KNOW YOUR GSTR 9 – TABLE 4A : All about Table 4A of GSTR 9

1.) Table 4A of GSTR 9 contains summary of supplies made to the unregistered person. Supplies made through electronic commerce operator to unregistered persons also would be included in this table . It will contain all the supplies to unregistered persons irrespective of quantum, intrastate or interstate supplies.

2.) Treatment of missing / incorrect invoices:- Circular No. 26/2017 dated 29 Dec 2017 provides the facility to insert / correct the missing or incorrect invoices in any subsequent months. This facility allows two kinds of insertions and corrections :-

(a) Transactions pertaining to 2017-18 in any month was inserted / corrected in subsequent month within 2017-18 itself

(b) Transactions pertaining to 2017-18 in any month was inserted / corrected in subsequent month but during 2018-19 ( correction / insertion was permitted up to 23rd April 2019 vide order no. 2/2018 dated 31 Dec 2018)

3.) Table 4A contain information from GSTR 1 filed for 2017-18 only . Insertion / correction in thru GSTR 1 of April 2018 or later is not allowed in case of B2C amounts reported

4.) Similarly , any credit / debit notes dated prior to March 2018 but reported in 2018-19 as an amendment should NOT be considered for deriving the final value to be disclosed in Table 4A

5.) Treatment of Credit / Debit Note :-

(a) Information filled in this table would be net of credit / debit note issued in respect of B2C supply during FY 2017-18.

(b) Credit / Debit Notes in respect of original supply in 2017-18 but issued and dated after 31st March 2018 would continue to be considered for 2018-19 only and not be adjusted with transactions of 2017-18 .

(c) Credit/ Debit notes affecting price relating to original supplies made before 01 July 2017 are required to be considered in 2017-18 as it were a transaction in GST regime itself .( Refer Section 142(2)(a) and (b) of the CGST Act .

6.) Other important points :-

(a) All information reported in Table 4A must flow from GSTR 1 provided that tax liability has been discharged from GSTR 3B for 2017-18.

(b) NIL rated / Exempted / Non GST supplies should not be reported in this table

(c ) Advance received during the year should not be part of this clause

(d) Taxable values and tax payable , extracted from GSTR 1 should be reconciled with the reporting made under outward supplies as per Table 3.1(a) in GSTR B

7.) Illustrations :-

(a) In September 2017 , intra state B2B invoice amounting to Rs 8,00,000/- entered by mistake as B2C . The same has been rectified in June 2018 .

Solution :- The incorrect amount from Table 4A should be reduced and the correct amount should be reported in B2B ( Table 10/11 of GSTR 9)

(b) In the month of Aug 2017 , Interstate B2C invoice of Rs 4,00,000 incorrectly entered as 40000/- .The same has been rectified in March 2018

Solution : Since the rectification carried out in 2017-18 itself , rectified value should be taken in table 4A

(c) Credit Note of Rs 1,50,000 issued in April 2018 in respect of B2C supply in Jan 2018 for Rs 3,50,000/-

Solution : In this case , though credit Note pertains to Jan 2018 , it was issued in April 2018 , hence , Rs 150000/- would not be allowed as reduction in value

Conclusion :-

While preparing Table 4A ( or any other table of GSTR 9 , for that matter ) , exercise involve is to compile the information to identify completeness of information extracted from GSTR 1 as declared in 2017-18 and up to dates permitted for corrections in 2018-19

Author Anita Bhadra can be reached at [email protected]

Tags : KNOW YOUR GSTR 9 – TABLE 4A, All about Table 4A of GSTR 9, How to file GSTR 9, FAQ’s on GSTR-9, GST Annual Return Form, GSTR 9