GST Returns
Returns under GST: Returns are an essential part of the GST ecosystem. A return is a document in which the taxable person reports the details of business transactions executed during the period. In the context of GST law, the person registered under GST law has to report details of sales and purchases periodically in different returns. Periodicity and manner of filing GST returns depend on the nature of registration obtained and turnover.
1.1.
Need to file returns under GST: GST
is a self- assessment-based tax. Return is an important
document for taxpayers as
well as for the government. Return is an important
link of interaction between the taxpayer and the government. Filing of periodic returns is important for the following reasons-
• Determination of correct tax liability of the registered person
• Returns provide important information to the government for necessary policy decisions.
•
Filing of
correct and timely
returns ensures compliance with the provisions
of the GST law. This will help a registered person
to improve the proposed compliance rating under the GST law.
•
Returns are one of
the important and primary documents for the government during
the assessment and audit of the registered person.
1.2.
Types of returns
or statements a registered person is required to furnish under GST: The Central Goods
and Services Act, 2017
(hereinafter referred to as “CGST
Act”) and State Goods and Services Tax Act. 2017 prescribes the following returns and statements
under Chapter IX of the CGST Act-
|
Sl. No. |
Type of Return or state- ment |
Rele- vant Section |
Rele- vant Rule |
Description |
Periodicity of filing return/ Statement |
|
1. |
Form GSTR-1 |
Section 37 |
Rule 59 |
Details of
outward supplies |
Monthly/ Quarterly |
|
2. |
Form GSTR-2A |
Section 38 |
Rule 60 |
Details of
auto- drafted supplies |
Not to be furnished (Auto drafted) |
|
3. |
Form GSTR-2B |
Section 38 |
Rule 60 |
Auto-drafted ITC Statement |
Not to be furnished (Auto drafted) |
|
4. |
Form GSTR-3B |
Section 39 |
Rule 61 |
Return |
Monthly/ Quarterly |
|
5. |
Form GSTR-4 |
Section 39 |
Rule 62 |
Return for taxpayers who have opted for composition scheme or availing benefit under Notification no 02/2019
–Central Tax (Rate) |
Annually |
|
6. |
Form GSTR–5 |
Section 39 |
Rule 63 |
Return for Non- resident taxable person |
Monthly |
|
7. |
Form GSTR–5A |
Section 39 |
Rule 64 |
Details of supplies of online information and database access or
retrieval (OIDAR) services person located outside India made to non-taxable persons in India |
Monthly |
|
8. |
Form GSTR–6 |
Section 39 |
Rule 65 |
Return for Input Service
Distributor |
Monthly |
|
9. |
Form GSTR–6A |
Section 39 |
Rule 59(3) & 65 |
Details of
supplies auto-drafted
form |
Not to be furnished (Auto drafted) |
|
10. |
Form GSTR–7 |
Section 39 |
Rule 66 |
TDS Return |
Monthly |
|
11. |
Form GSTR–7A |
Section 51 |
Rule 66 |
Tax Deduction at Source Certificate |
The
certificate is made available to the deductee on the basis of the return furnished in Form GSTR-7 |
|
12. |
Form GSTR–8 |
Section 52 |
Rule 67 |
TCS Return |
Monthly |
|
13. |
Form GSTR–9 |
Section 44 |
Rule 80 |
Annual Return |
Annually |
|
14. |
Form GSTR–9A |
Section 44 |
Rule 80 |
Annual Return (For Composition Taxpayer) |
Annually |
|
15. |
Form GSTR–9B |
Section 44 |
- |
Annual
Return by every electronic commerce operator |
Annually |
|
16. |
Form GSTR–9C |
Section 44 |
Rule 80 |
Reconciliation Statement |
Annually |
|
17. |
Form GSTR-10 |
Section 45 |
Rule 81 |
Final Return |
Upon cancellation of registration |
|
18. |
Form GSTR-11 |
Section 39 |
Rule 82 |
Statement of inward supplies
by persons having Unique Identification Number (UIN) |
Quarterly [In case
of claiming refund] |
Note: Unless otherwise specified, the section numbers and rules referred to in this publication pertain to the Central Goods and Services Tax Act, 2017 and the Central Goods and Services Tax Rules, 2017, respectively.
