Simplified GSTR 9 & 9C – Know Which Are Optional Tables in GSTR 9
On 14th November, 2019, Notification number 56/2019 was issued by CBIC which provided a huge relief to all registered taxpayers.
This notification not only aimed at extension of due date of GSTR 9 and GSTR 9C to 31st December, 2019 for FY 2017-18 but also provided for simplification of GSTR 9 and GSTR 9C forms that was announced in the 37th GST Council Meeting. The simplification of GSTR 9 Annual Return and GSTR 9C Reconciliation Statement is applicable for FY 2017-18 and FY 2018-19.
Simplified GSTR 9 With Optional Tables
Part II - Table 4 and Table 5
Part II contains details with respect to outward supply. Two substantial changes have been in this section.
A Registered taxpayer shall have an option to report the details in following tables net of credit notes, debit notes and amendments –
- Table 4B : Supplies made to registered persons (B2B)
- Table 4C: Zero rated supply (export) on payment of tax
- Table 4D : Supply to SEZ on payment of tax
- Table 4E: Deemed Exports
- Table 5A: Zero rated supply (export) without payment of tax
- Table 5B: Supply to SEZ without payment of tax
- Table 5C: Supplies on which tax is to be paid by the recipient on reverse charge basis
- Table5D: Exempted Supply
- Table 5E: Nil Rated Supply
- Table 5F: Non-GST supply
B An option has been made available to all registered taxpayers to consolidate values under Table 5D - Exempted Supply instead of bifurcation under Table 5D – Exempted Supply, Table 5E – Nil Rated Supply and Table 5F – Non-GST Supply.
Part III – Table 6, 7 and 8
Part III contains details with respect to input tax credit availed during the year. The following updates / changes have been made –
A. Input tax credit amount may be reported under inputs row rather than bifurcation into inputs, capital goods and input services. Such bifurcation is optional.
B. ITC on reverse charge for supplies received from registered and unregistered persons can be clubbed and reported under Table 6D - Inward supplies received from registered persons liable to reverse charge on which tax is paid and ITC availed. No bifurcation required
c.Reversals on account of various rules (Table 7A to Table 7E) can be clubbed and reported under Table 7H – Other Reversals. However, reversals for Tran-I (Table 7F) and Tran-II (Table 7G) shall be reported separately only.
D. Table 8A to 8D details may not be filled here in GSTR 9 but can be uploaded in PDF format in GSTR 9C without CA certification. Table 8A to Table 8D requires details for comparison of ITC available as per GSTR 2A and ITC availed as per books of accounts.
Part V – Table 12 and Table 13
A registered taxpayer has an option to not fill the following tables for FY 2017-18 and 2018-19 –
-Table 12 : Reversal ITC availed during previous financial year
-Table 13: ITC availed for the previous financial year.
Part VI – Table 15 to Table 18
The following tables have been made optional and a registered taxpayer may or may not fill information these tables –
-Table 15 : Details for demands and refunds
-Table 16 : Other Information with respect to goods received from composition taxpayer, goods sent on approval basis and goods sent on job work basis
-Table 17 : HSN summary for outward supply
-Table 18 : HSN summary for inward supply
Simplified GSTR 9C - New Changes
It is not compulsory to upload cash flow statement and has been optional.
Under Part B – Certification, words true and correct opinion has been replaced with true and fair opinion.
The following tables have been made optional i.e. information may or may not be reported –
- Table 5 – Reconciliation of annual turnover - Any adjustment required may be directly reported under “Table 5O - Adjustments in turnover due to reasons not listed above”. No requirement to show bifurcation under Table 5B to 5N.
- Table 12 – A registered taxpayer has been given an option to not fill information in Table 12B : ITC booked in earlier Financial Years claimed in current Financial Year and Table 12C : ITC booked in current Financial Year to be claimed in subsequent Financial Years
- Table 14 – A registered taxpayer has an option of not reporting information under Table 14 -Reconciliation of ITC declared in Annual Return (GSTR-9) with ITC availed on expenses as per audited Annual Financial Statement or books of account
New GST Circular 124/43/2019
On 18th November 2019, circular number 124/43/2019 in support of notification no. 47/2019 dated 9th October, 2019 was issued by CBIC.
The circular clarifies that where an option was provided to taxpayers having turnover below Rs 2 crores to not file GSTR 9 / 9A shall file their GSTR 9 / 9A within the due date if they want to file these returns.
If the returns are not filed within the said due date, the portal shall not permit filing of these returns.
Further, a taxpayer can discharge any additional liability using Form DRC-03.
The simplified GSTR 9: Annual Return and GSTR 9C: Reconciliation Statement has been made taking into consideration the difficulties faced by the taxpayers and with a view to encourage them to file returns within the due date specified.
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