FIRST EVER ANNUAL GST RETURN FILINGS – EVERYTHING YOU NEED TO KNOW

The time of the year has come where all your GST skills will be put to test. The first ever annual GST returns filing period. GST returns for the financial year from 1st July 2017 to 31st March 2018 needs to be filed by 31st March 2018 or before. There has already been an extension on the deadline and while you might wait till the last day to file your returns we suggest do it a little prior. The sole reason being, with so much traction and the first time GST returns, will be filled, the website ‘might’ just crash with heavy traffic. And the last thing one wants to do is pay a penalty over and above your GST returns.

This blog is going to cover most of the essentials you need to keep in mind while filing for the annual returns. As this is the first time such a large process is happening, there are a few pointers to keep in mind before you start the process. So let’s dive right into it. Curious to know the process of GST Filing of returns? Don’t worry, we’ve got you covered. Click here to know the process for GST Filing of Returns.

As per section 44(1) of the CGST Act, 2018, ‘every registered person, other than an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable person, shall furnish an annual return for every financial year electronically in such form and manner as may be prescribed on or before the thirty-first day of December following the end of such financial year.’

The government has introduced different categories for different variants of taxpayers such as normal taxpayers, taxpayers under the composition scheme, foreign non-residential taxpayers and so on. All registered taxpayers need to file for their annual returns, except

• Casual Taxable Persons
• Input Service Distributors
• Non – Residents Taxable Persons
• The person paying tax under TDS u/s 52 and TCS u/s 52

FORM FILLING PROCESS OF GST ANNUAL RETURNS

Once you have noted the category of taxpayer you fall under, there are different forms provided for different types of taxpayers. Only the form of the category you fall under needs to be filled. As per GST Rule 80, four types of annual returns have been established. The table below shows the different types of taxpayers and forms:

Category of Taxpayers	Form No.
Regular Taxpayer under Normal Scheme	GSTR -9
Taxpayer under Composition Scheme*	GSTR – 9A
E-Commerce Operator	GSTR – 9B
Taxpayer/Business Entity  – Turnover over 2 crore	GSTR – 9C

*Read our blog on composition scheme here.

All these returns need to be filled by 31st December 2018* and in case the deadline has not been met, there is a penalty to be paid. An 18% p.a. will be levied upon the taxpayer/business entity on the total amount taxable for every late return the taxpayer has paid. Additionally, an Rs. 100 per day for CGST (Central Goods and Service Tax) and Rs. 100 per day for SGST (State Goods and Service Tax) totalling off to Rs. 200 per day to a maximum cap of Rs. 5000.

*Latest Update as on 8th December 2018: Due date for filing GSTR-9, GSTR-9A, and GSTR-9C is extended till 31st March 2019 by CBIC for FY 2017-18

DETAILS REQUIRED IN THE GSTR – 9 FORM

The details of the GSTR-9 Form have been divided into a few parts. Starting from basic details to turnover and GST demands and refunds, this form covers everything you need to fill out for your returns. The table below explains the parts of the form and the information required thereof.

Part of GSTR – 9	Information needed
Part 1	Basic details such as PAN, Aadhar, address proof, business name, type of entity, etc. These details will be auto-generated
Part 2	Outward/Inward supplies during FY 17-18. Advances on which GST is applicable. The details of Debit notes and Credit notes have to be given. Details about Exempted, Nil Rated, and Non-GST Supplies also need to be provided.
Part 3	ITC declared in return files. These will also be auto-generated through previous filings. In Part 3, ITC Reversal or TRANS Credit Reversal details are to be mentioned. Thereafter, ITC not availed after matching with GSTR 2A will also be declared.
Part 4	Details of Tax paid in returns filed during the year. ITC adjusted as well as cash paid in the form of tax has to be given.
Part 5	Particulars of the transactions for the previous FY declared in returns of April to September of current FY or up to the date of filing of annual returns of previous FY whichever is earlier.
Part 6	Late Fees, GST Demands and refunds, quality of goods with HSN code, segregation of supplies with different categories of taxpayers

Declaration: This is mentioned at the end of the form post Part 6, mentioning that all information above provided is true and no information has been concealed or hidden. It ends with the signature of the authorised along with the details of the place, date and designation.

While you are preparing for your GSTR -9 form, the main information, and guidance needed to fill the form needs to be picked up from the GSTR – 1 and GSTR- 3B form that have been filled by the taxpayer/business entity throughout the year. The information filled in the GSTR-9 needs to be cross-referenced with these forms to ensure that all the data added in the form is accurate and matches with the previously filled out forms.

As this is the first annual GST returns, ensure that you follow all the steps correctly filings in the details required everywhere. It is not advisable to miss out on any viable information that could affect your returns. Any incorrect information can attract tax demands, interest and penalties on the same leave alone the long-term litigations that follow years later.

GSTR-9A and GSTR-9B are mostly on the similar lines of GSTR-9. The forms follow the same pattern as the one in GSTR-9. Most of the information the forms will be auto-generated through the process of previous filings of forms hence not a lot of work is required.

GSTR-9C: RECONCILIATION STATEMENT AND CERTIFICATE

All taxpayers/business entities doing business over Rs. 2 crores in turnovers annually need to fill out the GSTR-9C form. Along with, this form needs to be checked and audited by a CA for verification purposes.

GSTR-9C is a statement of reconciliation between:

• The Annual returns in GSTR-9 filed for an FY, first being 2017-18
• The figures as per Audited Annual Financial statements of the taxpayer

This form is quite similar to a tax audit report under the Income Tax Act. GSTR-9C has two major parts

• Part A: Reconciliation Statement
• Part B: Certificate

Part A

Part of GSTR – 9C: Part A	Information needed
Part 1	Basic details such as PAN, Aadhar, address proof.etc. These details will be auto-generated
Part 2	Reconciliation of Turnover declared in the Annual Statements
Part 3	Reconciliation of Tax Paid
Part 4	Reconciliation of Input Tax Credit
Part 5	Auditors recommendation on additional liability

Part B: Certificate

GSTR-9C – Part B is a certificate that has to be certified by the CA who conducted the GST audit or it can be by another CA who did not conduct the GST audit for that same taxpayer/business entity. The CA has to give his authority saying that all the claims are in place and the returns have been verified.

The difference between both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based the opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format for certification report will vary depending on who the certifier is.

This is mainly all that you need to keep in mind while filing for the first ever annual GST returns. Ensure all your documents are in place and along with the previous filings on the GST portal. Also if you have a few basic questions that need to be answered, read our blog on faqs on GST here.

That’s all from our end folks if you have any queries/doubts please leave them in the comments section below and we will ensure to answer them as soon as we can. Till then, happy filing!