Dear All,
Further to the announcement of extension in the due date, Government has issued a press release to clarify certain issues related to reporting requirements under GST annual return and audit report for FY 2017-18. Key takeaways are summarized below for your ready reference. For more details, refer attachment:
Short payment of tax
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- Short paid tax in monthly returns can be voluntarily discharged through Form DRC – 03 along with interest;
- In such cases, no penalty shall be levied;
- Summary of such turnover can be declared in annual return Form 9;
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Excess tax paid
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- Shall be declared in the annual return
- An eligible refund can be applied through RFD 01A;
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Input tax credit
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- ITC cannot be availed or reversed through annual return;
- Liability to reverse ITC shall be separately done through Form DRC 03;
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ITC claimed vs. 2A reconciliation (table 8)
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- ITC availed between July 2017 to March 2019 is required to be summarized;
- ITC not availed within due date shall lapse, however, there shall be no requirement to effect reversal since it is not credited to electronic credit ledger;
- Auto-populated figures of ITC as per 2A are per status as on 01st May 2019;
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Additional information in annual return which was not part of monthly filings
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- Supplies received from composition taxpayers can be declared to best of knowledge and records;
- HSN summary of inward supplies can be declared to best of knowledge and records;
- Data is for informational purpose and reasonable variations shall not be viewed adversely;
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Exempted, NIL rated and Non-GST supplies
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- Overlapping cases of NIL rated vis-à-vis exempted supplies shall not be viewed adversely;
- Non-GST supplies include the supply of alcoholic liquor for human consumption, motor spirit (commonly known as petrol), high speed diesel, aviation turbine fuel, petroleum crude and natural gas and transactions specified in Schedule III of the CGST Act;
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Additional reverse charge payments
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- RCM liability for FY 2017-18 paid in FY 2018-19 shall be reported in annual return for FY 2018-19 only;
- Variations shall be reported with reasons in audit report (9C);
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Debit/credit notes
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- Tax Credit notes pertaining to FY 2017-18 issued upto Sep’18 can be declared in annual return;
- Debit notes can be declared in reconciliation statement as “other adjustments” in point 5-O
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Reconciliation of ITC on expenses
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- Reconciliation required only for expenses on which ITC has been availed;
- List of expense in Form 9C is indicative and additional fields can be added;
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Trust you find the above useful.
Thanks & Regards
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