2.1. Applicability of annual return: Section 44 of the CGST Act, read with Rule 80 of the CGST Rules, outline the provisions for furnishing annual return. Section 44 of the CGST Act 2017 stipulates the provisions of filing annual returns as under-
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, which may include a self-certified reconciliation statement,
reconciling the value of supplies
declared in the return furnished for the financial
year with the audited annual financial statement for every financial year electronically, within
such time and in such form and in such manner as may be prescribed.
Rule 80 of the CGST Rules designates FORM GSTR-9 as the form of annual return for a registered person other than a person registered under a composition scheme and e-commerce operator. In case of a person paying tax under a composition scheme, FORM GSTR-9A is notified as the annual return. GSTR-9B is designated as the annual return for an e-commerce operator who collects TCS under Section 52. However, FORM GSTR-9B still needs to be notified by the government.
Filing
of annual returns is also not applicable in the case of any department
of the Central Government, a State Government
or a local authority whose books of account are subject to audit by the Comptroller and
Auditor-General of India or an auditor
appointed to audit the accounts of local authorities under any law for the
time being in force.
2.2. Due date for filing annual return: The due date for filing an annual return is defined under Rule 80 of the CGST Rules as the 31st day of December following the end of the financial year. The government may extend the time limit for filing annual returns. Earlier, the provision for an extension of the due date for filing annual returns was embedded in Section 44 itself. However, post-substitution of Section 44, such powers are not available within the provisions of Section
44. Powers as laid down under
Section 168A may be invoked to extend the due date in exceptional circumstances.
Sub-Section (2) is inserted in
Section 44 of the CGST Act to restrict
the filing of annual returns beyond three years from the due date of
filing of annual returns.
2.3. Relaxation from filing
of annual return: Section 44 empowers the Commissioner to exempt any
class of person from filing an annual
return on the recommendation of the GST council.
In the exercise of those
powers, an exemption is given to a registered person whose annual
aggregate turnover is up to Rs. 2 crores for the financial
year 2022-23 [A similar exemption was there for FY. 2017-18,
2018-19, 2019-20, 2020-21 and
2021-22]
2.4. Applicability
of GSTR-9 in
cases where registrations
are obtained
in multiple
states and turnover in each such
state is below Rs. 2 crores: The term aggregate turnover
is defined under Section 2(6) of the CGST Act as “aggregate turnover” means the aggregate value of all
taxable supplies (excluding the value of inward supplies
on which tax is payable
by a person on reverse
charge basis), exempt supplies, exports of goods or services or both and
inter-State supplies of persons
having the same Permanent Account Number, to
be computed on all India
basis but excludes
central tax, State
tax, Union territory tax, integrated tax and cess. The turnover
is calculated on an all-India basis. Therefore, the applicability of annual return turnover at the PAN
level would be considered.
i.e. aggregate turnover of all the locations. Suppose
aggregate turnover exceeds
Rs. 2 crores during the year. In that case, filing of annual returns
becomes mandatory, including filing of Nil returns for those GSTINs
that do not have any transactions during
the year.
2.5. Applicability
of FORM
GSTR-9 in case of cancellation of registration: Cancellation of
registration under GST law shall not
affect the liability to discharge the obligation under GST law for any period before the date of cancellation. It has been clarified, as per the FAQ on GSTR 9
available on www. gst.gov.in that the annual return
needs to be filed even if the taxpayer has got his registration cancelled during the said financial
year.
Rule 80(3) prescribes FORM GSTR-9C as the form for
furnishing self-certified
reconciliation statements as under.
(3) Every
registered person, other than those referred to in the second proviso
to section 44, an Input Service Distributor, a person paying tax under section 51 or section 52, a casual taxable person and a non-resident taxable
person, whose aggregate turnover
during a financial
year exceeds five crore
rupees, shall also furnish a self-certified reconciliation statement as specified under section 44 in
FORM GSTR-9C along with the annual
return referred to in sub-rule
(1), on or before
the thirty-first day of December following the end of such financial year, electronically through the common portal either directly or through a Facilitation
Centre notified by the Commissioner.
