GSTR 9 & 9C-

A Practical Approach

CA D.S.Agarwala &
CA Vikash Kumar Banka
Siliguri Branch of EIRC, Siliguri
11.08.2019
 Contents
• GSTR 9- Legal Provisions
• GSTR 9- Form Level Discussion
• GST Audit-Legal Provisions
• Practical approach to GST Audit
• GSTR 9C-Form Level Discussion

2
3
 Annual Return

Applicable to Not Applicable

to

ISD/TDS/TCS
Regd. Composition ECO if
Persons Taxpayers TCS u/s If Aggregate CTP/NRTP
52 Turnover>2
Cr. OIDAR
GSTR9 GSTR 9A GSTR 9B N
A CG/SG
GST Audit 9C Dept/LA- CAG
Audit, LA audit
 GSTR-9 Some
Due
Date 31st August, 2019 (ROD
July’17 to
6/19)
Period
Pre- March’18
Mandatory
Period
GSTR1
(Ins
GSTIN 2)
based
&
filing
Filing
3B (Ins 2) 5
 GSTR 9-Some

Revision
Late fee
No
Compulsory filing

100/- per day

Late fee (CGST+SGST),
Failure to Notice
Max- 0.25%in of
State Turnover) 6
 NIL GSTR 9-Conditions
If:
• No outward supply;
• No inward supply;
• No liability of any kind;
• Not claimed any ITC during the year;
• Not received any demand order;
• Not claimed any refund during the year
• No late fees paid

7
GSTR 9-Some key issues

Can taxes be paid?

Can unclaimed ITC of 17-

No
Yes, through DRC-03

18 be claimed?
(Instruction
No (Press
Can ITC be reversed
after March’19?
Can refund be
claimed?
No.
NoRelease
such 4)indt.
provision form

3/7/19) 8
9
Pay through DRC-03
Report in Table 4
Additional Liability (Ins 4)
 Reporting of Turnover Data in GSTR 9

Source: GSTR 1-Different Tables (As downloaded from

GST Portal)

Edit those Turnover data based on tax paid thereon

through GSTR 3B

If tax not paid through 3B (17-18 or 18-19), report

additional liability in T4 & pay through DRC-03

10
 GSTR-9
Part I Part II Part III Part IV Part V Part VI

Basic Details Liability ITC Taxes Paid Circular 26/2017 Other Info
Adjustments

Table 1-3 Table 4-5 Table 6-8 Table 9 Table 10-14 Table 15-19

11
 GSTR-9 at a glance
Description Table No. of GSTR 9

Turnover as per Books = 4 + 5 + 10-11

Tax Paid as per Books = 9 & 14

ITC as per Books = 6-7-12+13
Refund = 15
Informative details = 1,2,3,8,16,17,18
Late Fee payment = 19

12
 Supply

GST Supply- Sec 7 Non-GST Supply

Taxable Supply- Sec Non-Taxable Supply-Sec

2(108) 2(78)

Exempt Supply- Nil Rated

Sec 2(47) Supply

13
 Meaning of Goods & Services
Goods- Sec 2(52) Services- Sec 2(102)
• “Services” means anything other
• “Goods” means every kind
than goods, money and securities
of movable property other
but includes activities relating to
than money and securities
the use of money or its
but includes actionable
conversion by cash or by any
claim, growing crops, grass
other mode, from one form,
and things attached to or
currency or denomination, to
forming part of the land
another form, currency or
which are agreed to be
denomination for which a
severed before supply or
separate consideration is
under a contract of supply
charged;
14
 Exempt Supply- Sec 2(47)
• “Exempt supply” means supply of any goods or services or both
– which attracts nil rate of tax or
– which may be wholly exempt from tax under section 11, or under section 6 of
the IGST Act, and
– includes non-taxable supply;
 Nil Rated Supply
• No such rate in N. No.01/2017-CT (Rate) dt. 28.06.17 relating to Goods
• Three rates in N. No.11/2017-CT (Rate) dt. 28.06.17 relating to Services:

