.
▪ SEZ supply is not to be reported here
D Supply to SEZs on payment of tax ▪ Reported from Table 6B of GSTR 1
▪ Supply to SEZ under LUT is not to be reported here
Pt. II Details of Outward and inward supplies declared during the financial year
(Amount in ₹ in all tables)
Nature of Supplies Taxable Value CGST SGST IGST Cess
1 2 3 4 5 6
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E Deemed Exports ▪ Reported from Table 6C of GSTR 1 ( Notification No 48/2017 CT
Supply against Adv Authorisation, EPCG etc)
F
Advances on which tax has been paid
but invoice has not been issued (not
covered under (A) to (E) above)
▪ Here, case of advance received but invoice not issued during July
17 to Mar 18 are to be reported.
▪ Advance against goods was taxable upto 15.11.17
▪ (Notification No 66/2017 CT)
G Inward supplies on which tax is to be
paid on reverse charge basis
▪ As Recipient - Cases where Sec 9(3), 9(4) is applicable to be
reported.( It doesn’t include Import of Goods).
▪ Reported from Table 3.1(d) of Form GSTR 3B
▪ Including Advances,
▪ Net of Debit / credit note to be reported
H Sub-total (A to G above)
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Table
4
4I
4J
4K
4L
4M
4N
4
Credit Note
CN for Transactions for B2B,
Exports, SEZ and Deemed
Exports
(Table 9B of GSTR -1)
Debit Note
DN for Transactions for B2B,
Exports, SEZ and Deemed
Exports
(Table 9B of GSTR 1)
Amendments
Supplies/tax declared through
Amendments (+) - Increase
(Table 9A & 9C with Pay of
GSTR 1)
Amendments
Supplies/tax declared
through Amendments (-)
- Decrease
(Table 9A & 9C of GSTR -1)
4M – Sub Total (I) to (L)
Supplies & Advances on which
Tax is to be paid - (H + M)
4N – Balance Tax Payable
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I
Credit Notes issued in respect of
transactions specified in (B) to (E) above (-)
▪ Reported from Table 9B of GSTR 1.
▪ Details of Credit note of B2C is to be mentioned in Para 4A above
J
Debit Notes issued in respect of
transactions specified in (B) to (E) above
(+)
▪ Reported from Table 9B of GSTR 1.
▪ Details of Debit note of B2C is to be mentioned in Para 4A above
K Supplies / tax declared through
Amendments (+)
▪ Details of amendment made to above Para 4B, Para 4C, Para 4D,
Para 4E,
Para 4I, Para 4J to be reported here.
▪ Reported from Table 9A and Table 9C of GSTR 1
L Supplies / tax reduced through
Amendments (-)
▪ Details of amendment made to above Para 4B, Para 4C, Para 4D,
Para 4E, Para 4I, Para 4J to be reported here.
▪ Reported from Table 9A and Table 9C of GSTR 1
M Sub-total (I to L above)
N Supplies and advances on which tax is to
be paid (H + M) above
Referred in Audit Report
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4H
4A
4N - Tax Payable
(4A+4B+4C+4D+4E+4F+4G) + (-4I+4J+4K-4L)
Supplies Made toB2C
4B Supplies Made to B2B
4C Exports (Other Than to SEZ)
4D Supplies to SEZ
4E Deemed Exports
4F Advances
4G Inward Supplies - RCM
4M
4I Credit Notes
4J Debit Notes
4K Amendments (+)
4L Amendments (-)

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Table 5 (A – N)
Transactions not
having Tax
Implications
Details of
• Outward Supplies
on which Tax is Not Payable
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Turnover
Taxable
4N -
4G (RCM)
Exempted
5M
Include
Original
Amended
Dr /Cr
Note
NON GST The value of “no supply” shall also
be declaredhere.
B2B+B2C
Taxable& Exempted
Turnover
4N – 4G + 5M
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Table
5
5A
5B
5C
5D
5E
5F5G
Zero rated supply (Export)
without payment of tax
(Table 6A of GSTR -1)
Supply to SEZs without
payment of tax
Supplies on which tax is to
be paid by the recipient on
Reverse Charge Basis
Nil Rated
Non-GST supply
Exempted Supply
Sub-total
(A to F above)
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5 Details of Outward supplies on which tax is not payable as declared in returns filed during the financial year
supplies on which tax is not payable, are to be mentioned under this Para
A Zero rated supply (Export) without
payment of tax
▪ Export under LUT is to be reported here.
▪ SEZ supply is not to be reported here
B Supply to SEZs without payment of tax ▪ Reported from Table 6B of GSTR 1
▪ Supplies under LUT is to be reported here.
C Supplies on which tax is to be paid
by the recipient on Reverse Charge
Basis
▪ As Supplier - Cases where Sec 9(3), 9(4) is applicable to be
reported.( It doesn’t include Import of Goods).
▪ Reported from Table 4B of Form GSTR1
D Exempted ▪ Reported from Table 8 of Form GSTR 1
E Nil Rated ▪ Reported from Table 8 of Form GSTR 1
F Non-GST supply ▪ Reported from Table 8 of Form GSTR 1.
▪ "No Supply" category is also be covered here. ( This is as per
instruction to GSTR 9)
G Sub-total (A to F above)
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Table
5
5H
5I
5J
5K
5L
5M5N
Credit Notes issued in respect
of transactions specified in A
to F above (-)
(Table 9B of GSTR -1)
Debit Notes issued in
respect of transactions
specified in A to F above (+)
Supplies declared through
Amendments (+)
(Table 9A & Table 9C
of GSTR 1)
Sub-Total (H to K
above)
Turnover on which tax is
not to be paid
(G + L above)
Supplies reduced through
Amendments (-)
(Table Table 9A & Table 9C
of GSTR 1)
Total Turnover (including
advances) (4N +
5M - 4G above)
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H
Credit Notes issued in respect of transactions
specified in A to F above (-)
▪ Reported from Table 9B of Form GSTR 1
I
Debit Notes issued in respect of
transactions specified in A to F above (+)
▪ Reported from Table 9B of Form GSTR 1
J Supplies declared through Amendments (+) ▪ Reported from Table 9A & Table 9C of Form GSTR 1
K Supplies reduced through Amendments (-) ▪ Reported from Table 9A & Table 9C of Form GSTR 1
L Sub-Total (H to K above)
M Turnover on which tax is not to be paid
(G + L above)
N Total Turnover (including advances) (4N +
5M - 4G above)
▪ This will include all taxable , Non taxable outward supplies.
▪ This will include advances on which tax is paid but invoice is
not issued during the year.
▪ This will not include inward supplies on which tax paid under
RCM
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5G
5A
5N – Total Turnover
(Taxable Turnover 4N + Exempted Turnover 5M - Inward Supplies : RCM - 4G)
Exports without Payment of Tax
5B
Supplies to SEZ without Payment
of Tax
5C Outward Supply RCM
5D Exempted Supply
5E Ni Rated
5F Non- GST Supply
5L
5H Credit Notes for 5A – 5F
5I Debit Notes for 5A – 5F
5J Amendments (+)
5K Amendments (-)
5L Sub Total 5H to 5K
5M – Turnover on which Tax Not Paid
(5G + 5L)

Input Tax Credits
Table 6
Declared as per 3B
Table 7
Reversals as per 3B
Table 8
Reconciliation with 2A
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 In Part III, only tax amount is required to be mentioned.
 Value of supplies is not required to be mentioned.
 Information in Sr. No. A below are going to be auto populated
 In this part, at some para’s, bifurcation of information is required to be given
 Between Inputs, Capital Goods and Input Services at Sr. No. 6B, 6C, 6D and
 Between Inputs and Capital Goods at Sr. No. 6E
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Pt. III Details of ITC as declared in returns filed during the financial year
Description Type CGST SGST IGST Cess
1 2 3 4 5 6
6 Details of ITC availed as declared in returns filed during the financial year
6A Total amount of input tax credit availed through FORM GSTR-3B (sum
total of Table 4A of FORM GSTR-3B)
<Auto> <Auto> <Auto> <Auto>
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6B Inward supplies (other than
imports and inward supplies
liable to reverse charge but
includes services received
from SEZs)
Inputs ▪ Table 4(A)(5) of GSTR 3B can be used for filing up
these details
▪ Credit availed, but reversed (may be due to time
limit of 180 days for making payment to supplier)
and then re-claimed ( after making payment to
supplier) shall not be reported here. It is to be
reported in below Para 6(H)
Capital Goods
Input Services
6C Inward supplies received from
unregistered persons liable to
reverse charge (other than B
above) on which tax is paid &
ITC availed
Inputs ▪ Table 4(A)(3) of GSTR 3B can be used for filing up
these details.
▪ Credit of tax paid as per Sec 9(4) is to be
considered here
▪ It doesn’t include import of service
Capital Goods
Input Services
1 2 3 4 5 6
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6D Inward supplies received
from registered persons
liable to reverse charge
(other than B above) on
which tax is paid and ITC
availed
Inputs ▪ Table 4(A)(3) of GSTR 3B can be used for filing up these details.
▪ Credit of tax paid as per Sec 9(3) is to be considered hereCapital Goods
Input Services
6E Import of goods (including
supplies from SEZs)
Inputs ▪ Table 4(A)(1) of GSTR 3B can be used for filing up these details.
Capital Goods
6F Import of services
(excluding inward supplies
from SEZs)
▪ Table 4(A)(2) of GSTR 3B can be used for filing up these details.
6G Input Tax credit received
from ISD
▪ Table 4(A)(4) of GSTR 3B can be used for filing up these details.
1 2 3 4 5 6
SN Panigrahi

SN Panigrahi 49
Segregated Details of ITC
A Challenge
Data Classified as ITC on
Inputs,
Capital Goods and
Input Services
Required in
Table
6B
Table
6C
Table
6D
Data Classified as ITC on
Inputs &
Capital Goods
Required in
Table
6E
These Classifications in the ITC Availed will lead to Reworking on the Accounting Entries by the Assessee,
as the same details were not required in the periodic returns.