Therefore, a registered person
whose aggregate turnover during the financial year exceeds Rs. 5 crores must furnish
a self-certified reconciliation statement in FORM GSTR-9C. A Self-certified reconciliation statement
(GSTR-9C) reconciles the figures
furnished in return (GSTR-9) with the details of the audited annual
financial statement. However,
furnishing of GSTR-9C
is not applicable in the following cases-
•
Any department of the
Central Government or a State Government
or a local authority, whose books of account
are subject to audit by the CAG or an auditor appointed to audit the accounts
of local authorities under any law for the time being in force,
• An
Input Service Distributor,
• A person
paying tax under section 51 or section
52,
• A casual
taxable person and
• A non-resident taxable person.
2.7. Consequences for
non-filing of FORM GSTR-9: Non- filing or late filing of GSTR-9 has the
following implications under GST law-
(a)
Notice to defaulter: Section
46 of the CGST Act read with 68 CGST Rules empowers a proper officer
to issue a notice in FORM GSTR-3A to a registered
person who fails to furnish a return
under Section 39, Section 44, or Section 45 of the CGST Act, 2017 requiring
him to furnish such returns within 15 days.
(b)
Late fees for delayed filing:
Section
47(2) of the CGST Act provides for the levy of a late fee of Rs.100/-
per day for delay in furnishing annual
return in Form GSTR-9, subject to a maximum amount of 0.25% of
the turnover in the State or Union Territory. Similar provisions are also provided
under respective state
laws. Therefore, effective
late fees for late filing of annual return is Rs. 200/- per day, subject to the maximum amount of 0.5%
of the turnover in the
State or Union Territory.
However, CBIC, vide Notification 07/2023-Central Tax dt. 31st March 2023, partially exempted
late fees on the filing of FORM
GSTR-9 beyond the due date by certain taxpayers as under-
|
Sr No |
Class of registered person |
Amount (Each
in CGST & SGST) |
|
1 |
Registered person having aggregate turnover up to Rs. 5 crores in the relevant financial year. |
Rs. 25 per day, subject to a maximum of 0.02% of the
turnover. |
|
2 |
Registered person having aggregate turnover of more than Rs. 5 crores
up to Rs.
20 crores in the relevant financial year. |
Rs. 50 per day, subject to a maximum of 0.02% of the turnover. |
(c)
General Penalty: Section 125 of
the CGST Act provides for a penalty
up to Rs. 25000/- each in CGST & SGST for
contravention of any provision of the act or rules made thereunder for which no penalty is
provided separately. Penalty under
Section 125 may be invoked for non-filing of FORM GSTR-9.
RECORDS AND ACCOUNTS UNDER GST LAW
3.2.
General records
to be maintained by a registered person: As per Section 35 of the CGST Act,
every registered person is required
to keep and maintain a true and correct account
of following at his principal place of business as mentioned in the certificate of GST registration.
|
Sl. No. |
Type of record |
Relevant Section/Rule |
Description of records to be maintained |
|
(a) |
Production or manufacture of goods |
Section 35(1)(a) read
with Rule 56(12) |
The registered per- son manufacturing goods is required to maintain monthly
production accounts showing quantitative details
of raw materi- al or services used
in the manufacture and quantitative details of the goods so manu- factured, including the waste
and by-products thereof. |
|
(b) |
Inward and outward supply of
goods or services or both |
Section 35(1)(b) read
with Rule 56(1) |
The registered person is required to maintain the
accounts in respect of the inward and outward supply of goods
or services or both. |
|
(c) |
Stock of
goods |
Section 35(1)(c) read
with Rule 56(1) |
Every
registered person, other
than a composition taxpayer, shall
maintain the accounts of
stock in respect
of goods received and supplied by him, and such accounts shall contain particulars of - •
opening balance, |
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• receipt, |
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• supply, |
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• goods lost, |
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• stolen, |
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• destroyed, |
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•
written off or disposed of by way of a gift or free sample |
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and
the balance of stock includes raw materials, finished goods, scrap, and wastage. In addition to the above,
a supplier of service
shall maintain the accounts showing quantitative details of goods used in the provision of services, details of input services utilized, and the
services supplied. |
|
(d) |
Input tax credit |
Section 35(1)(d) |
Every registered |
|
|
|
availed |
read with Rule |
person, other than a |
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|
56(1) & (4) |
composition taxpayer, |
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shall keep and
maintain an account containing the details of tax |
||||
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(e) |
Output tax payable
and paid |
Section
35(1)(e) read with Rule 56(1)
& (4) |
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payable (including tax payable under RCM), tax collected and paid, input
tax, and input tax
credit claimed, |
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(f) |
A register of tax
invoices, credit notes, debit notes, and delivery challan |
