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CA Venugopal Gella
Common errors and issues
in ITC and Tax payable
in Annual return
Presented byCA. Venugopal Gella
Annual ReturnGSTR 9
Rule 44 read with Rule 80
CA Venugopal Gella
GSTR 9Annual Return
CA Venugopal Gella
Annual Return – GSTR 9 :: 6 Parts 19 Tables
Parts
Part I
Basic Info
Table 1-3
Part II
Liability
Table 4-5
Part III
Input Tax Credit
Table 6-8
Part IV
Tax paid details
Table 9
Part V
Circular 26/2017
Adjustments
Table 10-14
Part VI
Other info
Table 15-19
CA Venugopal Gella
Source of Information – Liability & ITC
Turnover & Liability• Aggregate value of supplies made to ……. on which tax has been paid shall be declared here.
• These will include details of supplies made through E-Commerce operators and are to bedeclared as net of credit notes or debit notes issued in this regard.
• Table x,y,z along respective amendments in Table 9 and Table 10 of FORM GSTR-1 may beused for filling up these details.
Input Tax Credit• Aggregate value of input tax credit availed on all inward supplies ………..hall be declared here.
• It may be noted that the total ITC Availed is to be classified as ITC on inputs, capital goodsand input services.
• Table 4(A)(…) of FORM GSTR-3B may be used for filling up these details.
• This shall not include ITC which was availed, reversed and then reclaimed in the ITC ledger.This is to be declared separately under 6(H) below.
CA Venugopal Gella
Premise for Reporting of ITC
ITC Reporting Table
Purchases of 17-18• Booked in 17-18 and credit availed in 17-18
• Booked in 17-18 and credit availed in 18-19
• Booked in 18-19 and credit availed in 18-19
Report in GSTR 9 of 17-18
Report in GSTR 9 of 18-19
Report in GSTR 9 of 18-19
Purchases of 18-19• Booked in 18-19 and credit availed in 18-19
• Booked in 18-19 and credit availed in 19-20
• Booked in 19-20 and credit availed in 19-20
Report in GSTR 9 of 18-19
Report in GSTR 9 of 19-20
Report in GSTR 9 of 19-20
Note: ITC is linked with when it is availed in 3B and not when it is availed in Books of Accounts
CA Venugopal Gella
Issues with in GSTR 9Credit
• Not Availed
• Subsequently Availed
• Excess Availed
• Wrongly Availed
• Segregation (IP/IS/CG)
Reversal• Not Reversed
• Wrong Value of Reversal
• Classification
8A• 8A vs 2A not Matching
• 8A Excel not matching
• 8D being positive & Negative
• Diff between 8E and 8F
Carry over Effect• 17-18 credits availed now
• Accounted in 19-20
CA Venugopal Gella
General Issues• Sales Return is taken as ITC
• Purchase returns shown as liability & taxes are paid
• RCM• RCM credits availed in next month
• RCM not paid / paid thru DRC 03
• Availed & Reversed • Gross value of Credit is higher
• Reversed in Different Tax period
CA Venugopal Gella
Focus AreasKey Legal Provisions
Eligible Credit • Sec 16(2) conditions
• Sec 16(4) Time Limit
• Sec 18(1) ITC -01
• Sec 18(3) ITC -02
• Trans Credits
In Eligible / Reversal• Rule 42 & Rule 43 – common
Credit
• 17(5) Blocked Credit
• 18(4) ITC -03
What to look in Books :
Eligibility• GST Input ledgers• Closing balance as on March..
