Details of Books of Accounts, Records and Documents to be maintained in GST (Other than persons covered under Composition Scheme)-Tough Road ahead in GSTR-9C
CA Arpit Haldia
With Filing date of GSTR-9C approaching, auditors while preparing the form have to specifically mention that the registered person has maintained the books of accounts, records and documents as required by the Law and the rules/notifications made/issued thereunder. The auditor in GSTR-9C is required to report
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:
Let’s have an overview about the Books of Accounts, Records and Documents to be maintained by a registered person under GST as per Section 35 of CGST Act, 2017 read with Rule 56 and 57 of CGST Rules, 2017.
Condition 1:- Requirements to be fulfilled by every registered person regarding maintenance of accounts
- Every registered person shall maintain true and correct account of—
- production or manufacture of goods,
- inward and outward supply of goods or services or both,
- stock of goods,
- input tax credit availed,
- output tax payable and paid,
- goods or services imported or exported,
- supplies attracting payment of tax on reverse charge along with the relevant documents, invoices, bills of supply, delivery challans, credit notes, debit notes, receipt vouchers, payment vouchers and refund vouchers.
- Every registered person shall maintain accounts of stock in respect of goods received and supplied by him, and such accounts shall contain particulars of the opening balance, receipt, supply, goods lost, stolen, destroyed, written off or disposed of by way of gift or free sample and the balance of stock including raw materials, finished goods, scrap and wastage thereof
- Every registered person shall maintain a separate account of advances received, paid and adjustments made thereto
- Every registered person shall keep and maintain an account, containing the details of tax payable (including tax payable in accordance with the provisions of sub-section (3) and sub-section (4) of section 9), tax collected and paid, input tax, input tax credit claimed, together with a register of tax invoice, credit notes, debit notes, delivery challan issued or received during any tax period.
- Every registered person shall keep the particulars of –
(a) names and complete addresses of suppliers from whom he has received the goods or services chargeable to tax under the Act;
(b) names and complete addresses of the persons to whom he has supplied goods or services, where required under the provisions of this Chapter;
(c) the complete address of the premises where goods are stored by him, including goods stored during transit along with the particulars of the stock stored therein.
Condition 2- Additional Requirement for Agents
Every agent referred to in clause (5) of section 2 shall maintain accounts depicting the,-
(a) particulars of authorisation received by him from each principal to receive or supply goods or services on behalf of such principal separately;
(b) particulars including description, value and quantity (wherever applicable) of goods or services received on behalf of every principal;
(c) particulars including description, value and quantity (wherever applicable) of goods or services supplied on behalf of every principal;
(d) details of accounts furnished to every principal; and
(e) tax paid on receipts or on supply of goods or services effected on behalf of every principal.
Condition 3: Additional Requirements for Manufacturer
Every registered person manufacturing goods shall maintain monthly production accounts showing quantitative details of raw materials or services used in the manufacture and quantitative details of the goods so manufactured including the waste and by products thereof.
Condition 4: Additional Requirements for Supplier of Services
Every registered person supplying services shall maintain the accounts showing quantitative details of goods used in the provision of services, details of input services utilised and the services supplied.
Condition 5: Additional Requirements for Works Contractor
Every registered person supplying services shall keep separate accounts for works contract showing –
(a) the names and addresses of the persons on whose behalf the works contract is executed;
(b) description, value and quantity (wherever applicable) of goods or services received for the execution of works contract;
(c) description, value and quantity (wherever applicable) of goods or services utilized in the execution of works contract;
(d) the details of payment received in respect of each works contract; and
(e) the names and addresses of suppliers from whom he received goods or services
Condition 6: Person acting as a carrier or clearing and forwarding Agent
Any person having custody over the goods in the capacity of a carrier or a clearing and forwarding agent for delivery or dispatch thereof to a recipient on behalf of any registered person shall maintain true and correct records in respect of such goods handled by him on behalf of such registered person and shall produce the details thereof as and when required by the proper officer.
Condition 7:-Where and How to keep the Accounts (For all registered persons)
- Every registered person shall keep the books of account at the principal place of business and books of account relating to additional place of business mentioned in his certificate of registration and such books of account shall include any electronic form of data stored on any electronic device.
- Any entry in registers, accounts and documents shall not be erased, effaced or overwritten, and all incorrect entries, otherwise than those of clerical nature, shall be scored out under attestation and thereafter the correct entry shall be recorded and where the registers and other documents are maintained electronically, a log of every entry edited or deleted shall be maintained.
- Each volume of books of account maintained manually by the registered person shall be serially numbered.
- Unless proved otherwise, if any documents, registers, or any books of account belonging to a registered person are found at any premises other than those mentioned in the certificate of registration, they shall be presumed to be maintained by the said registered person.
- Accounts maintained by the registered person together with all the invoices, bills of supply, credit and debit notes, and delivery challans relating to stocks, deliveries, inward supply and outward supply shall be preserved for the period as provided in section 36 and shall, where such accounts and documents are maintained manually, be kept at every related place of business mentioned in the certificate of registration and shall be accessible at every related place of business where such accounts and documents are maintained digitally.
- The records may be maintained in electronic form and the record so maintained shall be authenticated by means of a digital signature.
- Proper electronic back-up of records shall be maintained and preserved in such manner that, in the event of destruction of such records due to accidents or natural causes, the information can be restored within a reasonable period of time.
Comments: These are onerous requirements, and very few taxpayers would have complied with all of the requirements. The challenge lies ahead for the taxpayers to meet the requirements for preparation of such onerous records.