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Comparative Analysis of Scope and Reporting Requirements in Part B of GSTR-9C – Why the difference in Scope and Responsibilities and what purpose would submission of Cash Flow Statement suffice

Comparative Analysis of Scope and Reporting Requirements wherein GSTR-9C is drawn up by the person who had conducted the audit or is drawn up by a person other than the person who had conducted the audit of the accounts- Why the difference in Scope and Responsibilities and what purpose would  submission of Cash Flow Statement suffice

                                                                                                                                                                CA Arpit Haldia

 

As is well known that GSTR-9C can be drawn up by the person who had conducted the audit or is drawn up by a person other than the person who had conducted the audit of the accounts. This article throws a bird eye view on the difference in the reporting responsibilities.

ParticularsParticulars in Part B-IParticulars in Part B-IIComment
 

Heading

 

Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by the person who had conducted the audit:

 

Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the person who had conducted the audit of the accounts:

 

Differentiation on the basis of who draws the Reconciliation Statement

Declaration of Audit conducted under any other StatuteI/we report that the audit of the books of accounts and the financial statements of M/s. ………………..…………………. (Name and address of the assessee with GSTIN) was conducted by M/s. …………………………………………..………. (full name and address of auditor along with status), bearing membership number in pursuance of the provisions of the …………………………….Act,Reporting of who conducted the Audit under other Statue
 

Examination/Annexation of Balance Sheet/Profit and Loss Account

 

 

 

I/we have examined the—

 

 

 

 

(a) balance sheet as on ………

 

(b) the *profit and loss account/income and expenditure account for the period beginning from ………..…to ending on ……., and

 

(c) the cash flow statement for the period beginning from ……..…to ending on ………,

 

—attached herewith, of M/s …………… (Name), …………………….………… (Address), ..…………………(GSTIN).

 

*I/we annex hereto a copy of their audit report dated ……………………………. along with a copy of each of

 

(a) balance sheet as on ………

 

(b) the *profit and loss account/income and expenditure account for the period beginning from ………..…to ending on …….,

 

(c) the cash flow statement for the period beginning from ……..…to ending on ………, and

 

(d) documents declared by the said Act to be part of, or annexed to, the *profit and loss account/income and expenditure account and balance sheet.

 

Even though Reconciliation Statement is drawn by a person other than the person conducted Audit under other Statute but Cash Flow Statement would always be prepared by person who conducted the Audit under other Statute (For Part B-II)

 

(Additional Compliance in case of Audit under Section 44AB or other Statue where Cash Flow Statement are not part of Audit Report

 

 

Observation

 

 

Based on our audit I/we report that the said registered person—

 

 

*has maintained the books of accounts, records and documents as required by the IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

 

 

*has not maintained the following accounts/records/documents as required by the IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

 

1.

2.

3.

 

 

Based on our audit I/we report that the said registered person—

 

*has maintained the books of accounts, records and documents as required by the IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

 

*has not maintained the following accounts/records/documents as required by the IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

 

1.

2.

3.

 

 

Declaration regarding Books of Accounts/Records maintained and discrepancies thereof

 

 

Documents Annexed alongwith GSTR-9C

 

4. The documents required to be furnished under section 35 (5) of the CGST Act / SGST Act and Reconciliation Statement required to be furnished under section 44(2) of the CGST Act / SGST Act is annexed herewith in Form No. GSTR-9C.

 

3. The documents required to be furnished under section 35 (5) of the CGST Act / SGST Act and Reconciliation Statement required to be furnished under section 44(2) of the CGST Act / SGST Act is annexed herewith in Form No. GSTR-9C.

 

 

No Change

 

 

Discrepancies

 

 

3. (a) *I/we report the following observations/ comments / discrepancies / inconsistencies; if any:

 

…………………………………….  …………………………………….

 

 

NA

 

 

No observation to be reported additionally in Part B-II and no guidance on discrepancies to be reported here

 

 

Reporting

 

 

3. (b) *I/we further report that, –

 

(A) *I/we have obtained all the information and explanations which, to the best of *my/our knowledge and belief, were necessary for the purpose of the audit/ information and explanations which, to the best of *my/our knowledge and belief, were necessary for the purpose of the audit were not provided/partially provided to us.

 

(B) In *my/our opinion, proper books of account *have/have not been kept by the registered person so far as appears from*my/ our examination of the books.

 

(C) I/we certify that the balance sheet, the *profit and loss/income and expenditure account and the cash flow Statement are *in agreement/not in agreement with the books of account maintained at the Principal place of business at ……………………and ** ……………………additional place of business within the State.

 

 

NA

 

 

Additional Reporting in Part B-I-No such reporting in Part B-II

Certification regarding true and correct View of GSTR-9C5. In *my/our opinion and to the best of *my/our information and according to explanations given to *me/us, the particulars given in the said Form No. GSTR-9C are true and correct subject to following observations/qualifications, if any:

 

(a)……………………………………………

 

(b)……………………………………………

 

(c) ………………………………………………

4. In *my/our opinion and to the best of *my/our information and according to examination of books of account including other relevant documents and explanations given to *me/us, the particulars given in the said Form No.9C are true and correct subject to the following observations/qualifications, if any:

 

(a) .…………………………….…………

 

(b) ………….………………….…………

 

(c) .…………………………….…………

Additional declaration of Examination of Books of Accounts provided in Part B-II

Comment: It can be clearly observed that there is a huge gap in Scope and Responsibilities in Part B-I and Part B-II. Further additional requirement of cash flow statement burdens the reporting requirement i.e. wherein GSTR-9C is drawn up by the person who had conducted the audit or is drawn up by a person other than the person who had conducted the audit of the accounts.

 

It is difficult to perceive the benefits which would be served by the additional requirement of submission of cash flow statement in GST Reconciliation statement as GST Authorities would not be checking and nor would be concerned with the  financial health of the business as like the bankers and shareholders.

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