Analysis of GSTR 9A orGST Annual Return for Composition Taxpayer

Deepak Gupta | Nov 13, 2018 |

Analysis of GSTR 9A orGST Annual Return for Composition Taxpayer

Analysis of GSTR 9A or GST Annual Return for Composition Taxpayer :
The Composition Taxpayer registered under GST have to file various returns including an annual return. As per the provisions of GST, Composition Taxpayer is required to file an annual return (GSTR 9A) once in a financial year on or before 31stof December following the end of such financial year. [For FY 17-18 the due date for Filing GSTR 9A has been extended to 30th June 2019]
It is important to note that a Registered person who has opted in or opted out of composition is required to file both GSTR 9 & GSTR 9A for the relevant periods.
Broadly, an annual return forComposition Taxpayer or GSTR 9A is divided into 5 basic parts and the same are summarized here under
Through this article we have tried to analyse the broad elements of the Annual Return Form forComposition Taxpayer or GSTR 9A.

Amendment made byNotification No. 74/2018 Central Tax dated 31st December, 2018
1.) Headings in FORM GSTR-9A would be in respect of supplies etc. made during the year and not as declared in returns filed during the year.
2.)It is mandatory to file all your FORM GSTR-4 for the FY 2017-18 before filing this return. The details for the period between July 2017 to March 2018 are to be provided in this return.
3.)It may be noted that additional liability for the FY 2017-18 not declared in FORM GSTR-4 may be declared in this return.

Analysis of GSTR 9A or Annual Return for Composition Taxpayer

GSTR 9A can be classified in 5 major parts, they are as follows :

PartsDescriptionTables
Part 1Basic DetailsTable 1-5
Part 2Details of outward and inward supplies made during the financial yearTable 6-8
Part 3Details of tax paid as declared in returns filed during the financial yearTable 9
Part 4Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of filing of annual return of previous FY whichever is earlierTable 10-14
Part 5Other InformationTable 15-17

Part 1 :Basic Details


Part I comprises of Basic Details likeFinancial Year for which Annual Return is being filed, GSTIN Number , Legal Name and Trade Name of the Entity,Period of composition scheme during the year (From —- To —-) andAggregate Turnover of Previous Financial Year.
Points to be noted :

  1. Legal Name & Trade Name : Distinction between a trade name and a legal name must be clearly understood and borne out in clause 3A and 3B of Part I. Attention must be paid to the fact that the trade name and legal name are not used interchangeably.
  2. Period of composition scheme during the year(From —- To —-) : The start period shall be the period at which the composition scheme commenced. It is a possibility that the person was unregistered and later opted for Composition Scheme and it is also a possibility that a registered person could be registered as a Regular Registrant on migration and later opted to migrate to composition scheme. One should take care of the fact that period of commencement of composition scheme would be :
    • For persons already registered under pre-GST regime: Appointed Day or
    • Registered under GST and person switches to Composition Scheme: Date of filing of the Intimation

Part 2 : Details of outward and inward supplies made during the financial yearTable 6 : Details of Outward supplies on which tax is payable as declared in returns filed during the financial year

Table 6 of Form GSTR 9A requires reporting of Outward supplies on which tax is payable as declared in returns filed during the financial year. This table should only include the detailspertaining to the period July 2017 to March 2018 and not amendments pertaining to 2017-18 effected in the GSTR 4 filed during the year 2018-19.
Aggregate value of all outward supplies net of debit notes / credit notes, net of advances and net of goods returned for the entire financial year shall be declared in Table 6A. Table 6 and Table 7 of FORM GSTR-4 may be used for filling up these details.
Aggregate value of exempted, Nil Rated and Non-GST supplies shall be declared in Table 6B.
Table 7 :Details of inward supplies on which tax is payable on reverse charge basis (net of debit/credit notes) declared in returns filed during the financial year
Aggregate value of all inward supplies received from registered persons on which tax is payable on reverse charge basis shall be declared in Table 7A. Table 4B, Table 5 and Table 8A of FORM GSTR-4 may be used for filling up these details.
Table 4B, Table 5 and Table 8A of FORM GSTR-4 are described below :

Table 4BInward supplies received from a registered supplier (attracting reverse charge)
Table 5Amendments to details of inward supplies furnished in returns for earlier tax periods in the above Table [including debit notes/credit notes and their subsequent amendments]
Information from this table to be considered only to the extent of amendments made to Table 4B.
Table 8 AAdvance amount paid for reverse charge supplies in the tax period (tax amount to be added to output tax liability).
Advances from this table to be considered only to the extent related with Table 4B.