Sl. No. Heading Description

24 (i) 9986 Support services to agriculture, forestry,
fishing, animal husbandry
Ex- Supply of farm labour,
Renting or leasing of agro machinery or
vacant land,
Loading, unloading, packing, storage or
warehousing of agricultural produce;
 Nil Rated Supply
Sl. No. Heading Description
16(i) 9972 Services by CG, SG,UT or local authority
to governmental authority or
government entity, by way of lease of
land
16(ii) 9972 Supply of land or undivided share of land
by way of lease or sub lease where such
supply is a part of composite supply of
construction of flats, etc. specified in the
entry in column (3), against serial
number 3, at item (i) (ia), (ib), (ic), (id),
(ie) and  (if)]
 Examples- Books & GSTR 1 matched but
not 3B

Turnover
T4 T 10

Period Books GSTR 1 GSTR 3B

July’17–Mar’18 100 100 100 100 Nil

July’17–Mar’18 100 100 80 80 20

April’18-Mar’19 20
July’17–Mar’18 100 100 80
April’18-Mar’19 10 80+10 10
Unreported till 10
date
18
 Examples- Books & GSTR 3B matched but
not GSTR 1

Turnover
T4 T 10

Period Books GSTR 1 GSTR 3B

July’17–Mar’18 100 100 100 100 Nil

July’17–Mar’18 100 80 100 100 Nil

April’18-Mar’19 20
July’17–Mar’18 100 80 100
April’18-Mar’19 10 100 Nil
Unreported till 10
date

19
 Examples- GSTR 1 & 3B do not match with
Books

Turnover
T4 T 10

Period Books GSTR 1 GSTR 3B

July’17–Mar’18 100 100 100 100 Nil

July’17–Mar’18 100 80 80 80 20
April’18-Mar’19 20 20
July’17–Mar’18 100 80 80
April’18-Mar’19 10 10 80+10 10
Unreported till 10 10
date

20
GST Audit

21
 Legal Provisions
Section 35(5) Rule 80(3)
• Every registered person • Every registered person* 

• whose turnover during a • whose aggregate turnover

financial year exceeds the during a financial year
prescribed limit exceeds two crore rupees

• shall get his accounts audited • shall get his accounts audited
by a chartered accountant or
as specified under sub-
a cost accountant and
section (5) of section 35 and

*Other than those referred to in the proviso to sub-section (5) of 22

 Legal Provisions
Section 35(5) Rule 80(3)

• shall submit a copy of the: • he shall furnish a copy of:

– audited annual accounts, – audited annual accounts and
– the reconciliation statement – a reconciliation statement,
under sub-section (2) of duly certified, in FORM
section 44 and GSTR-9C, electronically
– such other documents in through the common portal
such form and manner as either directly or through a
may be prescribed. Facilitation Centre notified
by the Commissioner.
23
 Section 44(2)
•Every registered person
•who is required to get his accounts audited in accordance with the
provisions of sub-section (5) of section 35
•shall furnish, electronically, the annual return under sub-section (1)
•along with a copy of the audited annual accounts
•and a reconciliation statement,
•reconciling the value of supplies declared in the return furnished for
the financial year with the audited annual financial statement,
•and such other particulars as may be prescribed.

24
 Meaning of Audit- Sec 2(13)
Audit’ means

• the examination of records, returns and other documents

• maintained or furnished by the registered person
• under this Act or the rules made thereunder or under any other law
for the time being in force

25
 Meaning of Audit- Sec 2(13)
• to verify the correctness of
• turnover declared,
• taxes paid,
• refund claimed and
• input tax credit availed

• and to assess
• his compliance with the provisions of this Act or the rules
made thereunder

26
 Practical approach to GST Audit?
Remarks
Obtain Appointment letter Appendix 2,Page No. 178 of TG

Issue Acceptance letter Appendix 2,Page No. 178 of TG

Obtain Management Representation (MR) Letter Appendix 4,Page No. 199 of TG

Copy of Registration Certificate REG 6

Copy of audited annual accounts If multiple GSTIN: Alongwith above, obtain

books of accounts for each GSTIN alongwith
consolidated statement

Copy of GSTR 9

27
 Practical approach to GST Audit?
Remarks
Invoice wise outward supply statement  Copy of GSTR 1 (alongwith working sheet)
 % wise outward supply details
 % wise outward supply, tax on which to be paid by
recipient under reverse charge