50
6H
Amount of ITC reclaimed (other than B
above) under the provisions of the Act
▪ Amount of ITC claimed, reversed and reclaimed is to be reported
here
6I Sub-total (B to H above)
6J
Difference (I - A above) ▪ Ideally, this amount should be Zero. Figures as per para 6B to 6H
are just detailed versions of amount mentioned in Para 6A above
1 2 3 4 5 6
SN Panigrahi

51
Sub-Total 6B to 6H
ITC on B2B Inward Supplies +
RCM – RP & URP +
Import – goods & Services +
ITC from ISD +
Reclaimed ITC
6 J 6 I 6 A
6 B to 6H
Input Tax Credit Availed
through FORM GSTR-3B
Difference
between
claimed in
GSTR 3B and
Item-wise
breakup
Ideally, this
amount should
be Zero.
SN Panigrahi

52
6K
Transition Credit through TRAN-I
(including revisions if any)
6L Transition Credit through TRAN-II
6M
Any other ITC availed but not specified
above
▪ For example : Details of ITC availed through ITC 01, ITC 02 to be
reported here
6N Sub-total (K to M above)
6O Total ITC availed (I + N above)
1 2 3 4 5 6
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53
Sub-Total 6B to 6H
ITC on B2B Inward Supplies +
RCM – RP & URP +
Import – goods & Services +
ITC from ISD +
Reclaimed ITC
6 O 6 I 6 N
6 B to 6HTotal
ITC Availed
Sub-Total 6K to 6M
Transition Credit TRAN-I +
Transition Credit TRAN-II +
Other Credit Taken
6 K to 6M
SN Panigrahi

55
Details of ITC Reversal
As per Rule 37 As per Rule 39 As per Rule 42 As per Rule 43
Table 7A Table 7B Table 7C Table 7D
Rule 37 –
unpaid
Invoices
beyond 180
days from the
date of Invoice
Rule 39 –
Reversal for
ineligible
credits for ISD
Rule 42 –
Reversal
for
ineligible
Credits on
Inputs
Rule 43 –
Reversal for
ineligible
Credits on
Capital Goods
SN Panigrahi

56
7
Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year
A
As per Rule 37 ▪ Table 4B of GSTR 3B may be used for reporting this.
▪ Case of payment not made within 180 days
B
▪ Reversal of excess ITC distributed credit by ISD as per Rule 39(1)(j), 39(2)
C
▪ Reversal of ITC of Input/Input Services, if used for exempted supply
D
▪ Reversal of ITC of CG, if used for exempted supply
Pt. III
Table 7
Details of ITC Reversed and Ineligible ITC as declared in returns filed during
the financial year
Description CGST SGST IGST Cess
1 3 4 5 6
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57
Details of ITC Reversed and Ineligible ITC
Table 7E Table 7F Table 7G Table 7H
Sec 17(5) –
Blocked Input
Tax Credits
Reversal of
TRAN 1
Credits
Reversal of
TRAN 2
Credits
Other
Reversals
(Pls specify)
Table 7I Table 7A to H
Total ITC Reversed
(A to H above)
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58
6 O
Total
ITC
Availed
7 J
Net ITC
Available
for
Utilization
7I
Total
ITC
Reversed
Details of ITC Reversed and Ineligible ITC
SN Panigrahi

59
7
Details of ITC Reversed and Ineligible ITC as declared in returns filed during the financial year
E As per section 17(5) Blocked Credit ▪ Table 4B of GSTR 3B may be used for reporting this. Reversal of
blocked ITC
F Reversal of TRAN-I credit ▪ Table 4B of GSTR 3B may be used for reporting this
G Reversal of TRAN-II credit
H
Other reversals (pl. specify) ▪ ITC reversed through ITC 03, Sale of CG, Reversal due to closure of
business or any other reversal may be reported here
I Total ITC Reversed (A to H above)
J Net ITC Available for Utilization (6O -
7I)
Pt. III
Table 7
Details of ITC Reversed and Ineligible ITC as declared in returns filed during
the financial year
1 3 4 5 6
SN Panigrahi

SN Panigrahi 61
8A
ITC as per
GSTR 2A
(Table 3 & 5)
– Auto
Populated
8D
Difference
[8A –
(8B+8C))
8B
ITC as per
normal B2B
Transactions
and ITC
Reclaimed
(6B and 6H)
ITC on B2B Inward
Supplies +
RCM – RP & URP +
Import – goods &
Services +
ITC from ISD +
Reclaimed ITC
Other ITC Related Information
8C
ITC for 2017-18
availed in 2018-19
(April to Sept 2018)

SN Panigrahi 62
Table 6B
Inward supplies (other
than Imports and
inward supplies liable
to Reverse Charge but
includes services
received from SEZs)
Table 6C
Inward supplies
Received from
Unregistered persons
liable to Reverse
Charge (other than B)
Table 6D
Inward supplies
Received from
Registered Persons
liable to Reverse
Charge (other than B)
Table 6E
Import of Goods
(including supplies
from SEZs)
Table 6F
Import of Services
(excluding inward
supplies from SEZs)
Table 6G
Input Tax Credit
Received from ISD
Table 6H
Inward supplies (other
than imports and
inward supplies liable
to reverse charge but
includes services
received from SEZs)
Table 8B

63
8 Other ITC related information
A ITC as per GSTR-2A (Table 3 & 5 thereof) This will be auto populated by system from GSTR 2A
B
ITC as per sum total of 6(B) and 6(H)
above
It will be auto populated. (In form notified by govt, auto
comment is mentioned only for IGST, and not for other. It
might be typing mistake.)
C ITC on inward supplies (other than
imports and inward supplies liable to
reverse charge but includes services
received from SEZs) received during
2017-18 but availed during April to
September, 2018
Credit pertaining to July 17 to Mar 18, but availed in GSTR
3B of April 18 to Sep 18, shall be declared here.
Table 4(A)(5) of Form GSTR 3B may be used for filling up
these details
Credit taken based on Circular 26/2017
D Difference [A-(B+C)] <Auto>
Pt. III
Table 8
Other ITC related information
1 3 4 5 6
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64
8E
ITC
available
but Not
Availed
(out of 8D)
8K
Total ITC
Lapsed in
Current FY
(8E+8F+8J)
8F
ITC
available
but
Ineligible
(out of 8D)
Other ITC Related Information
8J = 8I
ITC available
but not
availed on
Imports
8G
IGST paid on
Imports (Inc
Supplies
from SEZ)
8I
GST NOT
AVAILED
Difference
(8G-8H)
8H
IGST credit on
Imports (Inc Supp
lies from SEZ) –
As per 6E (import
of Goods)
–Auto Populated
8D
8E
8F
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65
8 Other ITC related information
E ITC available but not availed (out of D) Amount of Para 8E + 8F = 8D
F ITC available but ineligible (out of D)
G
IGST paid on import of goods (including
supplies from SEZ)
H
IGST credit availed on import of goods (as per
6(E) above)
This will be auto populated by system from para 6E above
I Difference (G-H) GST NOT AVAILED
J
ITC available but not availed on import of
goods (Equal to I)
This should be equal to Para 8I above. This is credit not availed
and ineligible credit. Unnecessary this extra row is there.
K
Total ITC to be lapsed in current financial year
(E + F + J)
This is lapsed credit
Pt. III
Table 8
Other ITC related information
1 3 4 5 6
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66
 IGST/CGST/SGST/Cess Tax liability Paid: Reported from Table 6.1 of GSTR 3B. Here details of
actual tax paid during current FY as per GSTR 3B is required to be given. Even if there is
difference as per GSTR 3B and GSTR 1, here details as per GSTR 3B are to be given.
 Interest: Actual Interest paid as disclosed only to be shown here.
SN Panigrahi

Part IV – Table : 9
Details of tax Paid as declared in Returns
Tax liability discharged in Cash or ITC
Taxes
Late
Fees
Penalty/
OthersInterest
CGST
SGST
IGST
CESS
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68
Pt. IV Details of tax paid as declared in returns filed during the financial year
Table -9
Description Tax Payable Paid through
cash
Paid through ITC
Centra
l Tax
State
Tax /
UT
Tax
Integrate
d Tax
Cess
1 2 3 4 5 6 7
Integrated Tax
Central Tax
State/UT Tax
Cess
Interest
Late fee
Penalty
Other
SN Panigrahi

70
Supplies / tax
declared
through
Amendments
(+) (net of
debit notes)
Supplies / tax
declared
through
Amendments
(-) (net of
Credit notes)
Table 11Table 10
SN Panigrahi
Table 10 & 11
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.

