Changes in GSTR-9 and GSTR-9C (Prem Shankar Mishra)

Summary of Changes in GSTR-9 and GSTR-9C made by CBIC videNotification No. 56/2019–Central Tax Dated 14.11.2019

A. Changes in GSTR-9

General Changes in GSTR-9

The Part or Table headings, Field names and Instructions have been amended to make the forms suitable for FY 17-18 and also for FY 18-19

Simplifications in GSTR 9 for FY 17-18 and FY 18-19:

Table 4 & 5 – Turnovers

In case the RP is unable to split the details as original amounts declared and adjustments made (credit/Debit notes, up/downward amendments), they can fill the net values in respective fields

Table 5D,E & F – Exempted/Ni-Rated/Non-GST

If the RP is unable to split the details among Exempted, Nil-rated and Non-GST supplies, entire amount can be disclosed under 5D – "Exempted"

Table 6 – Input bifurcation

If the RP is unable to split the total credit as Inputs/Input Services / Capital goods, then the entire amount can be disclosed as "Inputs" in respective tables

Table 6C & 6D: RCM on supplies from Regd. & Unregd.

If the RP is unable to split the details b/w RCM credit related to Inward supplies from regd. persons and unregistered persons, then the entire amount can be disclosed in 6D i.e. RCM on inward supplies from Regd. persons

Table 7A to 7E: ITC reversals under different categories

If the RP is unable to split the amount of credit reversals as per the given tables, entire amount can be disclosed as Other reversals.

However, Tran-1 and Tran-2 related reversals should be disclosed in the tables i.e. 7F & 7G.

Table 8:2A Reconciliation

For FY 17-18 and FY 18-19, the details of the amounts specified / differences observed can be attached in PDF format as part of 9C. No CA signature required for this.

For FY 17-18 and FY 18-19, following tables made optional.

Table 12 & 13 – ITC Adjustments for current year in next FY

Table 15 – Particulars of Demands and Refunds

Table 16 – Supplies from Composition / Deemed supplies / Deemed supplies under Sec 143

Table 17 & 18 – HSN wise summary for Outward & Inward supplies

B. Changes in GSTR-9C

General:

Few Instructions have been amended to make the forms suitable for FY 17-18 and also for FY 18-19

Simplifications for FY 17-18 and FY 18-19:

For FY 17-18 and FY 18-19, following tables were made optional.

Table 5B to 5N – Split in the Reconciliation of gross turnover, Total of the same can be mentioned in 5O-Residuary.

Table 12B & 12C – Reconciliation of Net ITC

Table 14 – Reconciliation of Expense wise ITC total to GSTR-9

Comments:

The changes in Table 5 & 12 seems to defeat the basic purpose of GSTR-9C.Though it is made optional, if the unreconciled/unexplained differences are high, the probability of receiving the enquiries from the department would be high.

Hence, it is suggested to disclose proper reconciliations in 9C unless the other option is beneficial.

C. Changes in Part-B – Certification

Para 1C-Cash flow statement – Made optional, RP to upload the same, only if the same is available

Para 5 – Expression of Opinion – The wordings have been changed from "True and Correct" to "True and Fair".

Prem S Mishra

Adv. & Tax-Consultant