ITC Details Copy of GSTR 3B (alongwith working sheet)

Copy of GSTR 2A
Expenses head wise ITC details containing value,
ITC and eligible ITC

Copies of: Alongwith Monthly Summary sheet of discharge of

liability
E. Cash Ledger;
E-Credit Ledger and
E-Liability Ledger

Audit Checklist Appendix-10, Page No. 491 of TG

28
GSTR 9C- Form Level Overview

GSTR 9C

Part A- Part B-
Reconciliation
Statement Certificate
29
 Part A- Reconciliation Statement

Part I Part II Part III Part IV Part V

Basic Details Reco of Turnover Reco of Tax paid Reco of ITC Auditor’s recommendation
on additional liability due
to non-reconciliation

Sl. No. 1-4 Sl. No. 5-8 Sl. No. 9-11 Sl. No. 12-16

REG 6 Audited accounts, % wise O/s details 3B, 2A, working

GSTR 1, GSTR 3B, (also of RCM),E-cash, sheet, Exp head
GSTR 9 E-credit, E-Liability wise ITC details
Ledger, Monthly
Summary sheet of
discharge of liability 30
 Data Flow-GSTR-9 to 9C
Table No. Description Table No. of
of 9C GSTR 9

5Q Turnover as declared in Annual Return = 5N +10-11

(GSTR-9)
7F Taxable turnover as per liability declared in = 4N-4G+10-11
Annual Return (GSTR-9)
9Q Total amount paid as declared in Annual = 9+14
Return (GSTR 9)
12E ITC claimed in Annual Return (GSTR 9) = 7J
14S ITC claimed in Annual Return (GSTR 9) = 7J

31
32
33
 Part I-Basic Details
Sl. No.
Financial Year 1
GSTIN 2
Legal Name 3A
Trade Name (If any) 3B

Are you liable to audit under any Act (Please specify) 4

34
 Reconciliation of Gross Turnover
Turnover (incl. exports) Turnover as per
as per Audited accounts Annual Return-GSTR9
(5A) (5Q)
+ Report in
- Report
in

Unbilled Revenue Beginning of FY 5B End of FY 5H

Unadjusted End of FY 5C Beginning of FY 5I

advances
Credit Notes Accounted for in audited a/cs but 5J Issued after FY but 5E
not permissible under GST reflected in AR

Deemed Supply Under Schedule I 5D

Trade Discounts Accounted for in audited a/cs but 5F

not permissible under GST
35
 Reconciliation of Gross Turnover
Turnover (incl. Turnover as per
exports) as per Annual Return-GSTR9
Audited accounts [5A] [5Q]
+ Repor
t in
- Report
in

Q1 Turnover April’17 to June’17 5G

SEZ supply Adj. on a/c of supply of goods by 5K

SEZ units to DTA units

Composition Turnover Turnover for the period under 5L

composition scheme

Section 15 adjustments Adj. in turnover u/s 15 & 5M Adj. in turnover u/s 15 & rules 5M
rules thereunder thereunder
36
 Reconciliation of Gross Turnover
Turnover (incl. exports) Turnover as per
as per Audited accounts Annual Return-GSTR9
[5A] [5Q]
+ Repor
t in
- Report
in

Foreign Exchange Adj. in turnover due to FE 5N Adj. in turnover due to FE 5N

Fluctuation Fluctuation Fluctuation

Other Reasons Adj. in turnover due to other 5O Adj. in turnover due to other 5O
reasons reasons

37
 Un-reconciled Annual Gross Turnover (AT1)
Annual Turnover (5A)- after adjustments (from 5B to 5O) 5P

Turnover as declared in AR (GSTR 9)* 5Q

Un-reconciled Turnover (5Q-5P) 5R (AT1)

*This figure will come from 5N+10-11 of GSTR-9

Reason for Un-reconciled difference in Annual Gross

Turnover (Sl. 6)