Section
35(1)(f) read with Rule 56(1)
& (4) |
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together with a register |
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of tax invoice, credit |
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notes, debit notes, |
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delivery challan issued |
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or received during
any |
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tax period. |
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(g) |
Goods or |
Section 35(1)(f) |
Every registered |
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services |
read with Rule |
person shall keep
and |
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imported |
56(1) |
maintain, in addition |
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or exported |
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to the particulars |
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and relevant |
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mentioned in sub- |
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documents |
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section (1) of section |
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35, a true and correct account of the goods or services imported or exported or of supplies attracting payment of tax on reverse charge along with the relevant documents, |
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(h) |
Supplies attracting payment of tax on
reverse charge and relevant documents |
Section
35(1)(f) read with Rule 56(1)
& (4) |
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including invoices, |
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bills of supply, delivery |
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challans, credit notes, |
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debit notes, receipt |
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vouchers, payment |
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vouchers, and refund |
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vouchers. |
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(h) |
Maintaining details of accounts for advances |
Section
35(1)(f) read with Rule 56(1)
& (4) |
Every registered person shall keep and maintain a separate account
of advances received and paid, and adjustments made thereto. |
|
(i) |
Supplier
Master |
Section 35(1)(f) read with Rule 56(5) |
Every
registered person shall
keep
the particulars of names and complete addresses of suppliers from
whom he has received
the goods or services chargeable to tax
under the Act. |
|
(j) |
Customer Master |
Section 35(1)(f) read
with Rule 56(5) |
Every
registered person shall
keep
the particulars of names and complete addresses of the persons
to whom he has supplied goods or services, where required under
the provisions of this Chapter. |
|
(k) |
Warehouse Master |
Section 35(1)(f) read
with Rule 56(5) |
Every
registered person shall
keep
the particulars of the complete address
of the premises where goods are
stored by him, including goods stored during
transit, along with the particulars of the stock
stored therein. |
3.3.
Specific records
to be maintained by a registered person: GST law provides for specific
maintenance of records in certain
cases by certain classes of persons. Details of such specified class of person along with the additional records are as under-
3.3.1.
Records to be
maintained by transporter and owner/ operator
of godown or warehouse: Section 35 of CGST Act read with Rule 58 of CGST Rules requires
every owner or operator of warehouse
or godown or any other place used for storage
of goods and every transporter, irrespective of whether
he is a registered person or
not, shall maintain records of the consigner,
consignee and other relevant details of the goods in such manner as may
be prescribed.
Therefore, the person engaged
in the business of transporting goods would be required to maintain the records of the goods transported, delivered, and goods
stored in transit by him, along with
the GSTIN of the registered consigner and consignee
for each of his branches.
The owner/operator of a
warehouse/godown of a warehouse or godown
shall maintain books
of account with respect to the period for which particular goods remain
in the warehouse, including the particulars relating
to dispatch, movement,
receipt, and disposal of such goods. The owner/the operator of the godown is also required to store the goods in a manner
that can be identified item-wise and owner-wise, and it also facilitates any physical verification or inspection by the proper
officer on demand.
3.3.2.
Details to be
maintained by works contractor: Section 35(1)(f)
of CGST Act, read with Rule 56(14) of CGST Rules, requires a registered person executing the works contract to keep separate accounts for the works
contract showing the following
details-
(a)
the names and addresses of the persons
on whose behalf
the works contract is executed;
(b)
description, value,
and quantity (wherever applicable) of goods or services received
for the execution
of the works contract;
(c)
description, value,
and quantity (wherever applicable) of goods
or services utilized in the execution of the works contract;
(d)
the details of payment
received in respect of each works contract,
and
(e)
the names and
addresses of suppliers from whom he received goods or services.
3.3.3.
