GST Audit/Reconciliation and Certification (Form GSTR-9C)

by Madhav Joshi

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Posted on June 11, 2020

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• A registered taxable person whose turnover in a financial year goes above Rs 2 crore is required to get his books of accounts audited by a practicing chartered accountant or a cost accountant and need to file the audit report in Form GSTR – 9C with the annual return.
• Due date of filing the return is 31 December of the year in which the financial year ends.
•  A Chartered Accountant or a Cost Accountant can prepare GSTR 9C.

Following are the documents required to be submitted along with the Reconciliation statement in GSTR 9C are Audited Financial Statements such as:

• Balance Sheet
• P & L Account
• Cash flow statement
• Others prescribed Documents

Structure of reconciliation statement under GSTR 9C

The reconciliation statement is prepared in two parts:

• Part A is the reconciliation statement
• Part B Audit Report by the chartered accountant or the cost accountant who has drawn the Part A.

Part A divided into 6 sections:

• Part I-: Basic details
• Part-II-: Reconciliation of turnover  (GSTR-9)
• Part-III-: Reconciliation of tax paid
• Part-IV-: Reconciliation of ITC
• Part-V-: Auditor’s comment on additional Liability due to non-reconciliation.
• Part-VI-: HSN wise summary information.

Part I

This part includes basic details of the taxpayer which will be auto-populated i.e. FY, GSTIN, legal name, trade name. In addition, it also requires mention as to whether a person is liable to be audited under any other Law and if yes, the reference to that Act of Law has to be specified.

Part II

Part II involves the details of Outward and Inward supplies filed during the financial year. This detail is taken from a consolidating summary from all GST Returns 3B filed in the previous Financial Year.

• Table 5: Gross Turnover’s Reconciliation
• Table 6: Reason for Un-Reconciled difference in Annual Gross Turnover
• Table 7 Reconciliation of Taxable Turnover.
• Table 8: Reasons for Un-Reconciled Taxable Turnover

Part III

This part includes details of tax payable on outward supply during the previous Financial Year.

• Table 9: Reconciliation of rate wise liability and amount payable thereon.
• Table 10: Reasons for Un-Reconciled Payment  of Tax
• Table 11: Additional Amount Payable.

Part IV

In this part, we have a reconciliation of Input Tax Credits as per books of account and ITC as declared in the Annual Return.

• Table 12: Reconciliation of Input Tax Credit
• Table 13: Reasons for Unreconciled Difference in ITC
• Table 14: Reconciliation of ITC declared in Annual Return (GSTR 9) with ITC availed on expenses as per audited Annual Financial Statement
• Table 15: Reasons for Unreconciled difference in ITC
• Table 16: Tax payable on the unreconciled difference in ITC

Part V

This part includes details of the additional tax liability payable due to the unreconciled amounts as stated in the previous tables or any other outstanding liability on account of interest/late fees etc.

Part B: Auditor Certification

Part B gives the certification by the auditor. Certification is given Format I when reconciliation statement (FORM GSTR-9C) is drawn by the chartered accountant/cost accountant who had conducted the audit whereas Format II is applicable when reconciliation statement is drawn up by a person other than the person who had conducted the audit of the accounts.

Latest News as on 14th March 2020

39th GST Council Meeting Outcome

The due date for filing GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for FY 2018-19 is extended to June 30, 2020.

For businesses with an annual turnover of less than Rs 5 crore, filing of GSTR-9C for FY 2018-19 to be waived off.

For businesses with less than Rs 2 crore aggregate turnover in FY 2017-18 and FY 2018-19, no late fee will be charged for the delayed filing of GSTR-9.

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