38
 Reconciliation of Taxable Turnover
(Sl. No. 7)
Annual Turnover after adjustments (from 5P) 7A

Less :
Exempted, Nil-rated, Non-GST, No-Supply Turnover 7B

Zero-rated supplies without payment of tax 7C

Outward Supplies under reverse charge (tax payable by recipient) 7D

Taxable Turnover [7A-(7B to 7D)] 7E

Turnover in 7B, 7C and 7D are to be reported net of credit notes,

debit notes and amendments, if any
39
 Un-reconciled Taxable Turnover (AT2)
Taxable Turnover after adjustments 7E

Taxable Turnover as per liability declared in AR 7F

-Table (4N-4G)* + (10-11)** of GSTR 9

Un-reconciled Taxable Turnover (7F-7E) 7G (AT2)

*4N of GSTR 9: Supplies & Advances on which tax is to be paid

*4G of GSTR 9: Inward supplies on which tax is to be paid under reverse
charge
**10 of GSTR 9: Supplies/Tax declared through amendments (net of debit
notes)
**11 of GSTR 9: Supplies/Tax reduced through amendments (net of credit
notes)
Reason for Un-reconciled difference in Taxable Turnover 40
 Pt. III-
Reconciliation
of Tax Paid

41
 Reconciliation of rate wise liability and amount
payable thereon- Table 9
Tax Payable
Description Table T. Value CGST SGST/UT IGST Cess, if
GST Applicable
Liability under all rates 9A-9K
including RCM (e.g. 5%,
12% & so on)

Interest 9L
Late Fee 9M
Penalty 9N
Others 9O
Total amount to be paid 9P

42
 Un-reconciled payment of amount-Table 10
Tax Payable
Description Table T. Value CGST SGST/UT IGST Cess, if
GST Applicable
Total amount to be paid 9P

Total amount paid as 9Q

declared in AR
Un-reconciled amount 9R

Reasons for Un-reconciled payment of amount (Sl. 10)

43
 Issues
Sl. No. Issues Solutions
Form Amount payable as per T9 + Diff. tax Give reason for un-
9C-T9Q as per T14 of GSTR9 is auto populated reconciled amount in
here. However, auto population is of T10.
taxes only and not of Int, Late Fee &
penalty in T9 & Int in T14 resulting in
differences of 9Q with 9P. This results
in un-reconciled figure in T9R.
 Additional Amount Payable-Table 11
To be paid through cash
Description Taxable CGST SGST/UTG IGST Cess, if
Value ST Applicable
Liability under all rates
including RCM (e.g. 5%, 12%
& so on)
Interest
Late Fee
Penalty
Others

45
 Reconciliation of ITC- Pt. IV
ITC availed as per ITC claimed in Annual
Audited accounts (12A) Return-GSTR9 (12D)
+ Report in
- Report
in

ITC Booked in earlier FY, claimed in 12B Booked in current FY, to 12C
current FY be claimed in subsequent
FY

46
 Un-reconciled ITC (ITC 1)
ITC availed as per audited accounts 12D

ITC claimed in AR (GSTR 9)* 12E

Un-reconciled ITC (12E-12D) 12F (ITC 1)

*This figure will come from Table 7J of GSTR-9 which is

equal to total ITC availed (6O) minus total ITC reversed
(7I) upto 31.3.2018 in GSTR 3B.
Reason for Un-reconciled difference in ITC (Sl. 13)

47
 Reconciliation of ITC as per AR with ITC availed on expenses as
per audited accounts-Table 14

Description Table Value Amt of Total Amt of

ITC eligible ITC
availed

Purchases 14A
Freight/Carriage 14B
Imported goods (Inc. from SEZ) 14D

Goods lost, Stolen, destroyed, w/off 14F

or disposed of by way of gift/free
samples

Others 14C,14E,14G-14N
Capital Goods 14O
Any Other Expense 14P & 14Q
Total amount of eligible ITC availed 14R
48
 Un-reconciled ITC (ITC 2)
Total amount of eligible ITC availed 14R

ITC claimed in AR (GSTR 9) 14S

Un-reconciled ITC (14S-14R) 14T (ITC 2)