Records to be
maintained by Agent: Rule 56(11) of CGST
Rules requires every agent referred to in clause (5) of section 2 of CGST Act shall maintain
accounts depicting the —
(a)
particulars of
authorization received by him from each principal
to receive or supply goods or services on behalf of such principal
separately;
(b)
particulars, including
description, value, and quantity (wherever applicable) of goods or
services received on behalf of every principal;
(c)
particulars, including
description, value, and quantity (wherever applicable) of goods or
services supplied on behalf of every principal;
(d) details of accounts furnished to every principal and
(e)
tax paid on receipts
or on supply of goods or services effected on behalf of every principal.
In addition to the above, any
person having custody over the goods in the capacity
of a carrier or a clearing and forwarding agent for delivery or dispatch thereof to a recipient on behalf of any
registered person shall maintain true and correct records in respect of such goods handled by him
on behalf of such registered person
and shall produce
the details thereof
as and when required by the proper officer.
3.4. Maintenance of additional records or documents: Section 35(3) of the CGST Act empowers the
Commissioner to notify a class of
taxable persons to maintain additional accounts or documents for such purpose as may be specified therein.
3.5. Special manner of maintaining records for the notified class of persons: Section 35(4) of the
CGST Act empowers the Commissioner to specify the manner of maintenance of accounts where any class of taxable
persons is not in a position to keep and maintain accounts
in accordance with the provisions of Section 35 of
CGST Act.
3.6. Place of maintenance of records under GST: Section
35 of the CGST Act mandates every registered person to keep and maintain
a true and correct account
of the requisite records at his principal
place of business, as mentioned in the registration certificate. However, the first proviso
to Section 35 states that in
case more than one place of business is specified in the certificate of registration, the accounts relating to each place of business are required to be kept at such an additional place of business,
including data in electronic form stored on an
electronic device.
Where any records or books of
accounts belonging to the registered
person are found at a place other than the place mentioned in the registration certificate, such records would be presumed to be maintained by such a
registered person. The provision is
subject to an exception where the registered
person proves otherwise.
3.7. Maintenance of records in Electronic Form: The second proviso to Section 35 of CGST Act, read with Rule 56(15) of CGST Rules, allows maintenance of accounts and other particulars in electronic form subject to authentication of such records through digital signature. Rule 57 of CGST Rules provides for the generation and maintenance of electronic records under
(1)
Proper electronic
backup of records shall be maintained and
preserved in such manner that, in the event of
destruction of such records due to accidents or natural causes,
the information can be restored
within a reasonable period of time.
(2)
The registered person
maintaining electronic records shall produce,
on demand, the relevant records
or documents, duly authenticated by him in hard copy or in any
electronically readable format.
(3)
Where the accounts and records are stored electronically by any registered person, he shall, on demand, provide the details of such files, passwords of
such files, and explanation for codes used, where necessary, for access and any other information which is
required for such access along with a
sample copy in print form of the information stored in
such files.
3.8. Other miscellaneous provisions:
3.8.1.
Serially Numbered
records: Rule 56(9) of CGST Rules states that where books of accounts
are maintained manually, each volume of books of
account shall be serially numbered.
3.8.2.
Treatment where
the registered person
fails to account
for goods or services: Section
35(6) of CGST Act provides
that where the registered
person fails to account for the goods or services both according to Section 35 of CGST Act, the proper officer shall determine the amount of tax
payable on the goods or services that are not accounted for as if such person
had supplied such goods or services in terms of Section 73 & 74 of CGST Act. It is important to note
that this provision is applicable only in the case of Section 17(5)(h), i.e. Goods are lost,
stolen, destroyed, written off, or disposed of by way of gift or free samples.
Rule 56(6) of the CGST Act further provides
that if any taxable goods are found to be stored at any place(s)
other than those
declared without the cover of any valid documents, the proper officer shall determine the amount of tax
payable on such goods as if the registered person
has supplied such goods.
3.8.3.
Treatment of incorrect entry
or its deletion in accounts/ records under GST: As per Sub-rule (8) of Rule 56 of CGST Rules, any entry in registers, accounts
and documents shall not be erased, effaced
or overwritten, and all incorrect
entries,
otherwise than those of clerical
nature, shall be scored out under attestation and thereafter, the correct entry shall be recorded and where the registers and other documents
are maintained electronically, a log of every entry edited or deleted
shall be maintained.
3.8.4. Production of accounts maintained under any law to GST authorities: As per Sub-rule 18 of Rule
56, every registered person shall, on demand,
produce the books of accounts which he is required to maintain under any law for the time being
in force.
