Arjuna(Fictional Character): Krishna, after the declaration of election results, the issue of establishment of new government is resolved, but what about the issues of GST? The trade and industry is unable to resolve the issues in reporting of the Annual Return under GST for the FY 2017-18 before 30th June 2019. So, please elaborate on it?
Krishna(Fictional Character): Arjuna, In GSTR-9, every registered person has to provide details of outward supplies, inward supplies and inward supplies on which tax is payable on reverse charge basis (RCM) and determine the tax liabilities as appearing in the financial statement of 2017-18 of the taxpayers. Being first year of GST in 17-18 lots of mistake have happened and many of them are resolved in GST returns of FY 18-19. Thus there is an issue of reporting of this correction of 17-18 made in 18-19 in GSTR 9. Further, there is a difference in GSTR1 and 3B returns also which needs to be solved. Let's try to resolve it.
Arjuna: Krishna, where the details of outward supplies of 17-18 are to be entered in GSTR-9?
Krishna: Arjuna, details of outward supplies are to be entered in Table 4, Table 5 for FY 17-18 and Table 10/11 for correction made in FY 18-19. In table 4, the taxpayer has to provide details of taxable outward supplies made during the financial year 17-18. In table 5, the taxpayer has to provide details of Nil-rated, Exempted, Zero-rated, Non-GST outward supplies made during the financial year 17-18. Taxpayer should enter details of correction of FY 2017-18 and reported in return of FY 2018-19 in Table 10 or Table 11.
Arjuna: Krishna, What if the Outward supplies reported in returns deviates significantly from outward supplies appearing in financial statements?
Krishna: Arjuna, if the outward supplies reported in returns deviates significantly from outward supplies appearing in financial statements then it leads to two scenarios:
If the taxpayer has adjusted such deviations in returns of FY 2018-19, then taxpayer can show such transactions in Table 10 or Table 11.
But if taxpayer fails to add such transactions in returns of FY 2018-19, then the taxpayer should include such transactions in Table 4 and discharge such additional tax liability through DRC-03.
Arjuna: Krishna, What if the outward supplies reported in 3B differs significantly from outward supplies reported in GSTR-1?
Krishna: Arjuna, if the outward supplies reported in 3B differs significantly from outward supplies reported in GSTR-1 or vice versa then the taxpayer has to report it in Table 4/5 or Table 10/11 as per the case. So, let us take an example.
Outward Supply of Rs. 10000/- of July 17 was entered correctly in GSTR1 of July 17and shortly entered in 3B of July 17 as Rs. 9000/-The amount of Rs. 1000/- was added in outward supply of 3B of August 18. Then Rs. 9000/- for which payment was made in year 2017-18 should be reported in Table 4 and Rs. 1000/- for which payment was made in year 2018-19 are to be reported in Table 10. This is the “Jugaad” solution as the figures of GSTR1 is autopick in table 4, but requires human editing to resolve the query.
Outward Supply of Rs. 10000/- of July 17 month entered correctly in 3B and shortly entered in GSTR1 as Rs. 9000/- and Rs. 1000/- was adjusted in GSTR1 of August 18. Then the entire supply of Rs. 10000/- should be reported in Table 4 as payment was made in year 2017-18 itself. This is again a “Jugaad” solution as the figures of GSTR1 is auto pick in table 4, but requires human editing to resolve the query.
There are many issues in the reconciliation of GSTR1, 3B and books of accounts. Further, the reporting in 17-18 and Correction of it in 18-19 add more issues.
Arjuna: Krishna, What one should learn from this?
Krishna: Arjuna, the time has come to now to simplify the GST issues a new stable govt is in place. Many issues are there in reporting of Annual return, Audit, Interest, etc in GST. These need to be resolved before 30th June 2019 otherwise filing of this returns and GST audit is going to be a cumbersome exercise for the Taxpayer. Hope for the best.