Reasons for Un-reconciled difference in ITC (Sl. 15)

49
 Tax Payable on un-reconciled difference in ITC-
Sl. No. 16
Amount Payable
Description
CGST
SGST/UTGST
IGST
Cess
Interest
Penalty

50
 Auditor’s recommendation on additional liability-
Pt. V
To be paid through cash
Description Taxable CGST SGST/UT IGST Cess, if
Value GST Applicable
Liability under all rates including RCM (e.g.
5%, 12% & so on)
ITC
Interest
Late Fee
Penalty
Any other amount paid for supplies not
included in AR
Erroneous refund to be paid back

Outstanding demands to be settled

Others (Pl. specify)

51
 Recapitulation
Sl. No. Issues
1 How to report common ITC Reversal cases under rule 42 & 43 and
interest liability thereon in GSTR-9 & 9C?

2 How to report RCM of 2017-18 paid in 2018-19?

3 How to report additional liability and interest thereon in GSTR-9 &

9C?
4 How to report Transitional Credit in GSTR-9C?
5 How to report ITC of 2017-18 in GSTR 9C which was availed and
reported in 2018-19?
GSTR 9C- Form Level Overview

Part B- Certification

BII: Reconciliation
BI: Reconciliation statement drawn by
statement drawn by the Auditor who has
the Auditor who has not conducted the
conducted the audit audit
53
 B1. Hierarchy of clauses for certification
(Statutory & GST auditor same person)
Step Particulars Remarks
1 Examination of financials [BS, PL, Notes, CFS (if applicable)

Multiple GSTIN: Trial balance of the Legal Entity split

“registration-wise

2 Based on our ‘audit’, report that books of

accounts, records, documents under the GST
law have or have not been maintained

3(a) Report observations/ comments /

discrepancies / inconsistencies

54
 B1. Hierarchy of clauses for certification
Step Particulars

3(b) Further report that:

A. Information and explanations has / has not been obtained which

were necessary for the purpose of audit

B. Proper books of accounts have / have not been kept

C. Financials are / are not in agreement with the books

55
 B1. Hierarchy of clauses for certification
Step Particulars
4 State whether GSTR 9C and other relevant
documents are annexed

5 Particulars in GSTR 9C are ‘true and correct’

subject to observations/
Qualifications
6 Signature, Stamp and Seal of the Auditor duly
disclosing the date, place and full address

56
 SA 200
[Overall Objectives of the Independent Auditor and the Conduct of an Audit in
Accordance with Standards on Auditing]

Para 11:
In conducting an audit of financial statements, the overall
objectives of the auditor are:

(a) To obtain reasonable assurance about whether the financial

statements as a whole are free from material misstatement,
whether due to fraud or error, thereby enabling the auditor to
express an opinion on whether the financial statements are
prepared, in all material respects, in accordance with an
applicable financial reporting framework; and
(b) To report on the financial statements, and communicate as
required by the SAs, in accordance with the auditor’s findings
57
Guidance Note on Reports or Certificates for Special
Purposes (Revised 2016)

Para 3: Sometimes, the applicable law and regulation or a

contractual arrangement that an entity might have entered into,
prescribe the wording of report or certificates.

The wording often requires the use of word or phrase like “certify”
or “true and correct” to indicate absolute level of assurance
expected to be provided by the practitioner on the subject matter.

Absolute assurance indicates that a practitioner has

performed procedures as considered appropriate to
reduce the engagement risk to zero.
58
Guidance Note on Reports or Certificates for Special
Purposes (Revised 2016)
Para 4: A practitioner is expected to provide either a:

•Reasonable assurance(about whether the subject matter of

examination is materially misstated); or

•Limited assurance (stating that nothing has come to the

practitioner’s attention that causes the practitioner to believe that the
subject matter is materially misstated).

A practitioner is not expected to reduce the engagement risk to zero.