71
Reversal of ITC
availed during
Previous
financial year
Goods or Services Received
in the Previous
Financial year, but ITC
Availed upto Mar’19
Table 12 Table 13
SN Panigrahi
Table 12
Aggregate value of reversal of ITC which was availed in the previous financial year but reversed in returns filed for the
months of April to September of the current financial year or date of filing of Annual Return for previous financial year ,
whichever is earlier shall be declared here. Table 4(B) of FORM GSTR-3B may be used for filling up these details.
Table 13
Details of ITC for goods or services received in the previous financial year but ITC for the same was availed in returns filed
for the months 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. Table 4(A) of FORM GSTR-3B may be used for filling up these
details.

SN Panigrahi 72
GSTR 3B filed during April to Sep
2018
Irrespective of ITC reflected in
GSTR 2A or not
ITC to be reflected in Table 13 of
GSTR 9 of 2017-18
GSTR 3B filed during Oct 18 to
March 19
Where invoices uploaded by
supplier in GSTR 2A
ITC to be reflected in GSTR 9 of
2018-19
Details of ITC for goods or services received in the previous financial year but ITC for the same
was availed in returns filed for the months of April to September (upto 31st Mar’2019)* of the
current financial year or date of filing of Annual Return for the previous financial year
whichever is earlier shall be declared here.
Table 13
*It would be interesting to note that Part V in Form GSTR 9 for the financial year 2017-18 continues to refer to
‘April 2018 to September 2018’.

73
Pt. V Particulars of the transactions for the previous FY declared in returns of
April to September of current FY or upto date of filing of annual
return of previous FY whichever is earlier
Description
Taxable
Value
Central
Tax
State
Tax / UT
Tax
Integrat
ed Tax
Cess
1 2 3 4 5 6
Table 10 Supplies / tax declared
through Amendments (+) (net
of debit notes)
Table 11 Supplies / tax reduced
through Amendments (-) (net
of credit notes)
Table 12 Reversal of ITC availed
during previous financial year
Table 13 ITC availed for the
previous financial year
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75
Table 14 Differential Tax Paid on Account of Declaration in 10 & 11
above
Description Payable Paid
1 2 3Integrated Tax
Central Tax
State/UT Tax
Cess
Interest
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77
Pt. VI Other Information
15 Particulars of Demands and Refunds
Details CGST SGST IGST Cess Interes
t
Penalt
y
Late
Fee
1 2 3 4 5
A Total Refund claimed
B Total Refund sanctioned
C Total Refund Rejected
D Total Refund Pending
E Total demand of taxes
F
Total taxes paid in respect of E above
G
Total demands pending out of E above
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79
Table
16
Information on supplies received from composition taxpayers, deemed
supply under section 143 and goods sent on approval basis
Details Taxable
Value
Central
Tax
State
Tax /
UT
Tax
Integrate
d Tax
Cess
1
2 3 4 5 6
A
Supplies received from
Composition taxpayers
B Deemed supply under
Section 143 (Job Work)
C
Goods sent on Approval
basis but not Returned
Goods sent on approval to be received within 6 months else same is treated as supply
SN Panigrahi

80
 Sr. No 17 and 18: It is optional for tax payer having turnover upto 1.5 crore. It is mandatory to
report 2 digit level HSN Code for taxpayer having turnover in between 1.5 to 5 crore. It is
mandatory to report 4 digit level HSN Code for taxpayer having turnover in more than 5 crore.
UQC is to be reported only in case of goods
SN Panigrahi

SN Panigrahi 81
Table 5N
5N – Total Turnover
Table 10
Supplies / tax
declared through
Amendments (+)
(net of Debit Notes)
Table 11
Supplies / tax
declared through
Amendments (-) (net
of Credit Notes)
Table 17
HSN Wise Summary of outward supplies

82
17 HSN Wise Summary of outward supplies
HSN
Code
UQC Total
Quantity
Taxable Value Rate of Tax Central
Tax
SGST IGST Cess
18 HSN Wise Summary of Inward supplies
HSN
Code
UQC Total
Quantity
Taxable Value Rate of Tax CGST SGST IGST
Cess
SN Panigrahi

SN Panigrahi 83
Table 18
HSN Wise Summary of Inward Supplies
Not Required in GSTR 3B
Required in GSTR 9
This requirement of reporting HSN wise
inward supplies is cumbersome, if not
maintained earlier.
However, reporting of HSN summary is restricted only to those HSN which accounts for atleast 10% of
the total summary of inward supplies.

85
19 Late Fee Payable and Paid
Description Payable Paid
1 2 3
A Central Tax
B State Tax
SN Panigrahi

SN Panigrahi 86
Issue Remarks
The difference in the annual return as per the books of
accounts and GST data filed during the financial year.
The government gives an option to either declare
values as per the books or as per returns already filed.
GSTR 9 should provide the means to verify whether the
figures from GST data filed for annual return are in line
with the books of accounts.

87
✓ No place to mention remark/reservation in Form GSTR 9
SN Panigrahi

88
Digital
Signature
Certificate
(DSC)
Electronic
Verification
Code
(EVC)
A Digital Signature Certificate authenticates the
identity electronically while providing a high level of
security for online transactions by safeguarding the
privacy of the information exchanged using a digital
certificate. The GST Portal accepts only PAN-based
Class II and III DSC.
The Electronic Verification Code (EVC)
Authenticates the Identity of the user at the GST
Portal by generating an OTP (One Time Password)
which is sent to the registered Mobile Phone & E-
Mail ID of Authorized Signatory Filled in Part A of
the Registration Application.
Different
Modes of
Signing Form
GSTR-9
SN Panigrahi

SN Panigrahi 89
Information required in GSTR-1 and GSTR-3B but not required in GSTR-9 :
GSTR 3B
a. Supplies made to Composition tax payers as 3.2(b) of GSTR-3B have been clubbed in 4B of
GSTR-9 and not separately disclosed.
b. Supplies made to UIN holders as per 3.2(c) of GSTR-3B have been clubbed in 4B of GSTR-9 and
not required to be separately disclosed.
c. Receipt of Exempted, NIL rated and Non GST supplies required to be reflected in Table 5 of GSTR
3B is not required to be reflected in GSTR-9.
d. Information regarding taxes paid through TDS and TCS are required to be reflected in Para 6.2 of
GSTR-3B, which is not there in GSTR-9 because the provisions have come into effect only from 01-
10-2018.
GSTR-1
Information regarding documents issued during the tax period required to be reflected in Table 13 of
GSTR-9 is not required to be reflected in GSTR-9

91
What is GSTR 9C (GST Audit Form)?
GSTR 9C is an annual audit form for all the taxpayers having the turnover above 2 crores
in a particular financial year.
Along with the GSTR 9C audit form, the taxpayer will also have to submit audited annual
accounts & Reconciliation Statement along with the certification of an audit.
SN Panigrahi

92
Reconciliation of Gross Turnover
Reconciliation of Taxable Turnover
Reconciliation of Rate Wise Liability and Amount Payable thereon
Additional Amount Payable due to above Reconciliation but not paid
Reconciliation of Net ITC
Auditors Recommendation on additional Tax Liability
Verification
Audit Certification Report
Total V Parts
Total 16
Reporting
Headings
GSTR 9C

93
Sec
35(5)
Every Registered Person whose
Turnover During a Financial Year exceeds the prescribed limit,
get his Accounts Audited by a Chartered Accountant or a
Cost Accountant
Sec
44(2)
Every Registered Person who is required to get his
accounts Audited, shall Furnish, electronically, the Annual
Return (GSTR - 9) along with a copy of the Audited Annual
Accounts and a Reconciliation Statement
Rule
80(3)
Every Registered Person whose Aggregate Turnover during a
Financial Year Exceeds Rs 2 Cr shall get his Accounts
Audited, shall furnish a Copy of Audited Annual Accounts
and a Reconciliation Statement, Duly Certified, in
FORM GSTR-9C
Under this, the authorities have also introduced the format of GSTR 9C in the Notification No. 49/
2018 – Central tax dated September 13, 2018.
SN Panigrahi

94
Registered
Person
Registered under
Composition
GSTR – 9A
Registered under
E- Commerce
GSTR – 9B
Registered under
Normal
GSTR - 9
By 31st Dec
Sec 44(1)
ISD Registered
Person Deducting
TDS
Person Deducting
TCS
Casual Taxable
Person
Non-resident
Taxable Person Govt Entities whose a/c are audited by CAG
SN Panigrahi

95
GST
Audit
By Chartered Accountant
By Cost Accountant
No Member can Practice without Holding a Certificate of Practice
Company Secretary or any other Except CA / CMA
Part Time Practice cannot Perform an Audit
An Internal Auditor of an entity cannot undertake GST Audit of the
same entity.
Member having substantial interest in an assessee cannot take up its
audit.
Member responsible for writing / maintenance of books of account of
an assessee should not take up its audit
A CA who is indebted for more than Rs. 10,000, or has given any
guarantee or provided any security
Note :
Statutory Auditors can be Appointed as GST Auditors
SN Panigrahi

SN Panigrahi 96
Unique Document Identification Number (UDIN) has been made mandatory as per the Council
decision taken at its 379th Meeting held on 17th – 18th December, 2018 in the following phases:
 All Certification done by Practising CAs w.e.f. 1st Feb., 2019.
 All GST & Tax Audit Reports w.e.f. 1st April, 2019.
 All other attest functions w.e.f. 1st July, 2019
Practising CAs have to register at UDIN portal (https://udin.icai.org/) to obtain UDIN.

