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FORM GSTR-9C

FORM GSTR-9C. PRATIK SUDHIR SHAH CHARTERED ACCOUNTANT 9819122318 pratiksh2704@gmail.com. LEGAL PROVISIONS. R. 80(3) Every registered person whose aggregate turnover during a financial year exceeds Rs. 2 crore shall get his accounts audited as specified under S. 35(5) and

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FORM GSTR-9C

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  1. FORMGSTR-9C PRATIK SUDHIR SHAH CHARTERED ACCOUNTANT 9819122318 pratiksh2704@gmail.com CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  2. LEGALPROVISIONS • R.80(3) • Every registered person whose aggregate turnover during a financialyear • exceeds Rs. 2crore • shall get his accounts audited as specified under S. 35(5)and • he shall furnish a copy of audited annual accountsand • a reconciliationstatement, • duly certified, in FORMGSTR-9C • S.35(5) • Every registered person whose turnover during a financialyear • exceeds the prescribedlimit • shall get his accounts audited by a chartered accountant or a cost accountant and • shallsubmit- • a copy of the audited annualaccounts, • the reconciliation statement under S. 44(2)and • such other documents in such form and manner as may beprescribed. • S.44(2) • Every Registered Person who is required to get his accounts audited in accordance with provisions of Sec 35(5) shall • furnish,electronically, • the annual return under S.44(1) • along with a copy of the audited annual accountsand • a reconciliation statement, reconciling the value of supplies declared in the return furnished for the financial year with the audited annual financial statement,and • such other particulars as may beprescribed CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  3. FAQ ON APPLICABILITY OF GSTR 9C Q1. Mr A is supplier of Taxable Goods. During the period 1st July 17 to 31st March 18, Mr A had turnover of Rs 5 Crores + GST. Whether Mr A is liable to GST Audit ? Ans: Yes,GST Audit is Applicable as Aggregate Annual Turnover us exceeding Rs 2 Crores. Q2. Mr A is supplier of Taxable and Exempt Goods. During the period 1st July 17 to 31st March 18, Mr A sold Taxable Goods of Rs 1.5 Cr + GST and Exempt Goods of Rs 60 Lakhs. Ans: Yes, as per Section 35(5) read with rule 80(3), GST Audit is applicable if your Aggregate Annual Turnover in a Financial Year exceeds Rs 2 Crores. Aggregate Annual Turnover includes both Taxable and Exempt Supplies. 66 CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  4. FAQ ON APPLICABILITY OF GSTR 9C 66 Q3. Mr A has GST Registration in state of Maharashtra and Delhi. In Maharashtra his turnover was 1.25 Crore and in Delhi his turnover was 1.5 Crore. Whether Mr A is liable for GST Audit in Maharashtra or Delhi or Both? Ans: Yes, Section 35(5) read with Rule 80(3) does not use “Turnover in a State”. It states GST Audit shall be applicable when Aggregate Annual Turnover exceeds Rs 2 Crores. Hence PAN Indian Turnover should be calculated to determine whether GST Audit is applicable or not. Q4. Mr A has taxable turnover of Rs 2.5 Crores for the period 1st July 17 to 31st March 18. However he has not taken registration till date. Whether Mr A is required to file GSTR 9C ? Ans: Section 35(5) read with Rule 80(3) says “Every Registered Person”. In this case Mr A is not registered under GST in FY 2017-18 hence GST Audit is not applicable. As per my opinion GST Audit should be made applicable in this case as Mr A is actually liable to Audit. He should also be subjected to Penalty under Section 73 or 74 as case may be CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  5. FORMGSTR-9C CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  6. FORMGSTR-9C 16 CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  7. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) The turnover as per the audited Annual Financial Statement shall be declaredhere. There may be cases where multiple GSTINs (State-wise) registrations exist on the same PAN. This is common for persons/ entities with presence over multipleStates. Such persons/ entities will have to internally derive their GSTIN wise turnover and declare the samehere. This shall include export turnover (ifany). It may be noted that reference to audited Annual Financial Statement includes reference to books of accounts in case of persons/ entities having presence over multipleStates. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  8. FORMGSTR-9C INSTRUCTIONS (As Appended below FORM GSTR-9C) Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of accounting in the last FY and was carried forward to the currentFY. Inotherwords,whenGSTispayableduringthefinancialyearonsuchrevenue(whichwas recognized earlier), the value of such revenue shall be declaredhere. For example, if Rs. 10 crore of unbilled revenue existed for the financial year 2016-17, and during the current financial year, GST was paid on Rs. 4 crore of such revenue, then value of Rs. 4 crore shall be declaredhere S.31(2) an invoice for supply of services may be issued within 30days. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  9. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Unbilled revenue which was recorded in the books of accounts on the basisof accrual system of accounting during the current FY but GST was not payable on such revenue in the same FY shall be declaredhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  10. FAQ on Unbilled Revenue Case Study 1: Unbilled Revenue Mr A had provided consultancy services to Mr B of Rs 1,00,000. Services got completed on 25th March 2018 however invoice for the same was raised on 5th April 2018 (within 30 days of completion of service). Mr A have booked revenue in P n L Account in FY 2017-18 as he was following Mercantile System. Ans: Mr A must have booked income in Profit and Loss A/c as per IND AS in FY 2017-18. However he must have booked Income in GST Returns in FY 2018-19 as Invoice is raised in April 2018 as per Sec 31. Hence GST Turnover is lower than profit and loss t/o which calls for reconciliation. on. Case Study 2: Unbilled Revenue Mr A is providing services of construction to Mr B. Contract Value is Rs 10,00,000. As per agreement invoice shall be raised by Mr A and payment shall be made by Mr B only after completion of Construction. As on 31st March 2017, 60% of construction was completed hence MrA booked revenue in P n L Account of Rs 6,00,000 (10L * 60%) as per proportionate completion method (AS 7). Construction got completed on 15th July 2017 hence Mr A raised an invoice of 10,00,000 + GST in July 2017. Ans: Mr A must have booked Income of Rs 6 Lakhs in Profit and Loss A/c as per “Proportionate Completion Method” in FY 2016-17. However Entire Invoice of Rs 10 Lakhs + GST was raised in FY 2017-18. Hence GST Turnover is lower than profit and loss t/o which calls for reconciliation.. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  11. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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 declaredhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  12. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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 declaredhere. As GSTR-9C is being filed for the first time for the FY 2017-18, there is no room for unadjusted advances at the beginning of FY17-18. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  13. FAQ on Unadjusted Advances Case Study : Unadjusted Advances Q. MrA received advances on services on 28th March 2018 of Rs 5,00,000 + GST. Services got completed on 5th April 2018 and invoice was raised on same date. Ans: MrA must have booked Amount of Rs5,00,000 in Balance Sheet under Advances. It is not part of Profit and Loss A/c in FY 2017-18. However as per Time of Supply of Services under GST Law, GST Liability is attracted as soon as Advances is received. Hence it is forming part of Turnover under GST in FY 2017-18. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. Case Study : Unadjusted Advances Q. MrA received advances on services on 20th February 2017 of Rs 2,00,000 + Service Tax. Services got completed on 5th July 2017 and invoice was raised on 5th July 2017. Ans: Mr A must have booked Amount of Rs 2,00,000 in Balance Sheet under Advances. It is not part of Profit and Loss A/c in FY 2016-17. However Mr A has paid Service Tax in FY 2016-17 as Service Tax is applicable on Advances Received on Services. In this case, Mr A has raised an Invoice on 05th July 2017 hence it is required to raise an Invoice of Rs 2 Lakh + GST and take credit in Tran 1 of Service Tax already paid in FY 2016-17. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  14. FORMGSTR-9C Advances not to beconsidered- Against goods (after 15-Nov-2017) (13-Oct-2017 for GTO below 1.5crore) Against exemptedservices Deposits and securitiesreceived Loans andAdvances RevenueRecognition- AS-9: Revenue from sale of goods is recognized at the time of transfer of risks and rewards & revenue from services is recognised as the service isperformed CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  15. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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 includedhere. Schedule-I transactions may be verified through challans and e-waybills CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  16. CASE STUDIES FOR GSTR 9C 66 Case Study : Deemed Supply under Schedule I Q. MrA had two branches, 1st branch in Maharashtra and 2nd in Delhi. He transferred goods worth Rs 2,00,000 + GST from Maharashtra to Delhi. Such transfer was shown as Branch Transfer and not considered as Sales in P n L Account. Ans: Branch transfer outside the state are subjected to GST. Hence such branch transfer shall form part of GST Turnover. However there is no such provision in Accounting standard and hence Profit and Loss A/c shall not include Rs2 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. Case Study : Deemed Supply under Schedule I Q. MrA bought Air Condition in July 2017 for 1,28,000 (1 lakh + 28% GST). Mr A had taken set off of Rs 28,000. Later Mr A took Air Condition at home without any consideration. Mr A knew concept of Deemed Supply hence considered transfer of AC as Supply (Net Value = Rs 1 Lakh) and paid GST of Rs 28,000. Ans: As per Schedule I of CGST Act, Permanent Transfer or disposal of business assets on which ITC is availed shall be subjected to GST. Hence AC permanently transfer shall be considered as T/O in GST Act. However there is no such provision in Accounting standard and hence Profit and Loss A/c shall not include Rs1 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  17. FORMGSTR-9C 27 Para 1 of Schedule-I: Permanent transfer or disposal of business assets where ITC has been availed on such assets, e.g. stock transfers, assets donated, de- commissioning of plants, impairment of assets, assets taken byowners Para 3 of Schedule-I: Transaction between principal and his agent, e.g. in GST gross amount is shown in the hands of the agent whereas in financials only commission is shown Para 4 of Schedule-I: Import of services from a related person, e.g. foreignbranch supplying manpower to HO in Delhi; sharing of cloudservices CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  18. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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 (FORM GSTR-9) shall be declaredhere. CN issued during FY 2018-19 may not be given effect to during FY2017-18. GSTR-9 captures this detail from Table 11 [Supplies/ tax reduced throughamendments (-)(net of creditnotes)] If 5A is net turnover (on accrual basis) then it may be added to match with the gross turnover ofGSRT-9. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  19. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Trade discounts which are accounted for in the audited Annual Financial Statement but onwhich GST was leviable (being not permissible) shall be declaredhere. Types ofdiscounts- Special discount: On any extraordinary purchase made bycustomers Bonus Discounts: On negotiations made aftersales Incentives: Given on achieving targets and making sales without reducing salesprice Remission: General fall inprices Compensation: Significant correction ofprices CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  20. Case Study : Trade Discounts accounted for in the audited Annual Financial Statement but are not permissible under GST Mr A is supplier of Goods. During the year Mr B had purchased more than 100 quantity from MrA, hence Mr A decided to give him discount of Rs 5,000. Mr B issued credit note (Financial credit note without reducing GST) of Rs 5,000 and reduced it from Sales of FY 2017-18. Ans: • Mr A have reduced Sales in Profit and Loss Account to extent of Rs 5,000 (Discount). • However such discount shall not have any impact in GST Turnover as Mr A has not reduced GST on discount as discount was not agreed before or during the supply and Credit Note is Financial Credit Note. • Hence GST Turnover is lower than profit and loss t/o which calls for reconciliation.. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  21. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Turnover included in the audited Annual Financial Statement for April 2017 to June 2017 shall be declaredhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  22. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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. It may include credit notes which were issued otherwise than S. 34 read with R. 53i.e. financial credit notes, e.g. cash discount offered for early payment bydebtors CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  23. FORMGSTR-9C FAQ for Point 5J - Credit notes accounted for in the audited Annual Financial Statementbut are not permissible under GST (-) Q 1- What is the effect of Credit notes issued in relation to exempt supplies, zero-rated supplies and non-GST outward supplies? Supply of exempt, zero-rated and non-GST outward supply of goods and / or services are not liable to GST. In such a scenario, the credit notes issued for claiming reduction in the taxable value shall be recorded in the audited annual financial statements. Such credit notes should be declared against Pt. II Sl. No. 5J of Form GSTR 9C Q2- What are the implications upon issuance of financial credit notes? Financial credit notes would not adjust the amount of GST involved in the original tax invoice issued at the time of supply of goods and / or services. Accordingly, the transaction value of supply of goods and / or services shall stand reduced although tax paid thereon remains the same. This may result in higher amount of GST being paid considering the adjusted value of original supply. Since, the value of financial credit notes is to be reduced from the financial statements and not the GST Annual returns, it is required to be adjusted in 5J of Form GSTR 9C. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  24. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Aggregate value of all goods supplied by SEZs to DTA units for which the DTA units have filed billof entry shall be declaredhere. Supplies by SEZs to DTA units for which DTA units have filed bill of entry, such transaction does not form part of GST turnover as that is not reported by SEZ unit in its GST returns. [Refer Rule 58 of SEZ Rules,2006] CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  25. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) There may be cases where registered persons might have opted out of the composition scheme during the current financialyear. Their turnover as per the audited Annual Financial Statement would includeturnover both as composition taxpayer as well as normaltaxpayer. Therefore, the turnover for which GST was paid under the composition scheme shall be declared here. This amount can be taken from clause 6C of GSTR-9A, which is the sum total of table 6 [Tax on outward supplies] and 7 [Amnd. to outward supplies] of GSTR-4. Besides this exempted supplies of traders are to be extracted from the books ofaccounts CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  26. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) 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 there under. Therefore, any difference between the turnover reported in the Annual Return (FORM GSTR-9) and turnover reported in the audited Annual Financial Statement due to difference in valuation of supplies shall be declaredhere. (+) The differences arose on account of netting off of certain expenses in financials whereas the same are shown as turnover inGST CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  27. Case Study : Adjustments in turnover under section 15 and rules thereunder Q. MrA had sold goods for Rs 1 Lakh + 5000 GST to Mr B. Credit period was 30 days. Mr B paid money after 30 days hence Mr A charged Interest of Rs 1000 + GST. Interest was shown in “Other Income” in Profit and Loss A/c. Ans: Mr A has received Interest Income in relation to Supply made of Rs 1 Lakh. Hence GST shall be applicable on Interest Income of Rs 1,000. MrRs 1000 is forming part of GST Turnover. However it is not forming part of Sales in Profit and Loss A/c as Mr A has booked it in Other Income. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. Case Study : Adjustments in turnover under section 15 and rules thereunder Q. MrA is developer. He gave contract of construction of Rs 1 Cr to Mr B. Contract specified that all materials, labour, other services shall be responsibility of Contractor. Later Mr A (Developer) had cement in his godown hence supplied Cement free to Mr B (Contractor). Mr B (Contractor) completed construction and charged invoice of only Rs 1 Crore + GST. However he booked 80 lakhs as Revenue in P n L Account. Ans: As per GST Law, any expenses incurred by Receiver which ought to be incurred by Supplier of Services must be included in Value of Supply and GST shall be applicable. In given case, Mr A (Receiver) gave cement of Rs 20 lakhs to Mr A (Supplier). Such expenses should have been incurred by Supplier as contract specified entire responsibility is of Supplier. Hence GST shall be applicable on entire Rs 1 crore. However in Profit and loss account revenue of only Rs 80 lakhs shall be booked. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  28. FORMGSTR-9C (+) Taxes other than GST paid and recovered from customers whereas the same are taken in turnover as per valuation underGST (+) Free of cost supplies made by the contractee which do not reflect in the Financials of the contractor whereas the same is taken in turnover by the contractor for valuation purposes underGST (+) Incidental expenses like commission, packing, handling charges paid by the supplier before delivery and recovered from the customer and being net off in P&L A/c but shown as GST turnover in terms of valuationprovisions (+) E-comm. operator compensating vendors participating in mega sales. Such discounts are offered through financial credit notes in the form of subsidy being net off with commission paid tooperator CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  29. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Any difference between the turnover reported in the Annual Return (GSTR-9) and turnover reportedin the audited Annual Financial Statement due to foreign exchange fluctuations shall be declaredhere. The GST valuation has to be derived by considering the rate of exchange as specified in Rule 34 i.e. ROE as notified by CBIC for the date of time of supply of goods (S. 14 of Customs) and ROE as per GAAP for the date of time of supply of services. In books ROE is as perAS-11. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  30. Case Study : Adjustments in turnover due to foreign exchange fluctuations PQR Limited has exported goods to a Company located in USA. The value of goods is $100,000. The exchange rate (Rs/$) on the date of filing Shipping Bill are • CBEC Rate: Rs 65 • RBI Rate: Rs 68 • At the time of receipt of money bank has exchanged foreign currency at Rs 70. Ans: As per GST Law, Revenue must be booked under GST as per CBEC rate for Goods Exported. Hence GST Turnover as per GST Law is Rs 65,00,000/ As per Accounting Standards, Revenue must be booked in Profit And Loss Ac as per RBI Rate for Goods Exported. Hence Turnover as per Profit and Loss Ac is Rs 68,00,000 Hence Reconciliation of Rs 3,00,000 in GSTR 9C. PQR received money of Rs 70,00,000 (70 * 100000) hence difference of Rs 2,00,000 (Amount Received of Rs 70 lakhs less Income booked as per RBI Rate of Rs 68 Lakhs) shall be booked as Income in Profit and Loss Ac as “Foreign Exchange Fluctuation. Such Foreign Exchange Fluctuation is required as per Accounting Standard only and it shall not have any impact on GST Turnover. Hence Reconciliation of Rs 2,00,000 in GST 9C. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  31. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Any difference between the turnover reported in the Annual Return (FORM GSTR-9) and turnover reported in the audited Annual Financial Statement due to reasons not listed above shall be declaredhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  32. CASE STUDIES FOR GSTR 9C 66 Case Study : Adjustments in turnover due to reasons not listed above Q. Co A recovered Notice Pay from Employees Rs 50,000 + GST. Co A recovered GST on Rs 50,000. Such income was not shown as Sales or other income in P n L. It was reduced from Salary Expenses. Ans: As per Section 7 read with Schedule II, Act of Tolerance is also supply under GST. Hence Rs 50,000 is forming part of GST T/O. However in Profit and Loss Ac, Rs 50,000 is not forming part of Sales as it is reduced from Salary Expenses. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. Case Study : Adjustments in turnover due to reasons not listed above Q. MrA had sent goods to Mr B on sale or approval basis in Aug 2017. Goods were neither approved nor returned by Mr B within 6 months. Hence Mr A considered same as Supply (5Lakh +5% GST) as goods are not approved / returned within 6 months. Ans: As per GST Law, if goods sent on approval are not approved or returned within 6 months than is shall be deemed as Supply under GST Law and shall be subjected to GST. Hence Rs 5 lakhs shall be booked as Turnover under GST. However there is no such provision in Accounting standard and hence Profit and Loss A/c shall not include Rs 5 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  33. CASE STUDIES FOR GSTR 9C 66 Case Study : Adjustments in turnover due to reasons not listed above Q. MrA sent goods for Job Work to Mr B in Aug 2017. Goods were not returned by Mr B within 1 year. Hence Mr A considered same as Supply (2Lakh + 5% GST) under GST as goods are not returned within 1 year. Ans: As per Section 143 of CGST Act, Inputs sent on Job work must be returned within 1 year. If it is not received than it shall be considered as Deemed Supply under GST Law. Hence Rs 2 lakhs shall for part of GST Turnover. However there is no such provision in Accounting standard and hence Profit and Loss A/c shall not include Rs2 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for reconciliation. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  34. FORMGSTR-9C Physician sample distributed by the pharmaceutical company to physician for free Notice pay recovered fromemployees Gifts given to customers/ vendors/distributors Stocks issued to discharge CSRobligation Incentives/ Rebate received from supplier and considered as supply underGST Salespromotion/advertisementreimbursementreceivedandconsideredas supply Out of pocket expenses considered in the value ofsupply Value on which GST paid on sale of CapitalGoods CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  35. FORMGSTR-9C (-) Profit on sale of Capital goods disclosed in audited Annual FinancialStatements Loss on sale of Capital goods disclosed in audited Annual FinancialStatements Inward supply returns considered as Outwardsupply (-) Outward supply returns considered as Inwardsupply (-) Income in Profit and Loss account recognized based on specialcircumstances Value on which GST is liable to be paid in respect of transactions where income is recognized based on specialcircumstances Discounts which are not to be excluded from the value of supply as per S.15 Any otheramount CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  36. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Annual turnover as declared in the Annual Return (FORM GSTR-9) shall be declared here. This turnover may be derived from Sr. No. 5N [Total turnover on which tax is payable and tax is not payable but does not include inward supplies liable to RCM], 10 [Supplies/ tax declared through amendments (+)] and 11 [Supplies/ tax reduced through amendments(-)] of Annual Return (FORMGSTR-9). CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  37. FORMGSTR-9C • Taxable, exempted or non-GST outward supplies not declared in annual returns will form part of auto-computed value in thisTable • FORM GSTR-9C do not specifically provide toclaimthebenefitoftaxpaid erroneously CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  38. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Reasons for non-reconciliation between the annual turnover declared in the audited Annual Financial Statement and turnover as declared in the Annual Return (FORM GSTR-9) shall be specifiedhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  39. FORMGSTR-9C Reasons for reconciliation difference couldbe- Capital Gain/ Loss on sale of Fixed Asset recorded in books for turnover purpose comparedwith total consideration available inGST Transaction reported in Delivery Challan for supply on sale or approval basis beyond a period of 6 months shall be deemed to be supplyunder GST but may not be a sale for revenue recognition inbooks CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  40. FORMGSTR-9C 50 CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  41. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) The table provides for reconciliation of taxable turnover from the audited annual turnover after adjustments with the taxable turnover declared in annual return (FORMGSTR-9). CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  42. FORMGSTR-9C INSTRUCTIONS (As Appended below FORMGSTR-9C) Reasons for non-reconciliation between adjusted annual taxable turnover as derived from Table7E above and the taxable turnover declared in Table 7F shall be specifiedhere. CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  43. Part IV. Reconciliation of Input TaxCredit Reconcile CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  44. 12A. ITC availed as per auditedfinancials • Single GSTIN (From 1st July2017) • ITC ledger to be taken from financials (both revenue and capitalizeditems) • ITC availed to be considered whether it is utilized or not • ITC reversals and reclaimed to be considered to arrive at ITCavailed • ITC to be collated from net of debits and credits of the ITC ledger • ITC on reverse charge to beincluded • ITC receivable not to beconsidered • In case of single ledger for liability and ITC, suitable mechanism for derivation and assurance in the form of corroborative evidence to betaken CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  45. 12A. ITC as per audited financials 34 CGST/SGST/IGST CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  46. 12C. ITC booked in current FY to be claimed in later Fys(-) • All credits shown in FY 2017-18 in books but claimed in GSTR 3B of FY2018-19 • Credit which satisfies the conditions of eligibility in 2018-19 though booked in2017-18 • If shown in ITC receivable in books, it is not to be considered asbooked • Only if credit taken in the ITC ledger in books, it is to beconsidered • All GSTR 2A transactions on which ITC not taken in 2017-18 not to be reportedhere CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  47. 12D (Audited financials) vs 12E (Annualreturn) 12D. ITC availed as per audited financial statement or books ofaccount ITC availed as per audited financial statement or books of account as derived from values declared in Table 12A, 12B and 12C above will be auto populatedhere 12E. ITC claimed in Annualreturn Net ITC Available for utilization as declared in Table 7J of Annual return (GSTR 9) shall be declaredhere CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  48. 13. Reasons for unreconciledITC • Particularly relevant statutory auditors have not reconciled with returns/ECL and return filers did not have a look at thebooks • Whether credit is actually eligible or not is not to be checked in thistable • ITC as per books > ITC as per return (less crucial forDepartment) • Recognition of accrued expenses with GST before time ofsupply • Recognition of ITC at the time of receipt ofadvances • Rightful eligible credits not availed in returns though in books and GSTR 2A for any reason (disputed, genuine, mistakeetc.) • Breakup of ineligible ITC shown inbooks • ITC reversal or refund application claim not passed/incorrectly passed inbooks • Receipt of excess credit from ISD as perbooks CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  49. 13. Reasons for unreconciledITC • ITC as per books < ITC as per return (more crucial forDepartment) • Breakup of GST not shown in the expenses/capitalgoods • ITC of another GSTIN claimed inreturns • ITC claimed based on GSTR 2A without actual incurring theexpenses • ITC incorrectly reported at a higher figure inreturns • ITC reclaimed or refund rejection claim not passed/incorrectly passed inbooks • Duplicate ITC availed inreturns • ITC availed after the closure of books of accounts wherein no ITC wasshown • ITC claimed in return even though depreciation claimed on ITC inbooks • Non reconciliation may be on account of incorrect filling up of Form GSTR9 CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

  50. Amount of total ITC vs Eligible ITCAvailed CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

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