3.9 Retention of accounts and records under GST: Section 36 of the CGST Act provides for the
retention of accounts and records. As per said Section, the registered person
is required to keep and maintain books of accounts
and other records
as stated under Section 35 and are required to be retained until the expiry of 72 months from the due
date of furnishing of the annual
return for the year pertaining to such accounts and records. The retention period would also apply to all invoices, bills of supply, credit and
debit notes, and delivery challans
relating to stocks, deliveries, inward supply, and outward supply. In the case where records are maintained manually, such records should be kept at
every related place of business
mentioned in the registration certificate and should
be accessible at every related place of business where such accounts
and documents are maintained
digitally.
3.10 Additional period of retention: Proviso to Section 36 of CGST Act provides for additional period retention under
certain circumstances as
under-
(a)
Where the registered
person is a party to an appeal, revision,
or any other proceedings before the Appellate
Authority/ Revisional Authority/ Appellate Tribunal/ Court
(whether filed by him or the Commissioner)
(b)
Where the registered person
is under investigation for an offence
under Chapter XIX of the CGST
Act.
In
the above cases,
the registered person
is required to retain the books of accounts and other records
pertaining to the subject
matter of such appeal/ revision/ proceedings/
investigation for:
(a)
1
year
after
the
final
disposal of
such
appeal,
revision, etc., or
(b) 72 months from the due date of furnishing the annual return Whichever is later.
A STEP-BY-STEP WALKTHROUGH OF GSTR-9
1
& GSTR-3B, along with the information maintained as a part of the accounts and other records as
maintained under Section 35 of CGST
Act read with Rule 56 of the CGST Rules. However, the tables of GSTR-1 & 3B are not in alignment with the requirements of GSTR-9. Therefore, one has to take extra
precautions while reporting the figures in annual returns
as the facility to revise the annual return is not available.
Therefore, the reporting of
information in the Annual Return would be based on GSTR-1, GSTR-3B,
and the details available in accounts
and records. As discussed earlier, GSTR-9 consists of six parts and nineteen tables, as
listed below-
|
Sl. No. |
Part No. |
Description |
Relevant Tables |
|
1 |
I |
Basic
details |
1, 2, 3A to 3B |
|
2 |
II |
Details
of outward and inward supplies
declared during the financial year |
4A to 4N, 5A to 5N |
|
3 |
III |
Details
of ITC as declared in returns filed during
the financial year |
6A to 6-O, 7A to 7J, 8A to 8K |
|
4 |
IV |
Details
of tax paid as declared in returns
filed during the financial year |
9 |
|
5 |
V |
Particulars of the transactions
for the financial year declared in returns
of next financial year. |
10 to 14 |
|
6 |
VI |
Other information like pending
refund claim, demand of taxes,
total tax paid etc. |
15A to 15G, 16A to 16C, 17, 18, 19A to 19B |
The GSTN portal allows users to obtain a
system-computed consolidated summary
of GSTR-9, GSTR-1, and GSTR-3B. This
summary is based on the monthly returns filed by the registered person and includes details such as the taxable value, liabilities paid through ITC and
cash, ITC claims, and reverse charge.
GSTR-9 is auto-populated based on GSTR-1 & 3B, with an option to edit the
auto-populated data. However, there
are certain exceptions. A registered person
is not allowed to change the details of the following
tables-
Table 6A - The total amount of ITC availed
through Form GSTR-3B.
Table 8A - ITC as per Form GSTR-2A (specifically Table 3 & 5 thereof).
Table 9 - Details of tax payments
as declared in returns filed
during the financial year.
Editing system computed figures
enables a registered person to
report the correct figures of liability in GSTR-9 which is matching
with the accounts
and other records.
The registered person
can report additional liability that was not reported
in GSTR-1 or GSTR-3B and pay such liability through FORM DRC-03. However, a registered person is
not allowed to avail of additional ITC through GSTR-9.
It is worth noting that auto- populated data or consolidated yearly summary of GSTR-
1
& 3B is only for reference purposes. A registered person
is required to furnish the details in GSTR-9 based on actual supplies
made during the year and based on the accounts
and other records
maintained under Section
35 of the CGST Act.