Aggregate value of all inward supplies received from unregistered persons (other than import of services) on which tax is payable on reverse charge basis shall be declared in Table 7B. Table 4C, Table 5 and Table 8A of FORM GSTR-4 may be used for filling up these details.
Table 4C, Table 5 and Table 8A of FORM GSTR-4 are described below :

Table 4CInward supplies received from a registered supplier (attracting reverse charge)
Table 5Amendments to details of inward supplies furnished in returns for earlier tax periods in the above Table [including debit notes/credit notes and their subsequent amendments]
Information from this table to be considered only to the extent of amendments made to Table 4C.
Table 8 AAdvance amount paid for reverse charge supplies in the tax period (tax amount to be added to output tax liability).
Advances from this table to be considered only to the extent related with Table 4C.

Aggregate value of all services imported during the financial year shall be declared in Table 7C. Table 4D and Table 5 of FORM GSTR-4 may be used for filling up these details.
Table 8 : Details of other inward supplies as declared in returns filed during the financial year
Aggregate value of all inward supplies received from registered persons on which tax is payable by the supplier shall be declared inTable 8A. Table 4A and Table 5 of FORM GSTR-4 may be used for filling up these details.
Aggregate value of all goods imported during the financial year shall be declared in Table 8B.

Part 3 : Details of tax paid as declared in returns filed during the financial year

Part 4 : Particulars of the transactions for the previous FY declared in returns of April to September of current FY or upto date of filing of annual return of previous FY whichever is earlier


Details of additions or amendments to any of the supplies already declared in the returns of the previous financial year but such amendments were furnished in Table 5 (relating to inward supplies) or Table 7 (relating to outward supplies) of FORM GSTR- 4 of April to September of the current financial year or upto the date of filing of Annual Return for the previous financial year, whichever is earlier shall be declared in Table 10, 11, 12, 13 and 14.
[One may note that for FY 17-18 the due date for making such adjustment was 25th October 2018]

Part 5 : Other


Table Number15A, 15B, 15C and 15D : Aggregate value of refunds claimed, sanctioned, rejected and pending for processing shall be declared here. Refund claimed will be the aggregate value of all the refund claims filed in the financial year and will include refunds which have been sanctioned, rejected or are pending for processing. Refund sanctioned means the aggregate value of all refund sanction orders. Refund pending will be the aggregate amount in all refund application for which acknowledgement has been received and will exclude provisional refunds received. These will not include details of non-GST refund claims.
Table Number15E, 15F and 15G :Aggregate value of demands of taxes for which an order confirming the demand has been issued by the adjudicating authority has been issued shall be declared here. Aggregate value of taxes paid out of the total value of confirmed demand in 15E above shall be declared here. Aggregate value of demands pending recovery out of 15E above shall be declared here.
Table Number 16A :Aggregate value of all credit reversed when a person opts to pay tax under the composition scheme shall be declared here. The details furnished in FORM ITC-03 may be used for filling up these details.
Table Number 16B :Aggregate value of all the credit availed when a registered person opts out of the composition scheme shall be declared here. The details furnished in FORM ITC-01 may be used for filling up these details.
Table Number 17 :Late fee will be payable if annual return is filed after the due date.
(The Author of this Article can be reached at [email protected])
Disclaimer: The entire contents of this document have been prepared on the basis of relevant provisions and as per the information existing at the time of the preparation. Although care has been taken to ensure the accuracy, completeness and reliability of the information provided, I assume no responsibility therefore. Users of this information are expected to refer to the relevant existing provisions of applicable Laws. The user of the information agrees that the information is not a professional advice and is subject to change without notice. I assume no responsibility for the consequences of use of such information.In no event shall I shall be liable for any direct, indirect, special or incidental damage resulting from, arising out of or in connection with the use of the information. Please refer your consultant before relying on the provisions of this article.

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