As we are into 1st week of December 2022, the said month assumes comparatively more importance from GST compliance perspective since 31 December 2022 is the due date to furnish GSTR 9 and GSTR 9C for FY 2021-22. In this article, we would mainly comment on applicability of GSTR 9 and 9C along-with key pre-requisites.
A. Applicability for FY 2021-22
The applicability of GSTR 9 and GSTR 9C for FY 2021-22 is akin to that of FY 2020-21. However, for easy reference, we have reiterated the same below:
- GSTR 9 is to be furnished by all taxpayers whose aggregate turnover exceeds INR 2 crore.
- Conversely, GSTR 9 is exempt for taxpayers whose aggregate turnover is less than or equal to INR 2 crore.
- Further, a self-certified statement in GSTR 9C should be furnished by taxpayers whose aggregate turnover exceeds INR 5 crore.
- Accordingly, a taxpayer (whose aggregate turnover is between INR 2 crores and INR 5 crore) is required to only file GSTR 9.
B. Key Pre-Requisites
- Finalisation of books of accounts.
- In case of multi-state GSTINs, extraction of state-wise trial balance whereby total of all states should be tallied with turnover/ input tax credit (‘ITC’) as per financials.
- From outward perspective, transactional level reconciliation of GSTR 1 vs GSTR 3B vs books of accounts.
- From inward perspective, transactional level reconciliation of GSTR 2B vs GSTR 3B vs books of accounts.
- To track reporting of outward as well as inward supply transactions (along-with amendments) of FY 2021-22 in GSTR 1/ GSTR 3B of April 2022 to October 2022 tax periods filed till 30 November 2022.
- To also extract details of ITC pertaining to FY 2020-21 availed in FY 2021-22 for reporting the same in GSTR 9C.
- HSN wise outward supply details should be collated. (6 digit HSN for taxpayers with more than INR 5 crore turnover. 4 digit HSN for all B2B supplies by taxpayers having less than INR 5 crore turnover).
- GST rate-wise break-up of turnover as well as liability reported in GSTR 9 should be prepared (along-with RCM transactions).
- To verify GST data available on income tax website.
C. Key changes (from optional to mandatory reporting) in FY 2021-22 – GSTR 9 and 9C
| Table – GSTR 9 | Particulars | Reporting in FY 2021-22 | Remarks |
| 4I, 4J, 4K and 4L | Credit notes / Debit notes/Amendments (+)/(-) with respect to Table 4B to Table 4E | Mandatory to disclose separately | |
| 5D and 5E | Exempted and NIL rated supply | Exempt and NIL rated supply can either be shown separately in Table 5D and 5E or the consolidated value could be disclosed in Table 5D. | |
| 5F | Non-GST supply (includes ‘no supply’) | Mandatory to disclose separately | |
| 6C | RCM ITC on procurement from unregistered person | Mandatory to disclose separately | No option to report consolidated 6C and 6D value in Table 6D. The said option was available till FY 2020-21. |
| 6D | RCM ITC on procurement from registered person | Mandatory to disclose separately | |
| 17 | HSN wise summary of Outward Supplies | Mandatory to disclose separately | 6 digit HSN for taxpayers with more than INR 5 crore turnover.4 digit HSN for all B2B supplies by taxpayers having turnover upto INR 5 crore. |
| Table – GSTR 9C | Particulars | Reporting in FY 2021-22 | Remarks |
| 12A to 12D | Reconciliation of net ITC as per financials with ITC as per GSTR 9 | Mandatory to disclose Table 12B and Table 12C separately | Disclosure of values in Table 12B and Table 12C was optional till FY 2020-21 |
The aforesaid tables should be thoroughly looked into as these changes are applicable only from FY 2021-22 onwards. Therefore, the possibility of IT systems not being geared up to the reporting requirements is quite high.