Validation / in eligible• Staff welfare• Vehicles – FA Register + Repairs
& Maintenance• Insurance• Travel & Conveyance• Exempted Outward• FA – Civil Work• Missing in 2A• Etc etc
CA Venugopal Gella
Credit flow
Credits to Electronic Credit Ledger(ECrL)
Reported thru GSTR
3B
4A-4B=4C
Direct Entry to ECrL
Trans I Trans II ITC 01 ITC 02
<< Table 6K- 6MTable 6B to 6H >>
CA Venugopal Gella
Total Reporting of INPUT TAX CREDIT
ITC 2018-19
Availed
In 18-19
Table 6
In 19-20
Table 13
Reversed
In 18-19
Table 7
In 19-20
Table 12
CA Venugopal Gella
Credit Flow of GSTR 3B into GSTR 9
Matching Credits
GSTR 9 GSTR 3B
6B + 6H 4A5Forward Charge
Credit
6C + 6D 4A3 Reverse Charge Credit
6E 4A1Import of
Goods
6F 4A2Import of Services
6G 4A4 ISD Credit
CA Venugopal Gella
Reconciliation of GSTR 9 ITC
Net ITC Availed = 7J
Utilised During the Year
Table 9
Unused ITCECL Balance for
March 2019
CA Venugopal Gella
ITC Reconciliation with Books & GSTR 9
Net ITC available Table 7J
ITC availed for the Previous FY
Table 13
Reversal of ITC availed during
previous FYTable 12
ITC as per Books
CA Venugopal Gella [email protected]
Pt III Details of ITC for the financial year
Type IGST CGST SGST
2 5 3 4
6 Details of ITC availed during the financial year
A Total amount of input tax credit availed through FORM GSTR-3B (sum total of Table 4A of FORM GSTR-3B)3,12,028 75,359 75,359
Inputs - 1 1
Capital Goods
Input Services 9,423 45,886 45,886
Inputs - - -
Capital Goods
Input Services - 23,644 23,644
Inputs
Capital Goods
Input Services
Inputs -
Capital Goods
FImport of services (excluding inward supplies from SEZs)
-
G Input tax credit from recevied from ISD 3,02,605 5,828 5,828
HAmount of ITC reclaimed (other than B above) under the provisions of the Act
- - -
I Sub-Total (B to H above) 3,12,028 75,359 75,359
J Difference (I - A above) - - -
K - - -
L - - -
M - - -
N Sub-total (K to M above) - - -
O Total ITC availed (I + N above) 3,12,028 75,359 75,359
Description
Inward supplies (other than imports and inward supplies liable to reverse charge but includes
services received from SEZs)
Inward supplies received from unregistered persons liable to reverse charge (other than B
above) on which tax is paid & ITC availed
Inward supplies received from registered persons liable to reverse charge (other than B
above) on which tax is paid and ITC availed
Import of goods (including supplies from SEZs)E
C
D
B
1
Transition Credit through TRAN-I (including revisions if any)
Transition Credit through TRAN-II
Any other ITC availed but not specified above
CA Venugopal Gella
Pt III Details of ITC for the financial year
Type IGST CGST SGST
2 5 3 4
7 Details of ITC Reversed and Ineligible ITC for the financial year
A
B
C - - -
D
E
F
G
H 1,56,014 37,679 37,679
I Total ITC Reversed (A to H above 1,56,014 37,679 37,679
J Net ITC Available for Utilization (6O - 7I) 1,56,014 37,680 37,680
Reversal of TRAN-II credit
Other reversals (pl. specify)
Description
As per Rule 42
As per Rule 43
As per Rule 37
As per Rule 39
1
As per section 17(5)
Reversal of TRAN-I credit
CA Venugopal Gella
Match the Net Credits Availed through 3B
Table 4C of GSTR 3B
(Net ITC available after deducting reversals)
Table 6I of GSTR 9
6B to 6H
Table 7I of GSTR 9
ITC reversedminus
Difference can be only ifa) Erroneous Credit
reported in GSTR9, either excess or short
b) Reversal of Credits now done in GSTR9
CA Venugopal Gella
Reconciliation of RCM liability with RCM ITC
RCM
Liability
Table 4G of GSTR 9
ITC
URP / URD
Table 6C of
GSTR 9
RD
Table 6D of GSTR9
Import of Service
Table 6F of GSTR9
Not Matching1) Do cumulative for 17-18 &
18-192) Is liability in Table 10 vs
4G?
