GST Annual Return (GSTR 9) – A clause by clause analysis Part-1

GST Annual Return (GSTR 9) – A clause by clause analysis Part-1

By CA Vishal Jain

At present, the most talked about topic after Indian general elections and avengers- end game, is GST annual return and GST audit, i.e. Form GSTR-9 and GSTR 9C and Mr. Jain has approached Mr. GST to get the overview of the same. Following are the excerpts of their conversation:

1 What is GST annual return
Under GST law, section 44 requires every registered person to file a return on annual basis for a FY in Form GSTR 9, containing the details of outward and inward supplies on annual basis.
2 But why When a registered person is already filing GSTR 1, GSTR 3B for a tax period, then why annual reporting is required
GSTR 9 is nothing, but the consolidation of the details already punched in GSTR 1, GSTR 3B and GSTR 2A, in a more comprehensive manner with some additional information requirements.
3 But is that all! I mean there must be something more attached to it you know, as the government is not asking us to just compile the already filled details
Oh yes! Absolutely, the format of GSTR 9, as notified is based on the premise that the details of outward supply appearing in the GSTR 1 and GSTR 3B are in agreement with each other, further, the details of ITC as appearing in GSTR 2A and GSTR 3B are in concurrence with each other and how ideally it should be. Having said that, I know being the first year of implementation some mistakes are bound to happen and if there is any mismatch between the details reported in GSTR 1 &3B or GSTR 2A &3B, as the case may be, then my friend it is your last chance to rectify the same i.e. GSTR 9 can be used as a tool to report the undisclosed supplies or supplies omitted to be disclosed in the monthly filled returns.
4 Okay, so from where the GSTR 9 should be prepared, I mean from GSTR 1 or GSTR3B
The details of outward supplies should flow from GSTR 1 and the details of inward supplies including RCM should flow from GSTR 3B. However, if there is any mismatch between the details of outward supply in GSTR 1 and GSTR 3B, then:

5 Huh, what rubbish, Im not gonna file these forms, what harm will it make
Bro listen,
– Department can send you notice under section 46- prem patra k liye tayar rehna;
– Late fees upto INR 200/ day (CGST +SGST) or 0.25% of the turnover in state, whichever is lower;
– Penalty under section 125 upto INR 50,000 (CGST +SGST).
6 Im a composition dealer should I also file GSTR 9
No GSTR ‘9A is required to be filled by the composition dealers.
7 Am I required to file annual return even if :
A. I have obtained registration only for making payment of taxes on reverse charge basis.
B. No outward supply whatsoever only inward supply
C. No activity whatsoever i.e. no inward supply no outward supply
D. I have cancelled my registration in 17-18 still am I required to file GSTR- 9
– casual taxable person
– non resident taxable person
– input service distributor
– tax deductor under section 51
– tax collector under section 52
8. Koi CA certificate chahiye GSTR-9 ke liye
9 I have not filed some/all of return for the FY 17-18
You have to file all the returns first so as to enable yourself tom file GSTR 9.
10 I have filed all my returns late for FY 17-18 in 18-19 what should I do
GSTR-9 can be filled even if returns are filed belatedly.
11 whether GSTR-9 is required to be filed for all GSTIN or on PAN based
It is to be filed for all GSTIN registered on the same PAN separately.
12 What is the last date to file GSTR-9 for FY-17-18
For FY 17-18 GSTR-9 can be filed upto June 30, 2019
13 I was registered as a composition dealer for some part of the FY and then switched to regular registration
Both GSTR-9 & GSTR-9A are required to be filed for respective period.
14 Is there any offline tool to file the same
Yes, offline utility can be downloaded from GST portal
15 As the due date for filing GSTR-9 is approaching near, will it be feasiable to punch data on random basis and revise the same later on
Off course not, as GSTR-9 once filed cant be revised. One must exercise due care and diligence while filing GSTR-9.
16 Can additional liability be paid while filing GSTR-9
Yes same can be paid through FORM DRC-03 in cash.
17 Whether ITC missed till 31/3/19 pertaining to FY 17-18 can be availed through GSTR-9
NO ITC not availed in GSTR-3B cant be availed through GSTR-9.
18 You were also saying something about GST audit , what is it & how it is related to GSTR-9
GSTR-9 and GSTR-9C (audit) are related concepts GSTR-9 is required to be  filed by every registered person irrespective of turnover, however GSTR-9C is required to be filed by only those persons whose turnover exceeds 2 crore and is required to be certified by CA or CMA in practice.

This is the first part of the series of article on GSTR-9, unravelling GSTR 9- A clause by clause analysis, there is much more to explore in these annual return and GST audits. It will be followed by the analysis of the table 4 and table 5 of the GSTR 9 in the second article.

The members who have already started assisting in filing of the Form-9 or conducting the GST audits and even those who are planning to start these activities could refer to this write-up and give us their comments on any practical issues arising there from.


The information cited in this Guide has been drawn primarily from the and other sources. Readers are requested to note Sl. Nos / Table nos etc., wherever mentioned refer to the appropriate part / table of the relevant Forms. While every effort has been made in this write-up to avoid any kind of errors or omissions. It is likely that errors may have crept in. Any mistake, error or discrepancy noted by the reader should be brought to the notice of the author so that suitable edits/ corrections shall be effected in the next edition. It is notified that the author will not be responsible for any damage or loss to anyone of any kind or in any manner what so ever by the use of this write-up.

The author is a qualified chartered accountant and can be reached at:
Email : [email protected]

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Vishal Jain (, ACA), Chartered Accountant qualified in November 2018, having meritorious academic background. Having experience in carrying out opinion, assurance and advisory services including review of business operations in different sectors ( Real estate , manufacturing, hospitality, trading and service sector), he has been delivering seminars and corporate training sessions on GST and contributing by authoring various trending article series He has been actively creating awareness on GST through the YouTube channel ? ?GST in Shorts? His core competency and area of expertise is indirect taxation including FTP, corporate taxation and audits and carries a blend of industry and professional experience.

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