This is because there are inherent limitations attached to the
procedures which a practitioner may perform in relation to issuance of
a report or certificate, as the case may be.
59
 Guidance Note on Reports or Certificates for
Special Purposes (Revised 2016)
Para 4 contd…

The inherent limitations arise from:

a) the nature of financial reporting;

b) the use of selective testing;
c) the inherent limitations of internal controls;
d) the fact that much of the evidence available to the practitioner is
persuasive rather than conclusive;
e) the nature of procedures to be performed in a specific situation;

60
 Guidance Note on Reports or Certificates for
Special Purposes (Revised 2016)

f) the use of professional judgment in gathering and evaluating

evidence and forming conclusions based on that evidence;
g) in some cases, the characteristics of the underlying subject matter
when evaluated or measured against the criteria; and
h) the need for the engagement to be conducted within a reasonable
period of time and at a reasonable cost.

61
 Guidance Note on Reports or
Certificates for Special Purposes
(Revised 2016)
Para 5: In view of the above, depending upon the nature, timing
and extent of procedures that can be performed based upon the
facts and circumstances of the case, a report or certificate issued
by a practitioner can provide either reasonable or limited level of
assurance. Therefore, whenever a practitioner is required to give a
“certificate” or a “report” for special purpose, the practitioner needs
to undertake a careful evaluation of the scope of the engagement.

62
 Guidance Note on Reports or
Certificates for Special Purposes
(Revised 2016)
Para 6: The word ‘certificate’ as described in the laws and regulations or
even in the contracts that an entity might have entered into can normally be
associated with reasonable assurance.
However, depending upon the circumstances and based upon the nature,
timing and extent of the procedures which a practitioner can perform, the
practitioner can conclude that a reasonable assurance cannot be expressed
on the subject matter of the “certificate” and only limited assurance
conclusion can be given.
The practitioner’s procedures in case where reasonable assurance is to be
expressed would be substantially different (and more extensive) from
circumstances where limited assurance is to be expressed. 63
 Some Suggestions
Don’t’ copy figures in 9 & 9C. This will result in error while uploading.
However, written text can be copied using F2
There should not be single paisa difference in five figures of GSTR 9
which are reported in 9C
File which is to be uploaded should not be saved in network server.
Keep it in local PC.
While GSTR 9C offline utility is downloaded and extracted, it contains
one file ‘wsweb’. Keep this file in the same folder in which excel file is
saved.
Do not override other client’s figures. Always use fresh form.
DSC must be plugged in before proceeding to generate Json file.
 Some Suggestions
Don’t put zero before membership No. in Part V and in B(i) or B(ii) in
GSTR 9C.
PAN No. of Auditor in Part V of GSTR 9C must be same as in DSC.
To get HSN code of 4 digit, type 3 digit. If you type 4 digits, it will
show 8 digits.
In B(i) or B(ii), Cash Flow Statement is a mandatory field. Where it is
not applicable, put date there and give observation in Para 5.
Para 5-Observation/Qualification: Even if there is no observation/
Qualification, enter at least Nil.
 Some Tech issues
Sl. No. Steps
1 Before signing 9C, close all other emsigners. Download emsigner
from GST portal and run as administrator.

2 Java Version 8 update 101 and above

3 Excel 2007 and above

4 If web socket for emsigner is not opening, then type

https:\\127.0.0.1:1585 in address bar. Then click ‘proceed to
safety’ and follow instructions.
67
 Steps for signing GSTR-9C using Offline
Utility V1.2:
Sl. No. Steps
1 Please ensure Internet Explorer 11 is installed.
2 Open the Offline Utility excel file and make sure all data is
correctly filled up.

3 Click on generate JSON file. This will open Internet Explorer.

4 Click on the Internet Explorer (e) icon in the taskbar.
5 Press F12 to open Developer Tools.
 Steps for signing GSTR-9C using Offline
Utility V1.2:
Sl. No. Steps
6 On the right side of Developer Tools, there should be a button
with "5" written on it. Click on it and change it to Edge.

7 Then click on the ‘x’ button on the right to close Developer Tools.
8 Continue signing as per instructions given in the web page.
Any Question
?
 CA D.S.Agarwala
Email: agards@gmail.com (M) 94330-97972
CA Vikash Kumar Banka
Email: Vikash_banka@hotmail.com (M) 98309-85000