SN Panigrahi 97
Pre-Conditions for Filing
GSTR 9C
Filed GSTR-9
for the
Relevant
Financial Year
Got his
Accounts
Audited as
Specified
Registered
Person
Turnover
> Rs 2 Cr
Handed Over
to Auditor

SN Panigrahi 98
How to Down Load
GSTR 9
System Generated Summary
Taxpayer can download the ‘System Generated Summary based on GSTR-9’ in PDF file
from the portal by clicking on ‘Download GSTR-9C tables derived from GSTR-9(PDF)’ button.
Downloaded PDF can be handed over / passed on to auditor.
Auditor can use the same to fill the GSTR-9 related fields in GSTR-9C.
‘System Generated Summary based on GSTR-9’ filed shall have the following fields:
 Turnover as declared in Annual Return (GSTR-9)
 Taxable Turnover as per liability declared in Annual Return(GSTR-9)
 Total amount of Tax Paid as declared in Annual Return (GSTR-9)
 ITC Claimed in Annual Return(GSTR-9)

SN Panigrahi 99
To download and open the GSTR-9C Offline Utility in your system from the GST Portal,
perform following steps:
 Access the GST Portal:gst.gov.in.
 Go to Downloads > Offline Tools > GSTR-9C Offline Tool option and click on it.
 Unzip the downloaded Zip file which contain GSTR_9c_Offline_Utility.xls excel
sheet.
 Open the GSTR_9c_Offline_Utility.xls excel sheet by double clicking on it.
 Read the ‘Read Me’ instructions on excel sheet and then fill the work sheet
accordingly.
How to Down Load
GSTR 9C
Offline Utility

SN Panigrahi 100
Some Information in GSTR-9 is Required to be Directly carried to GSTR 9C
Table (4N-4G) + (10-11) of GSTR 9
Taxable Turnover
Table 7F of GSTR 9C
Taxable Turnover
Table 5N+10+11 of GSTR 9
Gross Turnover
Table 5Q of GSTR 9C
Gross Turnover
Table 7J of GSTR 9
ITC Available
Table 12E = 14S of GSTR 9C
ITC Available
Table (9+14) of GSTR 9
Table 14 = Net of Table 10 & 11
Tax Payable
Table 9Q of GSTR 9C
Tax Payable

SN Panigrahi 101
GSTR 9C
Offline : Down Load & Upload
Login
Upload GSTR
9C
In JSON File
GSTR-9C
Offline Utility:
No Need to
Login
DownLoad
UpLoad
Taxpayer must login in to the GST Portal to upload the generated JSON file using GSTR-
9C Offline Utility.
Log in to GST portal > Annual return
 Select Financial year and click on Search
 > Click on ‘Prepare Offline’ option in GSTR-9C tile
 > Go to ‘upload’ tab.

SN Panigrahi 102
The taxpayer, or the auditor can download GSTR-9C offline tool (.zip file) from GST Portal
and unzip the downloaded file to open excel based offline tool.
Fill details in the downloaded offline sheet and validate sheet.
From where can I download and use the GSTR-9C Offline
Utility in my system?
To download and open the GSTR-9C Offline Utility in your system from the GST Portal,
perform following steps:
Access the GST Portal: gst.gov.in.
Go to Downloads > Offline Tools > GSTR-9C Offline Tool option and click on it.
Unzip the downloaded Zip file which contain GSTR_9c_Offline_Utility.xls excelsheet.
Open the GSTR_9c_Offline_Utility.xls excel sheet by double clicking onit.
Read the ‘Read Me’ instructions on excel sheet and then fill the work sheet accordingly.

SN Panigrahi 103
How would Form GSTR 9C be verified and signed by Chartered Accountant/ Cost
Accountant?
Chartered Accountant / Cost Accountant shall use the offline tool to fill up the required details
and the Certificate.
He would generate a JSON file after validation and upload the file.
After generating JSON the Auditor shall affix his digital signature.
Who would upload the Form GSTR9C?
Chartered Accountant/ Cost Accountant after verification and signing shall pass on the signed
JSON file to taxpayer for upload of Form GSTR 9C.
It is to be uploaded on GST portal by the taxpayer, after verification, along with a copy of the
following documents
Balance Sheet, Income and Expenditure Account / Profit and Loss Account and any other
document.
Can I download draft Form GSTR 9C before filing?
Yes. Draft GSTR-9C in PDF format can be downloaded after the upload of JSON file.

Auditor
Tax Payer
104
Down Load GSTR 9C
Offline Tool
Use the Offline Tool to
Fill up the Required
Details and the
Certificate
Generate a JSON file
after Validation & Affix
Digital Signature
Pass on the
Signed JSON
File to Taxpayer
Draft GSTR-9C in PDF
Format can be
Downloaded after the
upload of JSON File
Along with a copy of
Balance Sheet, Income
& Expenditure Account
/ Profit & Loss Account &
any other document in PDF
Format
Upload of Form
GSTR 9C
In the Portal
In JSON Format only
Receives Signed
JSON File from
Auditor

SN Panigrahi 105
No Changes are allowed in the JSON file uploaded by the Auditor
If Auditor has made Recommendation on Additional Liability to be Discharged, Make the Same
through GST DRC 03
In case of any Error shown by System on uploading the Form GSTR 9C
 Download the JSON error file and handover it to auditor.
 Auditor has to open it in offline tool by clicking on “Open downloaded error JSON file”.
 He would correct errors as per details mentioned in “GST Validation errors” and sign it
again after generating JSON.
 On upload of signed JSON; system shall validate that no changes have been made in
signed JSON by taxpayer.

106
When proceed to file button shall been
abled
Save button shall be enabled only after successful upload of mandatory documents
(Balance sheet and Profit & loss statement/Income & expenditure statement)
‘Proceed to file’ button shall be enabled only after successful upload of Signed JSON
file Balance sheet in PDF/JPEG format Profit & Loss statement/ Income & Expenditure
statement in PDF/JPEG format and save
Upload Signed JSON File
+
Balance sheet in PDF/JPEG format Profit & Loss statement/ Income & Expenditure
statement in PDF/JPEG format
Save Button shall be Enabled, then Press “Save” Botton
‘Proceed to file’ Button shall be enabled, then Press it to File

107
Reconciliation
& Audit
GSTR 9
Down Load
Audited
Financial
Statement
Gross Turnover
ITC
Taxable Turnover
Tax Liability & Payable
Part - II
Part - II
Part - III
Part - IV
Auditors RecommendationPart - V
Part A Part B
Audit
Certification

108
Part I Table 1-4 Basic Information
Part II Table 5-8
Reconciliation of Turnover declared in audited Annual Financial Statement with
turnover declared in Annual Return GSTR9 (Sr. No 5 to 8)
Table – 5: Reconciliation of Gross Turnover
Table – 6: Reasons for Un - Reconciled Difference in Annual Gross Turnover
Table – 7: Reconciliation of Taxable Turnover
Table – 8: Reasons for Un - Reconciled difference in Taxable Turnover
SN Panigrahi

109
Part III Table 9-11 Reconciliation of tax paid ( Sr. No. 9 to 11)
Table – 9: Reconciliation of Rate wise Liability and amount payable thereon
Table – 10: Reasons for Un-reconciled Payment of Amount
Table – 11: Additional Amount Payable but not Paid (due to reasons specified under
Tables 6,8 and 10 above)
SN Panigrahi

110
Part IV Table 12 - 16 Reconciliation of Input Tax Credit (ITC) (Sr. No. 12 to 16)
Table 12. Reconciliation of Net Input Tax Credit (ITC)
Table 13. Reasons for un-reconciled difference in ITC
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
SN Panigrahi
Table 15. Reasons for un - reconciled difference in ITC
Table 16. Tax payable on un-reconciled difference in ITC (due to reasons specified in 13
and 15 above)

