Whether Auto-populated Data in Table 4 of GSTR-9 can be used for preparation of Annual Return and possible treatment of Difference between GSTR-1 and GSTR-3B??
CA Arpit Haldia
It would be pertinent here to mention that for the purpose of filing of Annual Return either details provided in GSTR-3B would be final since the tax has been discharged through GSTR-3B or the details would have to be provided as per books of accounts. The values being auto-populated in GSTR-9 are from GSTR-1 but instructions provide that all supplies payment for which has been made through GSTR-3B are to be shown here. Therefore, details provided in GSTR-1 only have suggestive impact but it cannot be made the base to file the return.
Agenda of 31st GST Council Meeting for Approval of GSTR-9
If the payment of tax for a supply has been made in the return for FY 2017-18, then supply is required to be declared in Part II of FORM GSTR-9. If payment for a supply has been made between April to September, 2018, then supply related to such payment shall be declared in Part V of FORM GSTR-9.
Instructions to GSTR-9
Part II consists of the details of all outward supplies & advances received during the financial year for which the annual return is filed. It may be noted that all the supplies for which payment has been made through FORM GSTR-3B between July 2017 to March 2018 shall be declared in this part.
Part V consists of particulars of transactions for the previous financial year but paid in the FORM GSTR-3B of April to September of current FY or date of filing of Annual Return for previous financial year (for example in the annual return for the FY 2017-18, the transactions declared in April to September 2018 for the FY 2017-18 shall be declared), whichever is earlier.
Therefore, suggestive treatment in this regard is as follows, however reader may use their discretion and further clarification by Government would be welcome as there is lack of clarity in this regard:
Therefore, we need to be very cautious while using autopopulated Data on the basis GSTR-1 for preparation of GSTR-9. Although Clarification in this matter would be welcome but as of now suggestive treatment is as follows:
a) Tax Paid between July to March 2018 by 3B:- Table 4
b) Tax paid between April to September 2018 by 3B: Table 10 and 11
c) Tax paid through Annual Return: Table 4 and Use of DRC-03