Query on RCM in Annual Return*
As per point no. 'g' of Press Release dated 03.07.19, 2017-18 RCM liability and input, shown in GSTR3B of 2018-19 has to be shown in GSTR9 of 2018-19 instead of 2017-18.
Contrary to this, as per sec 39(9) , any erroneous mistake or omission can be rectified till GST return of September 2018 or Annual Return whichever is earlier.
The taxpayer had paid RCM liability and claimed input in GSTR3B of September 2018. So this has to be shown in Annual return of 2018-19 and not of 2017-18.
If yes, is the press release above the law? (Precisely sec 39)
And being an auditor, I have to report in GSTR9C that RCM liability has not been paid in Annual Return with unnecessary explanation quoting the Press Release that liability has been paid but it will be shown in GSTR9 of 2018-19.
GOOD NEWS :
The due date for furnishing of Annual Return in the FORM GSTR-9 / FORM GSTR-9A and Reconciliation Statement and Audit Report in FORM GSTR-9C for the financial year 2017-18 has been extended from 31st August, 2019 to 30th NOVEMBER, 2019.
REMOVAL OF DIFFICULTY ORDER No. 07/2019-CT dated 26.08.2019, issued by the CBIC Department.
Hence, the latest Due Date to file ANNUAL RETURN ( GSTR-9 and GSTR-9A ) and Reconciliation Statement and Audit Report ( GSTR-9C ) is 30.11.2019.
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