111
Part V Auditor's Recommendation on Additional Liability due to Non-reconciliation
Part B CERTIFICATION
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112
✓ Information Required in Annual Return for
PERIOD YES / NO
April 17 to June 17 YES
July 17 to Mar 18 YES
April 18 to Sep 18 NO
FORM GSTR 9C : FY 17-18
✓ In Form GSTR 9C, information of turnover of April 17 to June 17 is required to be given.
✓ Said details are also required to furnish in first GSTR 1 of F.Y. 17-18.
✓ Cross checking of said information with GSTR 1 is to be done.
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113
 Return to be prepared by Auditor (Chartered Accountant or Cost Accountant).
 Excel tool to be provided for preparation of the return.
 Auditor will Generate json and handover to taxpayer after attaching DSC, who will upload the same on the
portal.
 Other documents comprising Profit and Loss statement/ Income and expenditure statement etc. also
to be uploaded.
 Turnover values will be based on GSTR-9 in few tables.
 A pdf of such values will be made available to taxpayer. Auditor may have the same from the taxpayer for use
in preparing GSTR-9C.
 File will be processed on the portal and error, if any will be indicated. Taxpayer will download the file and
handover to Auditor who will make correction. File to be uploaded again as it was uploaded originally.
 Processed file will be filed by taxpayer.
 Download option will be available at draft stage and after filing as well in pdf.
 Navigation option to make payment will be available which can be made through GST DRC-03.
 GSTR-9C can be filed after filing GSTR-9 only.
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114
GSTR 9 GSTR 9C
To be filed by all registered persons
irrespective of Threshold Limit
To be filed only if the aggregate
turnover in a financial year exceeds
Rs 2 Crores.
No Need to Annex Financials Financials to be Annexed
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116
GSTR 9C
Part A
Part B
Reconciliation Statement
Five Parts
Certification Portion
Total V Parts
Total 16
Reporting
Headings
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117
Reconciliation of Gross Turnover
Reconciliation of Taxable Turnover
Reconciliation of Rate Wise Liability and Amount Payable thereon
Additional Amount Payable due to above Reconciliation but not paid
Reconciliation of Net ITC
Auditors Recommendation on additional Tax Liability
Verification
Audit Certification Report
Total V Parts
Total 16
Reporting
Headings
GSTR 9C
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118
Part - I
Basic Details Table : 1-4
Part - II
Reconciliation of Gross Turnover Table : 5
Reasons for Un - Reconciled difference in Annual Gross Turnover Table : 6
Reconciliation of Taxable Turnover Table : 7
Reasons for Un - Reconciled difference in taxable turnover Table : 8
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119
Part - III
Reconciliation of rate wise liability and amount payable thereon Table : 9
Reasons for un-reconciled payment of amount Table : 10
Additional amount payable but not paid (due to reasons specified
under Tables 6,8 and 10 above)
Table : 11
Reconciliation of Tax Paid
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120
Part - IV
Reconciliation of Net Input Tax Credit (ITC) Table : 12
Reasons for un-reconciled difference in ITC Table : 13
Reconciliation of ITC declared in Annual Return (GSTR9) with ITC
availed on expenses as per audited Annual Financial Statement or
books of account
Table : 14
Reconciliation of Input Tax Credit (ITC)
Reasons for un - reconciled difference in ITC Table : 15
Tax payable on un-reconciled difference in ITC (due to reasons
specified in 13 and 15 above)
Table : 16
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Part - V
Auditor's Recommendation on Additional
Liability due to Non-reconciliation
To be paid through Cash
Voluntary Payment through Form : GST DRC 03
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122
COMMENT:
▪Information of whole F.Y. 17-18 is required to be given in this form
▪Financial Statements are to be divided
o Into GSTIN wise, and
o April 17 to June 17 and July 17 to Mar 18
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123
Financial Statement but are not permissible under GST
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124
5
G Turnover from April 2017 to June 2017 (-)
H Unbilled revenue at the end of Financial Year (-)
I Unadjusted Advances at the beginning of the Financial
Year (-)
J Credit notes accounted for in the audited Annual
(-)
K Adjustments on account of supply of goods by SEZ
units to DTA Units (-)
L Turnover for the period under composition scheme (-)
M Adjustments in turnover under section 15 and rules
thereunder
(+/-
)
N Adjustments in turnover due to foreign exchange
fluctuations
(+/-
)
O
Adjustments in turnover due to reasons not listed above
(+/-
)
P Annual turnover after adjustments as above <Auto>
Q Turnover as declared in Annual Return (GSTR9)
R Un-Reconciled turnover (Q - P) AT1
6 Reasons for Un - Reconciled difference in Annual Gross Turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
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125
Pt.
II
Reconciliation of turnover declared in audited Annual Financial
Statement with turnover declared in Annual Return
(GSTR9)
5 Reconciliation of Gross Turnover
A
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)
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126
B Unbilled revenue at the beginning of
Financial Year
(+)
Pt.
II
Statement with turnover declared in Annual Return (GSTR9)
COMMENTS:
▪PARA 5B: Clause 5B requires addition of unbilled revenue at the beginning of Financial Year. It
means, revenue booked in last F.Y. on accrual basis (WIP etc), However invoice for the same is
raised in F.Y. 17-18 and GST is charged on the same.
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, then value of
rupees Four Crores rupees shall be declared here)
In case of entities with multiple registration, a separate statement to be obtained for each
GSTIN reconciling the total with the amount disclosed in financials. SN Panigrahi

SN Panigrahi 127
In simple terms, unbilled revenue is the revenue recognized in the books of
accounts before the issue of an invoice at the end of a particular period.
Accounting Standard - 9 / IND AS 115 provides for recognition of revenue on
full completion / partial completion of the services though the due date for
issuing invoice as per the contract would be on a later date.
Un-Billed Revenue
Accounting Standard - 9 / IND AS 115

128
Particulars Amount (Rs.)
Opening balance of unbilled revenue as on 31St March 2017 XXXX
Less: Invoice raised during the period April 2017 to June 2017 XXXX
Less: Invoice raised during the period July 2017 to March 2018 XXXX
Add: Unbilled revenue recognized as on 31st March 2018 XXXX
Closing balance of unbilled revenue as on 31st March 2018 XXXX
1. Representation services provided on 25th of March for which invoice is raised on 5th of
April will be recognized as unbilled revenue. However, this will not be part of Clause 5B as it
is transaction during the period April 2017 to June 2017.
2. IT/ITES services provided for the month of March 2017 for which invoice is raised on 1st of
July 2017 as per the terms of contract will be recognized as unbilled revenue.
3. Fixed landline charges for the month of March will be recognized as unbilled revenue to the
extent of billing cycle in subsequent month/quarter.
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129
4. Rental contract for which billing is on 20th of every month, unbilled revenue will be
recognized in the books of accounts as on 31st March to the extent of 11 days of
services provided in March.
5. Maintenance contract for which billing is on 5th of the subsequent month, unbilled
revenue will be recognized in the books of accounts as on 31st March.
6. Cost incurred as on 31st March towards construction services for which billing will
be done on reaching the milestone in September 2017.
7. In case of cost-plus companies, if any cost is excluded from billing cycle during the
financial year and is identified at the time of Audit, it will be booked as unbilled revenue
in the books of accounts and invoice will be raised in the month in which it is identified
i.e. September or October 2017.
Cont…….
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130
What detailed are to be provided in Sl. No.5B (Unbilled revenue at
the beginning of Financial Year)?
Ans. Clause 5B requires addition of unbilled revenue at the beginning of
Financial Year.
Unbilled revenue which was recorded in the books of accounts on the basis
of accrual system of accounting in the earlier financial year for which the
invoice is issued under GST law is required to be declared here.
In other words, when GST is payable during the financial year on such
revenue (which was recognized as income in the earlier year), the value of
such revenue is to be declared here.
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131
C Unadjusted advances at the end of the
Financial Year
(+)
Pt.
II
COMMENTS:
It is a business practice to collect Advances from customers before effecting supplies. When an advance is
received, since the goods and / or services would not been delivered / rendered, the revenue is not yet earned,
whereby this advance would be recorded as a liability (either as current liability or long-term liability) in the balance
sheet as at the end of the financial year.
▪PARA 5C: It means, advance on which GST is paid in FY 17-18 but invoice for the same is not raised in FY 17-18
Value of all advances for which GST has been paid but the same has not been recognized as revenue in the
audited Annual Financial Statement shall be declared here.
Sl. No. 5I Less: Unadjusted advances at the beginning of the Financial Year Introduction
The scope of Part II Sl No. 5C and 5I is to make adjustment of Unadjusted Advances to Audited Financials for
arriving towards the GSTR 9 turnover.
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132
What are the adjustments to be included / excluded from Sl. No.5C of
Form GSTR-9C?
Ans. Advances received can be for various purposes. Therefore, the Advances on which GST is liable should
only be considered for the adjustment. The illustrations of advances to be included / excluded are as follows:
Include for Adjustment
Sl. No. Particular’s Reason
1 Advance received in respect of services for which the supply
has not been made as on 31st March 2018
Revenue not recognized in
books, but offered to tax for GST
2 Advance received for Goods before 15th Nov 2017 and the
supply of goods not complete as on 31st March 2018
Revenue not recognized in
books, but offered to tax for GST
Do NOT include for Adjustment
Sl. No. Particular’s Reason
1 Advance received for EXEMTED services as on 31st March
2018
GST is not applicable
2 Advance received for Goods after 15th Nov 2017 GST is not applicable
3 Financial Advances received which are not adjustable
against any services
NOT a GST Transaction
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133
D Deemed Supply under Schedule I (+)
Pt.
II
COMMENTS:
Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017 shall be declared here. Any
deemed supply which is already part of the turnover in the audited Annual Financial Statement is not
required to be included here.
▪PARA 5D: It include adjustment on account of Schedule I Supply reported in GSTR 1, mainly: - Branch
Transfer, Capital Goods transferred to under GSTIN unit etc
SN Panigrahi
•Schedule – 1
•1. Permanent transfer or disposal of “Business assets” where input tax credit has been availed on such
assets.
•2. Supply of goods or service or both between related persons or between distinct person as specified in
section 25 when made in the course or furtherance of business.
•3. Supply of goods:-
•♦ By a principal to his agent where the agent undertakes to supply such goods on behalf of principal or
•♦ By an agent to his principal where the agent undertakes to receive such goods on behalf of the principal
•4. Import of “Service” by a taxable person from a related person outside India or from any of his other
establishment outside India, in the course or furtherance of business.