CA Venugopal Gella
Control Check for RCM from Registered Person
Table 4 of GSTR 2A
Table 4G of GSTR 9
(RCM Liability)
Table 4 of GSTR 2A
Table 6D of GSTR 9
(RCM ITC)
CA Venugopal Gella
Check between Table 8C and Table 13
• Table 8C of GSTR 9 Excludes ITC on imports and ITC on inward supplies liable to reverse charge
• Table 13 of GSTR 9 includes all ITC which is availed during subsequent FY including ITC on imports and ITC on inward supplies liable to reverse charge
Table 8C of GSTR 9Table 13 of GSTR 9
(ITC claimed in Apr-18 to Sep-18)
CA Venugopal Gella
Detection of Erroneous Credit
Credits Matching with
Reverse Charge Credit RCM liability reported in 4G of GSTR-9
Credit on Import of goods Reflected in the ICE Gate portal; 8I would be negative
ISD credits Part B of GSTR 2A
Credit reported as Trans Credit
Value in the electronic credit ledger
Any Other ITC Respective ITC forms ITC 01, ITC 02 etc should have filed
CA Venugopal Gella
Table 8D : Un reported GSTR 2A Line Items
GSTR 2A Credits 8A = 200
Reported in 3B /ECL = 120
Eligible & Availed
60
8B
Ineligible but availed
20
8B
Availed in 2018-19
40
8C
Not Reported 3B /ECL = 80
Missed out Taking credit
in 3B
35
8E
Ineligible & Not availed
45
8F
CA Venugopal Gella
Deriving Table 8A
ITC in GSTR 2A AmountTable 3+5 of GSTR 2A (Cr Note is -ve) XxxLess: Original invoices that are amended XXXLess: POS<> LOR XXXLess: Supplier Filing status N XXXLess: ISD Credits XXXTotal - (A) XXXActual Table 8A of GSTR9- Portal XxxDiff Ideally to be zero
CA Venugopal Gella
Segregation of GSTR 2A of 2018-19
ITC in GSTR 2A IGST
Total - (A) - Above Xxx
Of the above
Availed in 3B 18-19 ( Eligible + In eligible) - 4A of 3B XXXAvailed in 3B 19-20 XXX
Not Availed - (coz Ineligible) XXX
Balance Xxx
CA Venugopal Gella
8B, 8E, 8F
Table 8B ITC in GSTR 3B (Table 6B + 6H)
Table 8E Missed Credits
Table 8F Ineligible ITC
CA Venugopal Gella
Table 8C :ITC claimed next year
Credit of 2018-19 availed in 2019-20 Xxx
Less: 8C of 2017-18 Xxx
Table 8C of 2018-19 xxx
CA Venugopal Gella
8C illustration
2017-18 2018-19 Total8A 100,000 200,000 300,000books 80,000 220,000 300,000
AS per GSTR 3B
Claimed in 2017-18 75,000 75,000
Claimed in 2018-19 20,000 180,000 200,000Claimed in 2019-20 15,000 15,000
Not claimed ineligible 3,000 1,200 290,000Not Claimed forgot 2,000 3,800Total 100,000 200,000
GSTR 9 Reporting2017-18 2018-19
8A 100,000 200,0008B 75,000 200,0008C 20,000 -5,0008D 5,000 5,0008E 2,000 3,8008F 3,000 1,200
Total 100,000 200,000
CA Venugopal Gella
CreditsEligible
• Availed in GSTR 3B – same year Table 6 & Table 8B• Availed in GSTR 3B – Next year Table 6 & Table 8C + Table 13• Not availed – Forgot / Lapse Table 8E
In Eligible• Availed in GSTR 3B & Reversed Same year Table 7 & Table 8B• Availed in GSTR 3B & Reversed Next year Table 7 & Table 8B + Table 12• Not availed – Reported in 4D Table 8F
Meaning of 8D• If 8D is positive it means some credits in 2A are not taken in 3B• If 8D is negative it means credits availed in 3B are more than of 2A
CA Venugopal Gella
Notification 56/2019 CT : Inward SupplyTable Particulars Relaxation
6A to 6E Bifurcation of input credit Option to fill all credits in “input” only.
6C & 6D RCM ITC Option to fill details of 6C & 6D in table 6D only.
7A to 7H Credit Reversal Except reversal pertaining to Tran-1 (7F) & Tran-2(7G) option to fill all details in table 7H only.
8A to 8D Details of ITC Option to upload details of these tables in pdf format while filing GSTR-9C.
12 & 13 Amendments in next year Optional
CA Venugopal Gella
Liability & Tax Payments Data flow
Liability 1
Table 4
Add: Table 10
Less: Table 11
Liability 2
Table 9(2)
Add: Table 14(2)
Taxes Paid
Table 9(3-7)
Add: Table 14(3)
Liability 1 Liability 3 Liability 2 Difference represents DRC-03 / Refund /PY adj
CA Venugopal Gella
Difference between Taxes Paid & Payable
• Carry forward number of Table 10 & 11 of GSTR 9 :: 17-18
• ITC reversal in 3B > ITC availed in 3B
• Opening and closing balance in electronic Credit Ledger
• Refund of ITC claimed during the period
• other
CA Venugopal Gella
Values to check before filing➢4 N : Supplies and advances on which tax is to be paid (H + M) above
➢5 N : Total Turnover (including advances) (4N + 5M - 4G above)
➢6 O : Total ITC availed (I + N above)
➢7 J : Net ITC Available for Utilization (6O - 7I)
➢8 D : Difference [A-(B+C)] 2A vs 3B
➢10 & 11 : Supplies / tax declared through Amendments
➢12 : Reversal of ITC availed during previous financial year
➢13 : ITC availed for the previous financial year
➢14 : Differential tax paid on account of declaration in 10 & 11 above
