The filing Form GSTR 9 & 9C with the recent changes has become more complex which if not checked carefully, will change to GST annual return may cause an input tax credit mismatch.
All taxpayers registered under GST are required to file their annual return for the financial year 2023-24 by December 31, 2024, except for certain exempted categories.
Table of Contents
What is GSTR-9?
Form GSTR-9 is an annual return to be filed once for each financial year, by the registered taxpayers who were regular taxpayers, including SEZ units and SEZ developers. The taxpayers are required to furnish details of purchases, sales, input tax credit or refund claimed or demand created etc. in this return.
What is GSTR 9C?
GSTR-9C is a reconciliation statement for reconciling values between the annual GSTR-9 of a financial year and the audited financial statements of the taxpayer. Every registered taxpayer whose turnover exceeds Rs.5 crore during a financial year is required to file this reconciliation statement.
Significant Changes In GST Annual Return (GSTR-9) for FY 2023-24
The sourcing of input tax credit (ITC) details is the most important modification in the GST Annual Return (GSTR-9) for FY 2023–2024. In the past, the data in GSTR-2A (a declaration of inbound supplies) was used to construct Table 8A of GSTR-9.
However, starting in FY 2023–2024, the data in GSTR-2B will be used to populate Table 8A. A statement of inbound supplies called GSTR-2B is automatically generated from supplier invoices that are uploaded.
This change is intended to simplify the procedure and lessen the amount of human labor that taxpayers must do in order to reconcile their ITC claims.
If the ITC reported in GSTR-3B differs from GSTR-2B because of supplier invoice upload delays or other problems, discrepancies may arise. These discrepancies call for extra reconciliation work, highlighting the necessity of careful data management to prevent issues and guarantee compliance.
Eligibility
Taxpayers having aggregate turnover upto Rs.2 Crores are exempted from filing GSTR-9 for FY 2023-24 vide Notification No.14/2024 – CT. All other taxpayers are required to file GSTR-9 for FY 2023-24.
Taxpayers having aggregate turnover upto Rs.5 Crores are exempted from filing GSTR-9C for FY 2023-24 vide Rule 80(3) of CGST Rules. All other taxpayers are required to file GSTR-9C for FY 2023-24.
Past Relaxations Still In Force
Table4: Amendments, credit notes and debit notes cannot be shown as net figures in B2B, B2C, etc. now. Table 4I to 4L to be disclosed separately from FY 21-22.
Table 5: Exempted & Nil-rated can be consolidated in ‘Exempted’ column or shown separately. Table 5F – Non-GST to be shown separately from FY 21-22 onwards
Table 17: HSN outward details mandated from FY 2021-22 onwards. (GSTR 1 consolidated data can be used for table 17)
HSN disclosures to be performed at 6-digit level (when Turnover is more than Rs. 5 crore) and 4-digit level (when Turnover is less than Rs. 5 crore for B2B only)
Clarification that disclosures in GSTR 1 tables 9A, 9B & 9C must be disclosed in table 10 & 11 of GSTR 9.
Table 5: Amendments, credit notes and debit notes can be shown as net figures in table 5.
Table 6: ITC bifurcation into ‘inputs’/’input services’ not mandatory, total value can be consolidated under ‘Inputs’. From FY 2019-20 – under ‘Inputs’ & ‘Capital Goods’.
Table 6: May consolidate ITC under RCM from registered and un-registered persons under registered persons’ table.
Table 7: All ITC reversals may be consolidated under Table 7H, although TRAN reversals to be shown separately.
Part V: Reversal/Availment of ITC in previous year may not be filled (T12 & T13)
Table 15, 16 & 18: Refund details, Info on inward supplies & deemed supply, HSN inward
details remain optional.
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