134
E Credit Notes issued after the end of the
financial year
but reflected in the annual return
(+)
Pt.
II
COMMENTS:
▪PARA 5E:
Aggregate value of credit notes which were issued after 31st of March for any supply accounted in the current financial year
but such credit notes were reflected in the annual return (GSTR-9) shall be declared here.
As per me, this para is not relevant and incorrect.
This Sl.No. mandates reporting of the aggregate value of credit notes which were issued after Mar 31, 2018 in respect of any
supply accounted in the current financial year (2018-19) but such credit notes were reflected in the annual return (GSTR –9
for the financial year 2017-18).
But, it is uncommon, although not impossible, for credit note dated after Apr 1, 2018 to be given effect to in the financial
accounts. This Sl.No. only applies when such rarity has occurred. For the most part, this Sl.No. may well be ‘nil’.
SN Panigrahi

135
F Trade Discounts accounted for in the audited Annual
(+)
Pt.
II
COMMENTS:
▪PARA 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
Clause 5F requires disclosure of trade discounts which have been given effect to, in the audited financial
statements but which are not permissible as part of deductions from the value of supply under the GST
Laws.
Validation
The concept of ‘sale price’ does not permit the inclusion of trade discount in sale price. Wherever any
credit notes are to be issued for discount or sales incentives by any dealer to another dealer after issuing
tax invoice, the selling dealer shall issue a credit note without disturbing the tax component on the price
mentioned in the original tax invoice, so as to retain the quantum of input tax credit already claimed by
the buying dealers as well as not to disturb the tax already paid by the selling dealer.
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136
Pt.
II
COMMENTS:
▪PARA 5G: Turnover of F.Y. 17-18 are to be reported here
In terms of this Sl.No. the turnovers included in the audited financial statement for the
period April 2017 to June 2017 shall be declared and deducted from annual turnover to
arrive at the turnover as per GST Laws.
Validation of Information
The turnovers declared in the said excise return, State Level VAT returns and Service Tax
returns ought to match with the turnovers declared in the books of accounts for the period
relating to April 2017 to June 2017, subject to point of taxation differences that may arise in
terms of the erstwhile laws and accounting standards relating to revenue recognition.
G Turnover from April 2017 to June 2017 (-)
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137
Pt.
II
H Unbilled revenue at the end of Financial Year (-)
COMMENTS:
▪PARA 5H: Unbilled revenue (WIP) recorded on accrual basis in current FY but GST is
not payable not the same. (Tax invoice is also not raised in FY 17-18 and will be raised in
next FY)
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 same financial year shall be declared here.
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138
Pt.
II
COMMENTS:
▪PARA 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
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.
I Unadjusted Advances at the beginning of the Financial
Year (-)
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139
Pt.
II
J Credit notes accounted for in the audited Annual
(-)
COMMENTS:
PARA 5J: Value of credit notes which have been accounted for in Financial Statement but
were not admissible under Section 34 of the CGST Act shall be declared here
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.
Analysis
All the adjustments made in the Books of Accounts by way of adjustment [reduction] in the
turnovers by issuing a Credit Note shall be reckoned for this purpose. All the information in
the Credit Note register without having a GST effect should be collated and provided.
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140
Pt.
II
K Adjustments on account of supply of goods
by SEZ
units to DTA Units
(-)
COMMENTS:
▪PARA 5K: Value of goods supplied by SEZs to DTA for which the DTA units have filed
bill of entry shall be declared here.
Such outward supplies are not required to be reported by SEZ units in their GST Returns
and hence the data cannot be retrieved from the returns filed by such SEZ units.
SEZ units are is required to maintain records of the assets / goods admitted into the SEZ
unit and the details of disposal of such goods. Such records can assist an Auditor in
identifying the outward supply made by an SEZ unit. Additionally, disposal of capital goods
will be disclosed as deletion in Fixed Asset Registers.
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141
Pt.
II
L Turnover for the period under composition
scheme
(-)
COMMENTS:
There may be cases where Registered Persons might have opted out of the composition scheme during
the 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 under this Sl.No.
A person registered under the composition scheme who has opted out of the scheme he should file both
GSTR 9 and GSTR 9A. An Auditor may note that even a person violating the conditions stipulated in
Section 10 of CGST Act or Rule 5 of CGST Rules or Notification CT 8/2017 dated 27/06/2017 will stand to
exit the scheme. In such cases, the composition person should file form COMP-4 and opt out of the
scheme.
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142
Pt.
II
M Adjustments in turnover under section 15 and
rules the reunder
(+/-)
COMMENTS
There may be cases where the taxable value and the invoice value differ due to valuation
principles under section 15 of the CGST Act, 2017 and rules thereunder. Therefore, any
difference between the turnover reported in the Annual Return (GSTR 9) and
turnover reported in the audited Annual Financial Statement due to difference in
valuation of supplies shall be declared here.
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143
N Adjustments in turnover due to foreign
exchange fluctuations
(+/-)
Pt.
II
Any difference between the turnover reported in the Annual Return (GSTR9) and turnover
reported in the audited Annual Financial Statement due to foreign exchange fluctuations
shall be declared here.
COMMENTS
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144
O Adjustments in turnover due to reasons not
listed above
(+/-)
Pt.
II
Any difference between the turnover reported in the Annual Return (GSTR9) and turnover
reported in the audited Annual Financial Statement due to reasons not listed above shall
be declared here.
Analysis
The following broad head of adjustments can be reported under this Sl.No.: -
(a) turnover considered as ‘supply’ under GST but not considered as income in the audited
Annual Financial Statements;
(b) turnover discovered as ‘supply’ during the course of audit, but not considered in books
of account and Form GSTR 9
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145
 Incentives / Rebate received from supplier
 Sale of Capital Goods
 Return of pre-GST Inward Supplies
 Inputs and Capital Goods which is sent to a job worker but is not returned within
the prescribed period
 Notice Pay Recovery from Employees
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146
P Annual turnover after adjustments as above <Auto>
Q Turnover as declared in Annual Return (GSTR9)
R Un-Reconciled turnover (Q - P) AT1
Pt.
II
The turnover arrived at Sl.No. 5 P shall comprise of the following:
(a) taxable turnover of outward supply of goods and / or services;
(b) Exempt turnover of outward supply of goods and / or services;
(c) Non-GST outward supplies turnover;
(d) Exports of goods and / or services turnover;
(e) Outward supplies liable to GST under reverse charge mechanism.
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147
6 Reasons for Un - Reconciled difference in Annual Gross
Turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
Reasons for non-reconciliation 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.
This portion of GSTR 9C identifies the turnover differences to be placed on record for
explaining the differences between the GST Returns and the Audited Financials.
All the information filled up in the GST returns has to be flown from the Books of
Accounts.
However, the un-reconciled turnover on account of disclosure norms as per Accounting
Standard issued by ICAI or other statutory provisions or practice adopted by the
Registered Person on special approval basis, which are not reconciled at turnover level
should be disclosed in this Sl.No..
SN Panigrahi

