Points of caution for filing your GST Annual Return

By: Mr. Milind Kangutkar - 12th August, 2019

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GST Annual return once filed cannot be amended and hence filers need to be extra cautious to avoid any unnecessary losses that may arise from any error or omissions in the filing process

Tax payers need to be particularly cautious on the following points

a. File your annual GST return on time

Taxpayers should take note of this and file their GST returns well before the deadline as this could save this not only interest and penalties, but also the issue of a demand notice in cases where the GST return has not been filed.

b. Ensure a separate GSTR-9 return is filed for every State/Union Territory

GST returns are filed on the basis of a GSTIN held by a business. Businesses having operations in multiple States/UTs need to file a separate GSTR-9 annual return for each State/UT, and not for the entire company/business as a whole.

c. Proper treatment of data relating to April-June 2017 transactions

GST was introduced in India in July 2017, which means the first year of filing the annual return form GSTR-9 will only be for 9 months and not for the entire year. Taxpayers need to be extremely careful while reporting transactions for FY 17-18 as only data for the 9-month period i.e July 2017 to March 2018 needs to be reported.

d. Properly match the data filed in monthly and quarterly returns

Taxpayers should ensure that all monthly and quarterly filed returns match with the data reported in the GSTR-9. Mismatch of data could be one of the primary causes of getting a demand notice at a later date from the GST department. While the due date for making amendments to data of FY 17-18 has passed, taxpayers can still disclose any additional tax liability in the GSTR-9 return. The same can be paid in form DRC-03.

e. Correct segregation of data in the annual return

The annual GST return calls for the bifurcation of data across various fields such as input tax credit, HSN codes, demands and refunds, to name a few. This level of detail was not required at the time of filing the monthly or quarterly GST returns. Hence, a lot of digging into the books of accounts will be necessary to find and report this data accurately in the GSTR-9 return.

f. Maintain proper documentation

Before filing the annual return, it is the duty of the taxpayer to reconcile, verify and report only accurate information. In addition to this, the taxpayer should ensure that there is substantial documentary proof of all data that is reported in the return, in order to avoid unnecessary hassles at a later date.

g. File a Nil return where there are no transactions

Taxpayers registered under GST have to compulsorily file an annual return for the period up till which their registration is cancelled. Even in cases where there have been no transactions during the year, a 'Nil' return needs to be filed.

h. Filing GST Audit Report where turnover is above 2 crores

This is a new requirement applicable under GST which was not applicable under the previous Indirect Tax Laws. A business whose turnover exceeds two crore rupees is required to get their books of accounts audited by either a Chartered Accountant or a Cost Accountant, and a reconciliation statement between the audited financial statements and the annual return, furnished thereof, in form GSTR-9C.

Thanks for your patient reading.

Wishing you a hassle free and smooth GST filing experience.


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