[Opinion] GSTR 9 and 9C – Optional to Mandatory reporting in FY 2021-22

Ritesh Jain – [2022] 145 taxmann.com 318 (Article)

As we are into 1st week of December 2022, the said month assumes comparatively more importance from GST compliance perspective since 31 December 2022 is the due date to furnish GSTR 9 and GSTR 9C for FY 2021-22. In this article, we would mainly comment on applicability of GSTR 9 and 9C along-with key pre-requisites.

A) Applicability for FY 2021-22

The applicability of GSTR 9 and GSTR 9C for FY 2021-22 is akin to that of FY 2020-21. However, for easy reference, we have reiterated the same below:

• GSTR 9 is to be furnished by all taxpayers whose aggregate turnover exceeds INR 2 crore.
• Conversely, GSTR 9 is exempt for taxpayers whose aggregate turnover is less than or equal to INR 2 crore.
• Further, a self-certified statement in GSTR 9C should be furnished by taxpayers whose aggregate turnover exceeds INR 5 crore.
• Accordingly, a taxpayer (whose aggregate turnover is between INR 2 crores and INR 5 crore) is required to only file GSTR 9.

B) Key Pre-Requisites

• Finalisation of books of accounts.
• In case of multi-state GSTINs, extraction of state-wise trial balance whereby total of all states should be tallied with turnover/ input tax credit (‘ITC’) as per financials.
• From outward perspective, transactional level reconciliation of GSTR 1 vs GSTR 3B vs books of accounts.
• From inward perspective, transactional level reconciliation of GSTR 2B vs GSTR 3B vs books of accounts.
• To track reporting of outward as well as inward supply transactions (along-with amendments) of FY 2021-22 in GSTR 1/ GSTR 3B of April 2022 to October 2022 tax periods filed till 30 November 2022.
• To also extract details of ITC pertaining to FY 2020-21 availed in FY 2021-22 for reporting the same in GSTR 9C.
• HSN wise outward supply details should be collated. (6 digit HSN for taxpayers with more than INR 5 crore turnover. 4 digit HSN for all B2B supplies by taxpayers having less than INR 5 crore turnover).
• GST rate-wise break-up of turnover as well as liability reported in GSTR 9 should be prepared (along-with RCM transactions).
• To verify GST data available on income tax website.

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