Table 5R of GSTR 9C
Un-Reconciled
Turnover
Table 5Q of GSTR 9C Table 5P of GSTR 9C
Turnover as
Declared in
GSTR 9
Turnover as
Derived from
Audited Financial
Statement after
Adjustments
Gross Turnover
Table 5N
= 4N – 4G + 5M
& Table 10 & 11 of
GSTR 9
4N = Taxable Turnover
5M = Exempted Turnover
4G = Inward Supplies on
which Tax is to be Paid on
RCM
Table 6 of GSTR 9C
Reasons for
Un-Reconciled
Annual Gross
Turnover
GSTR 9C Part II
Table – 5 & 6
Reconciliation of
Gross Turnover

150
COMMENT:
▪ PARA 7A: It will be auto reflected
▪ PARA 7B: Amount net of Debit Note/ Credit Note to be reflected here.
▪ PARA 7C: Amount net of Debit Note/ Credit Note to be reflected here. SEZ Supplies under LUT are also be to be
reflected here.
▪ PARA 7D: Amount net of Debit Note/ Credit Note to be reflected here.
▪ PARA 7E: It will be auto reflected
▪ PARA 7F: This turnover may be derived from Sr.No. 4N of Form GSTR 9
▪ PARA 7G and 8: Reasons for non-reconciliation between adjusted annual taxable turnover as derived from Table
7E above and
the taxable turnover declared in Table 7F shall be specified here.
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151
7 Reconciliation of Taxable Turnover
A Annual Turnover after Adjustments (from 5P above) <Auto
B
Value of Exempted, Nil Rated, Non-GST supplies, No-Supply
turnover
7A : Annual turnover as derived in Table 5P above would be auto-populated here
.
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.
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152
Validation of Information
Clause 7B essentially comprises the following 4 classes / types of supplies:
(a) Supplies taxable at a ‘NIL’ rate of tax; currently there are no goods / services under
‘NIL’ rate category
(b) Supplies that are wholly or partially exempted from CGST, SGST or IGST, by way of a
notification; E.g.: Milk, water, education service, health care services etc.,
(c) Non-taxable supplies as defined under Section 2(78) of the CGST Act – supplies that
are not taxable under the Act (viz. alcoholic liquor for human consumption).
(d) No supplies include the activities covered under Schedule III which are neither a supply
of goods nor a supply of services. Examples- Sale of land or completed building,
actionable claims, other than lottery, betting, and gambling.
Exempted, Nil Rated, Non-GST supplies, No-Supply turnover
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153
C Zero rated supplies without payment of tax
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.
Analysis
Zero rated supply under the provisions of GST law means:
(a) Exports of goods or services or both.
(b) Supply of goods or services or both to Special Economic Zone developer /Special
Economic Zone unit.
The zero-rated supplies can be effected either by payment of tax or without payment of tax
upon filing letter of undertaking (LUT). Since, under Sl.No. 7 the taxable turnover as arrived
from the revenue recorded in the audited annual financial statement should be reconciled with
the taxable turnover as declared in the monthly returns / annual returns, only the zero-rated
supplies without payment of tax should be declared against Sl.No. 7C.
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154
What is the effect of non-receipt of consideration in convertible
foreign exchange within the prescribed time-limit for export of
services and its effect on GSTR-9C?
Ans. In terms of Rule 96A, it is specified that a taxable person would be liable to pay applicable tax
along with interest within fifteen days from the following date:
In case of services – after the expiry of one year or such further period as may be allowed by the
Commissioner from the date of issue of export invoice, if the payment is not received by the exporter
in convertible foreign exchange.
If the tax is remitted in terms of Rule 96A of CGST / SGST Rules, the relevant zero- rated
supplies should not be declared against Sl.No.7C since the tax on such supplies have been
remitted.
Being an inter-State supply that has failed the condition of repatriation of forex (only in case of
services), output tax will become payable on transactions earlier considered as export of services.
SN Panigrahi

SN Panigrahi 155
D Supplies on which tax is to be paid by the
recipient on reverse charge basis
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.
Analysis
Relevant Provisions
(a) Relating to goods: N.No.4/17 CT (R) and 4/17 IT (R) dt.28.6.17, as amended.
(b) Relating to services: N.No.13/17 CT(R) dt.28.6.17 and N.No.10/17 IT (R), as amended.
(c) As per S.17(3) of CGST/ SGST Act, 17, exempt supply shall include supplies on which recipient is liable
to pay tax under reverse charge. The meaning of this provision is that where a supplier is supplying goods/
services, the tax on which is liable to be paid by recipient then such supply of goods/ services would be
treated as exempt supply in the hands of such supplier.
Conclusion
It must be ensured that if the supplier has turnover which are liable to both forward charge and reverse charge then
the turnover liable to reverse charge ought to be accounted in FORM 7D.
It may be ensured for control purposes that aggregate of turnover under forward charge and reverse charge add up to
total turnover.

156
E Taxable turnover as per adjustments above (A-B-
C-D)
<Auto>
The data in Table 7A is auto populated from entry in Table 5P. Table 5P refers to ‘Annual
turnover after adjustments.
From the said turnover, the following turnovers are reduced:
(a) value of exempted turnover
(b) nil rated turnover
(c) Non-GST turnovers
(d) No Supply turnovers
(e) Zero rated turnover made without payment of tax
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157
F Taxable turnover as per liability declared in
Annual Return (GSTR9)
Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall be
declared here.
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158
G Unreconciled taxable turnover (F-E) AT 2
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159
8 Reasons for Un - Reconciled difference in taxable turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
Reasons for non-reconciliation between adjusted annual taxable turnover as derived
from Table 7E above and the taxable turnover declared in Table 7F shall be specified
here.
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160
This part of GSTR 9C identifies the taxable turnover differences to be placed on record for
explaining the differences between the GST Returns and the Audited Financials. All the
information filled up in the GST returns has to flow from the Books of Accounts. However, the
un-reconciled turnover on account of disclosure norms as per Accounting Standard issued by
ICAI or other statutory provisions or practice adopted by the Registered Person on special
approval basis, which are not reconciled at turnover level should be disclosed in this Sl.No..
For instance, the mechanism for determination of Revenue in case of Sale of a Capital Asset
shall differ for the value to be disclosed in GST Returns compared with that of the practice
adopted in Book of Accounts
Notes to GSTR 9C:
In case the invoice does not contain the declaration as required under Rule 46 or credit has
not been reversed under Rule 39, 42 or 43 or tax has been wrongly collected by
supplier on services liable for reverse charge (and retained by supplier), then such
infractions ought to be reported in Audit Report since the Audit Report requires disclosures
regarding non-maintenance of records and documents/ observations and inconsistencies
relating to reversals of credit.
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161
Provide a few illustrations of unreconciled differences to be reported in Sl No.8 of Form GSTR-9C.
Ans. Following illustrations can be considered for having the reconciliation differences to be
reported in Sl No.8 of Form GSTR-9C:
Zero-rated supply made by the Registered person during the previous year. However, conditions
relevant for the supply has not been complied by the Registered person, can be construed to be a
regular supply.
Transaction reported in a Delivery challan during the financial year for supply on sale or approval
basis beyond a period of six months shall be deemed to be a supply under GST.
However, that may not be a sale for revenue recognition in the books of accounts for such
transaction. Assuming GST returns carry the supply details and no revenue recognition has been
done in the books of accounts, this shall call for the reconciliation. Exemption conditions not fulfilled
by the Registered person while exercising the option to supply either a Nil rated of Exemption, shall
be reported as Regular Supply.
SN Panigrahi

GSTR 9C Part II
Table – 7 & 8
Reconciliation of
Taxable Turnover
Table 7G of GSTR 9C
Un-Reconciled
Taxable Turnover
Table 7F of GSTR 9C Table 7E of GSTR 9C
Taxable Turnover
as per Liability
Declared in
Annual Return
(GSTR 9)
Taxable
Turnover as per
Audited
Financial
Statement After
Adjustments
Taxable Turnover
Table 7A-7B-7C-7D
7A: Annual Turnover after Adjustments (from Table 5P)
7B: Value of Exempted, Nil Rated, Non-GST Supplies, No-Supply Turnover
7C: Zero Rated Supplies without Payment of Tax
7D: Supplies on which tax is to be paid by the recipient on Reverse Charge basis
Table 8 of GSTR 9C
Reasons for
Un-Reconciled
Taxable Turnover
Table 4N of GSTR 9

SN Panigrahi 163
Pt. III
Reconciliation of Tax Paid
9 Reconciliation of rate wise liability and amount payable thereon
Tax payable
Description Taxable Value Central
tax
State tax
/ UT tax
Integrated
Tax
Cess, if
applicable
1 2 3 4 5 6
A 5%
B 5% (RC)
C 12%
D 12% (RC)
E 18%
F 18% (RC)
G 28%
H 28% (RC)
I 3%
J 0.25%
K 0.10%
L Interest
M Late Fee
N Penalty
O Others
P Total amount to be paid as per
tables above
<Auto> <Auto> <Auto> <Auto>
Q Total amount paid as declared in
Annual Return (GSTR 9)
R Un-reconciled payment of amount PT 1

