Under Goods and Service Tax (“GST”), Annual return is required to be furnished in form GSTR-9 and Reconciliation statement and certificate is required to be furnished in form GSTR-9C.
As these forms are getting filed for the first time and considering the various issues faced by taxpayers, due date of filing of GSTR-9 and GSTR-9C has been extended till 30th November, 2019 for FY 2017-18.
Similarly, taxpayers are also facing various issues in the filing of Form GST RFD-01 (Application of Refund).
To resolve the issues faced by taxpayers, the department has made various amendments in its 7th Amendment Rules in the form of GST RFD-01 and also liberalize reporting requirements of Form GST RFD-01, GSTR-9 and GSTR-9C vide Central Goods and Services Tax (7th Amendment Rules), 2019.
1. Amendment in form GST RFD-01 as per 7th Amendment Rules
To simplify the information furnished at the time of filing of refund application, the Central Board of Indirect Taxes and Customs (“CBIC” or “Department”) has notified the following certain changes in the 7th Amendment Rules annexure to form GST RFD-01:
A. Amendment in Existing annexures:
| Annexure |
Amendment |
|
Statement-1A (Refund Type: ITC accumulated due to inverted tax structure)
|
Statement 1A has been amended to provide following information additionally:
- Type of Inward Supply
- Type of Document - Tax Invoice/Credit Note/Debit Note
- Bill of Entry No., if applicable
- Port Code
|
|
Statement 2 (Refund Type: Export of services with payment of tax (accumulated ITC))
|
Statement 2 shall contain the following information additionally: Document-wise detail is required to furnish for Debit Note and Credit Note.
|
|
Statement 3 (Refund Type: Export without payment of tax (accumulated ITC))
|
For claiming refund for exports without payment of taxes, taxpayer is required to enter following information additionally:
- Type of document
- Amount of BRC/FIRC (In earlier form, only number and date was required)
|
|
Statement-4 (Refund Type: On account of supplies made to SEZ unit or SEZ Developer (on payment of tax))
|
In statement 4, following information is required: Document-wise detail is required to furnish for Debit Note and Credit Note.
|
|
Statement-5 (Refund Type: On account of supplies made to SEZ unit or SEZ Developer (without payment of tax))
|
Details of Debit and Credit Note are required to be furnished document-wise.
|
|
Statement-5B (On account of deemed exports)
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Two separate tables have been notified where refund is claimed by supplier or recipient in case of deemed export.
|
|
Statement-6 (Refund Type: On account of change in POS (inter-state to intra-state and vice versa))
|
Taxpayer is required to mention Document type for each invoice, i.e., Debit Note, Credit Note or Tax Invoice.
|
B. New Statement inserted as per 7th Amendment Rules
| Annexure |
Clause |
|
Statement -4A (Refund by SEZ on account of supplies received from DTA – With payment of tax)
|
Annexure-4A has been inserted which shall be used by SEZ units for claiming refunds of taxes charged by DTA while supplying to SEZ units. Following information is required to be furnished:
- GSTIN of supplier
- Type of Document
- Document Number
- Document Date
- Document Value
- Number and date of Shipping Bills / Bill of Export / Endorsed Invoices by SEZ
- Taxable Value
- IGST
|
2. Amendment or Clarification on form GSTR-9:
GSTR-9-Annual Return is one of the crucial forms as it contains complied information for the entire financial year. However, due to the complexity of information involved and also non-clarity on various contents of the form, the due date of filing of first GSTR-9 of FY 2017-18 has further been extended till 31st December 2019.
Therefore, CBIC has amended or provided clarification in the 7th Amendment Rules about the following contents of form GSTR-9 through Notification No. 56/2019 – Central Tax dated 14th November 2019:
| Reference |
Information |
Amendment in 7th Amendment Rules |
| 8C |
ITC of current year claimed in succeeding FY |
Separate column for FY 2018-19 (Apr–Sep 2019) |
| V |
Current year transactions declared in next FY |
Separate column for FY 2018-19 (Apr–Sep 2019) |
| 4B–4E |
Details of B2C, B2B, Exports, SEZ, Deemed Export |
Option to report net of Notes/Amendments; Tables 4I–4L optional (FY 17-18 & 18-19) |
| 5D–5F |
Exempted, Nil Rated & Non-GST Supplies |
If not distinguished, report combined in 5D (FY 17-18 & 18-19) |
| 5A–5F |
Outward supplies on which tax is not payable |
Option to report net of Notes/Amendments; Tables 5H–5L optional |
| 6B |
GST paid on inward supplies |
Report all under “Inputs” (FY 17-18 & 18-19) |
| 6C–6D |
RCM inward supplies |
Report all under “Inputs” or consolidated in 6D |
| 6E |
ITC on import of goods |
Report under “Inputs” |
| 7A–7H |
ITC reversed & ineligible |
Report in 7H; TRAN-1/2 to be reported separately |
| 8A |
Auto ITC from GSTR-2A |
As of 1st Nov 2018 (FY 18-19) |
| 8A–8D |
ITC reconciliation |
Upload signed PDF in GSTR-9C (FY 17-18 & 18-19) |
| 10 |
FY 17-18 transactions declared till Mar 2019 |
Amended to include FY 18-19 (Apr–Sep 2019) |
| 12–13 |
Reversal & availing of previous FY ITC |
Optional (FY 17-18 & 18-19) |
| 15A–15G |
Demands & Refunds |
Optional (FY 17-18 & 18-19) |
| 16A–16B |
Composition, sec 143 & approval basis |
Optional (FY 17-18 & 18-19) |
| 17–18 |
HSN summary – outward & inward |
Optional (FY 17-18 & 18-19) |
3. Amendment or Clarification on form GSTR-9C:
Following amendments or clarifications in 7th Amendment Rules are provided with respect to form 9C:
| Reference |
Information |
Amendment |
| Table 5B–5H |
Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in
Annual Return (GSTR-9)
|
For FY 2017-18 and 2018-19, the registered person shall have an option to not fill this table. If there are any adjustments required to be reported, they may be reported in Table 5O.
|
| Table 12B & 12C |
ITC booked in earlier Financial Years claimed in current Financial Year & ITC booked in current Financial Year to be claimed in subsequent Financial Years
|
For FY 2017-18 and 2018-19, the registered person shall have an option to not fill this Table.
|
| Table 14 |
Reconciliation of ITC declared in Annual Return (GSTR-9) with ITC availed on expenses as per audited Annual Financial Statement or
books of account
|
For FY 2017-18 and 2018-19, the registered person shall have an option to not fill this Table.
|
Read more Certain Important clarification on GST Audit and GST Annual Returns
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