As we all know, GSTR 9 annual return to be filed within six months from the end of financial year for which the return is to be filed. However, the due date for filing GSTR 9 for Financial Year 2017-18 has now been revised to 30th November, 2019, the original / first due date being 31st December, 2018.

These constant and continuous revision in GSTR 9 due dates have been due to the complexities of Form GSTR 9, excessive data required for filing the same, frequent revisions in the Form and vague understanding available on filing of GSTR 9 due to lack of appropriate data on the same.
It has been clarified by the Government that one should take GSTR 3B as a base while filing GSTR 9. To simplify GSTR 9 filing process, one must follow the below-mentioned steps -
1. Reconciliation of outward supplies as per GSTR 3B, GSTR 1 and books of accounts -
It was very important to verify and match value as per GSTR 3B, GSTR 1 and books of accounts.
Due to the first year of implementation of GST, there may be a lot of discrepancies in outward supplies as per GSTR 3B, GSTR 1 and books of accounts. In the event of such discrepancies, one must understand as to which value may be disclosed in GSTR 9.
Example 1- Assuming no amendments have been made. May be reported in Part II of GSTR 9.
Rs. in Lakhs
Sr. No |
As per GSTR 3B |
As per GSTR 1 |
As per Books of Accounts |
GSTR 9 reporting |
Additional Liability |
1. |
100 |
90 |
100 |
100 |
0 |
2. |
100 |
110 |
100 |
100 |
0 |
3. |
80 |
100 |
100 |
100 |
20 |
4. |
80 |
80 |
100 |
100 |
20 |
5. |
80 |
90 |
85 |
85 |
5 |
2. Amendments made in Outward Supplies-
One has to check if any amendments have been made to outward supplies. Such amendments may have taken place in the same financial year or in the next financial year for the transaction relevant to the period for which GSTR 9 is to be filed.
Such amendments may be reported in Part V of GSTR 9 depending on GSTR 3B reporting
Example 2 -
A sales invoice was issued on 25th July, 2017. Assuming GSTR 1 and GSTR 3B are the same, let us consider the following scenarios -
CASE |
Said Sales is Reported in GSTR 1 of |
Whether any amendments are required for said invoice |
Amendment filed in GSTR 1 of |
Reporting of Original Details in GSTR 9 |
Reporting of Amendment Details in GSTR 9 |
A |
July 17 |
Yes |
Sep 17 |
Part II |
Part II Sr. No - 4K / 4L |
B |
July 17 |
Yes |
July 18 |
Part II |
Part V |
C |
July 18 |
Yes |
Sep 18 |
Part V |
Part V |
Example 3 -
Sale invoice issued in July 2017.
Where GSTR 3B and GSTR 1 are not the same, the implication on reporting will be as follows -
Case |
Original details recorded in GSTR 3B |
Original details recorded in GSTR 1 |
Amendment made in GSTR 3B |
Amendment made in GSTR 1 |
GSTR 9 Reporting |
|
Original |
Amendment |
|||||
A |
July 17 |
July 17 |
Jan 18 |
Jan 18 |
Part II |
4K/4L - Part II |
B |
July 17 |
July 17 |
Jan 18 |
Apr 18 |
Part II |
4K/4L - Part II |
C |
July 17 |
July 17 |
Apr 18 |
Apr 18 |
Part II |
Part V |
D |
July 17 |
July 17 |
Apr 18 |
Dec 17 |
Part II |
Part V |
E |
July 17 |
Apr 18 |
- |
Sep 18 |
Part II |
Part II |
3. Reconciliation of input tax credit availed as per GSTR 3B, GSTR 2A and books of accounts -
It is important to verify the amount of input tax credit availed as per GSTR 3B with that available as per GSTR 2A and books of accounts. In case of discrepancy, final input tax credit shall be updated as books of accounts taking into consideration GSTR 2A.
Example 4-
ITC amount is inclusive of CGST, SGST / UTGST, IGST. Assuming no ITC has been claimed in the next financial year.
Sr. No |
ITC availed as per GSTR 3B |
ITC available as per GSTR 2A |
ITC as per books of accounts |
GSTR 9 Reporting |
Excess/ (Short) credit claimed |
1. |
70 |
65 |
70 |
70 |
0 |
2. |
70 |
75 |
70 |
70 |
-5 |
3. |
70 |
65 |
65 |
65 |
5 |
4. |
65 |
70 |
70 |
70 |
-5 |
a. In case of Sr. no - 1, one has to keep documentary records on the basis of which ITC has been availed in excess of GSTR 2A.
b. In case of Sr. no - 2 and 4, the additional input tax credit available in GSTR 2A / books of accounts but not availed through GSTR 3B shall lapse (short credit claimed).
c. In case of Sr. no - 3, excess credit claimed shall be payable through Form DRC-03 along with interest
4. Input tax credit availed in the next financial year -
There may be certain invoices on which input tax credit has been in the next financial year. In such cases, input tax credit availed may be reported in table 8 of Part III and Table 13 of Part V.
Example 5 -
Purchase Invoice recorded in books on 25th Aug 2017, having IGST ITC amount of Rs 2,00,000. However, while filing GSTR 3B of Aug 17, ITC for said invoice is considered as Rs 20,000/-. Amendment with correct values is carried out in GSTR 3B of Sep 18 by taking additional credit of Rs 1,80,000/-
- Rs 20,000 will form part of disclosure at Part III - Table No 8
- Rs 1,80,000 will form part of disclosure at Part V - Table No 13
5. Reversal of input tax -
While reconciling data for GSTR 9, we may come across some input tax credit that may have been availed but was ineligible or credit was required to be reversed under various provisions of the law. Such input tax credit that requires reversal but not reversed may be reversed under Table 7 Part II of GSTR 9. The amount of input tax credit reversed shall be an additional liability and paid through Form DRC-03.
Example 6 -
ITC Rs. 100,000 on a motor car purchased was availed in the month of Dec 17. This amount may be reversed in GSTR 9 Table 7.
6. Tax payable in GSTR 9 -
Part IV of GSTR 9 may be updated as per details updated in Part II whereas Table 14 may be updated as per details updated in Part V.
Any other liability arising on account of the input tax credit shall be added to tax payable while filing and making payment through Form DRC-03. Such payment shall be made along with interest.
Example 7 -
Additional Liability reported in GSTR 9 |
Tax payable to be reported in GSTR 9 |
Part II |
Part IV - Table 9 |
Part V - Table 10 / 11 |
Part V - Table 14 |
Input tax credit excess claimed, now reversed |
Form DRC-03 - Add to tax payable |
Conclusion -
One must take care of these basic 6 steps before filing GSTR 9. Following these 6 steps will make filing GSTR 9 easier and will help you cover major aspects that need to be verified before filing GSTR 9.
End Note -
GST Hero is a government of India appointed GST Suvidha Provider and is also a cloud-based multi-user software with a smooth mechanism to work together which provides multiple tools and reports like
- GSTR 1 vs. GSTR 3B comparison,
- GSTR 3B vs. GSTR 2A reconciliation,
- GSTR 2A vs. purchases data reconciliation,
- Amendment and supplies report for any amendments made or supplies added in the current or next financial year,
- GSTR 1 annual reconciliation with books of accounts
- Auto-update and bi-furcation of purchases data in GSTR 9.
These reports make filing GSTR 9 a simplified and less time-consuming process which otherwise becomes difficult with manual reconciliation.
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