164
Rate wise details of tax Liability
7 rates of tax have been notified on supply of goods and services effecting the tax
liability during the year 2017-18. The said rate of taxes are Nil, 0.10%, 0.25%, 3%,
12%, 18% and 28%.
The rate wise details of tax liability to be punched in Table 9 firstly is to be bifurcated
in two parts namely for:
(a) Outward Supply
(b) Inward Supply
SN Panigrahi

165
Table No. Instructions
9 The table 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.
9P The total amount to be paid as per liability declared in Table 9A to 9O is
auto populated here.
9Q The amount payable as declared in Table 9 of the Annual Return (GSTR9) shall be
declared here. It should also contain any differential tax paid on Table 10 or 11 of the
Annual Return (GSTR9).
SN Panigrahi

166
Form GST DRC-03 now available on GST Portal for making voluntary payments by a
taxpayer
Form DRC-03 enables a taxpayer to make voluntary payments,
 before issue of Notice u/s 73 or 74 of the CGST Act, 2017
or
 within 30 days of issue of show cause notice (SCN).
Facility to intimate payment made voluntarily or made against SCN has now been enabled on GST
Portal (refer Rule 142(2) S. Rule 142(3) of the CGST Rules, 2017).
SN Panigrahi

167
10 Reasons for un-reconciled payment of amount
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
Reasons for non-reconciliation between payable / liability declared in Table 9P above and the
amount payable in Table 9Q shall be specified here.
Scope
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) GSTR 3B shows less/more tax paid
(B) GSTR 1 and GSTR 3B inter se matching but not with Audited Financials
(C) Taxable turnover as per books matching in GSTR 1 and GSTR 3B but tax is not
matching.
SN Panigrahi

GSTR 9C Part III
Table – 9 & 10
Reconciliation of Rate wise
Liability and Amount Payable
Table 9R of GSTR 9C
Un-Reconciled
Payment of Amount
Table 9Q of GSTR 9C Table 9P of GSTR 9C
Total Amount Paid
as declared in
Annual Return -
GSTR 9
Total Amount to be
Paid as per
Audited Financial
Statement
Rate wise Tax
Payable (Outward
Supply & Inward
Supply) + Interest +
Late Fee + Penalty +
Others
Table 10 of GSTR 9C
Reasons for
Un-Reconciled
Payment of
Amount
Table 9, 10, 11 of
Annual Return -
GSTR 9

SN Panigrahi 169
11 Additional amount payable but not paid (due to reasons specified under Tables
6,8 and 10 above)
Description Taxable Value
Central tax State tax
/ UT tax Integrated
tax
Cess, if
applicabe
1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Interest
Late Fee
Penalty
Others
(please specify)
Any amount which is payable due to reasons specified under Table 6, 8 and 10 above shall be declared here.
Table 6 : Un - Reconciled difference in Annual Gross Turnover
Table 8: Un - Reconciled difference in Taxable Turnover
Table 10 : un-reconciled payment of amount
SN Panigrahi

170
Additional Amount
Payable but Not
Paid
Due to Reasons
Specified under
Tables 6, Table 8
and Table 10
Table 6 :
Un - Reconciled difference in Annual
Gross Turnover
GSTR 9C Part III
Table - 11
Table 8 :
Un - Reconciled difference in Taxable
Turnover
Table 10 :
un-Reconciled Payment of Amount
Amount to be Paid through Cash
In GST DRC 03

171
Pt. Reconciliation of Input Tax Credit (ITC)
IV
12 Reconciliation of Net Input Tax Credit (ITC)
A
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)
B
ITC booked in earlier Financial Years claimed in
current Financial Year (+)
C
ITC booked in current Financial Year to be
claimed in subsequent Financial Years (-)
D
ITC availed as per audited financial statements or
books of account <Auto>
E ITC claimed in Annual Return (GSTR9)
F Un-reconciled ITC ITC 1
SN Panigrahi

172
13 Reasons for un-reconciled difference in ITC
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
Reasons for non-reconciliation of ITC as per audited Annual Financial Statement or books of
account (Table 12D) and the net ITC (Table12E) availed in the Annual Return (GSTR9) shall
be specified here.
Therefore, 13 of GSTR 9C looks out for the reason of difference between ITC claimed in
books of accounts and annual return. This should keep a check on unwarranted ITC being
availed by the Registered person.
SN Panigrahi

173
GSTR 9C Part IV
Table – 12 & 13
Reconciliation of
ITC
Table 12F of GSTR 9C
Un-Reconciled
ITC
Table 12E of GSTR 9C Table 12D of GSTR 9C
ITC Claimed in
Annual Return -
GSTR 9
ITC Availed as per
Audited Financial
Statement
Table 12D =
Table 12 A + 12B – 12C
Table 13 of GSTR 9C
Reasons for
Un-Reconciled
ITC
Table 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)
Table 12B : ITC booked in earlier Financial Years claimed
in current Financial Year
Table 12 C : ITC booked in current Financial Year to be
claimed in subsequent Financial Years
Table 7J of
Annual Return -
GSTR 9:
Net ITC Available

SN Panigrahi 174
14 Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on
Description Value
Amount of Total
ITC
Amount of eligible ITC
availed
1 2 3 4
A Purchases
B Freight / Carriage
C Power and Fuel
D
Imported goods (Including
received
from SEZs)
E Rent and Insurance
F
Goods lost, stolen, destroyed,
written off
or disposed of by way of gift or
free samples
G Royalties
H
Employees' Cost (Salaries,
wages, Bonus etc.)
I Conveyance charges
J Bank Charges
K Entertainment charges
L
Stationery Expenses (including
postage
etc.)
M Repair and
Maintenance
N Other Miscellaneous
expenses
SNPanigrahi

175
O Capital goods
P Any other expense 1
Q Any other expense 2
R Total amount of eligible ITC availed <<Auto>>
S ITC claimed in Annual Return (GSTR9)
T Un-reconciled ITC ITC 2
14 Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on
SN Panigrahi

176
15 Reasons for un - reconciled difference in ITC
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
SN Panigrahi

177
GSTR 9C Part IV
Table – 14 & 15
Reconciliation of ITC
Availed on Expenses
Table 14T of GSTR 9C
Un-Reconciled
ITC availed on
Expenses
Table 14S of GSTR 9C Table 14R of GSTR 9C
ITC Claimed in
Annual Return -
GSTR 9
Total Amount of
Eligible ITC as per
Audited Financial
Statement
Table 15 of GSTR 9C
Reasons for
Un-Reconciled
ITC Availed on
Expenses
Table 7J of
Annual Return -
GSTR 9:
Net ITC Available

178
16
Tax payable on un-reconciled difference in ITC (due to reasons specified in
13and 15 above)
Description Amount
Payable
Central Tax
State/UT
Tax
Integrated
Tax
Cess
Interest
Penalty
SN Panigrahi

179
Tax payable on
un-reconciled
difference in ITC
Due to Reasons
Specified in
Table 13 and
Table15
Table 13 :
Un - Reconciled difference in ITC
GSTR 9C Part III
Table - 16
Table 15 :
Un - Reconciled difference in ITC on
Expenses
Amount Payable

180
Pt. V Auditor's recommendation on additional Liability due to non-reconciliation
Description Value
Central tax State tax
/ UT tax Integrated tax
Cess, if
applicable
1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Input Tax
Credit
Interest
Late Fee
Penalty
Any other amount paid for supplies
not included in Annual Return SN Panigrahi

SN Panigrahi 181
GSTR 9C Part V
Auditor's Recommendation on Additional
Liability due to Non-reconciliation

182
Verification
I hereby solemnly affirm and declare that the information given herein above is true and correct to
the best of my knowledge and belief and nothing has been concealed there from.
**(Signature and stamp/Seal of the Auditor) Place: ……………
Name of the signatory ………………… Membership No………………
Date: ……………
Full address ………………………
SN Panigrahi

184
PART – B- CERTIFICATION
I. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by the person who had conducted
the audit:
* I/we have examined the—
(a) balance sheet as on ………
(b) the *profit and loss account/income and expenditure account for the period beginning from ………..…to ending on ……., and
(c) the cash flow statement for the period beginning from ……..…to ending on ………, — attached herewith, of M/s ……………
(Name), …………………….………… (Address),
..…………………(GSTIN).
2. Based on our audit I/we report that the said registered person—
*has maintained the books of accounts, records and documents as required by the IGST/CGST/<<>>GST Act, 2017 and the
rules/notifications made/issued thereunder
*has not maintained the following accounts/records/documents as required by the IGST/CGST/<<>>GST Act, 2017 and the
rules/notifications made/issued thereunder:
1.
2.
3.
2. (a) *I/we report the following observations/ comments / discrepancies / inconsistencies; if any:
…………………………………….
…………………………………….
SN Panigrahi

# Annual Returns – GSTR 9 & 9A + Audit GSTR 9C # By SN Panigrahi

# Annual Returns – GSTR 9 & 9A + Audit GSTR 9C # By SN Panigrahi

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# Annual Returns – GSTR 9 & 9A + Audit GSTR 9C # By SN Panigrahi