Common Issues and solutions while filing GSTR-9 for F.Y. 2023-24
Notification No 12/2024-Central Tax dated 10th July 2024 read with Notification No.20/2024-Central Tax Dated 8th October 2024 contains provisions related to filing of GSTR-9 for F.Y. 2023-24.
Filing the annual return (GSTR-9) is a critical compliance requirement for businesses. It summarizes all the GST transactions during the financial year. However, several issues arise due to the complexity of reconciliations, errors in monthly returns, and lack of clarity regarding data to be reported. Below is an article highlighting common challenges taxpayers face while filing GSTR-9 for FY 2023-24, along with solutions.
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Mismatch between Turnover reported in GSTR-3B, GSTR-1 and books of accounts- It may be noted that irrespective of when the supply was declared in FORM GSTR-1, the principle of declaring a supply in Pt. II or Pt. V is essentially driven by when was tax paid through FORM GSTR-3B in respect of such supplies. If the tax on such supply was paid through FORM GSTR-3B between April 2023 to March 2024 then such supply shall be declared in Pt. II and if the tax was paid through FORM GSTR-3B between April 2024 to September 2024 then such supply shall be declared in Pt. V of FORM GSTR-9.
One common challenge reported by taxpayer is in Table 4 of FORM GSTR-9 where details may have been missed in FORM GSTR-1 but tax was already paid in FORM GSTR-3B and therefore taxpayers see a mismatch between auto-populated data and data in FORM GSTR-3B. It may be noted that auto-population is a functionality provided to taxpayers for facilitation purposes, taxpayers shall report the data as per their books of account or returns filed during the financial year.
Any additional outward supply which was not declared by the Registered person in FORM GSTR-1 and FORM GSTR-3B shall be declared in Pt.II of the FORM GSTR-9. Such additional liability shall be computed in Pt.IV and the gap between the “tax payable” and “Paid through cash” column of FORM GSTR-9 shall be paid through FORM DRC-03.
For FY 2023-24, 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 9A, Table 9B and Table 9C of FORM GSTR-1 of April, 2024 to October, 2024 filed upto 30th November, 2024 shall be declared in table 10&11 of GSTR-9
2. ITC mismatch between GSTR-3B V/s GSTR-2B- As per the Notification No 12/2024 Central Tax dated 10th July 2024 read with Notification No.20/2024-Central Tax Dated 8th October 2024, for FY 2023-24 onwards, the total credit available for inwards supplies shall be auto-populated in the table 8A of Form GSTR-9 from GSTR-2B of the FY 23-24. Further, in table 8C of Form GSTR-9 total value of ITC on inwards supplies received during the FY but availed in next FY up to specified period, need to be filled manually.
It is pertinent to mention that for FY 22-23 in table 8A of Form GSTR-9, values were getting auto populated from GSTR-2A however for FY 23-24 same are being auto populated from GSTR-2B. Therefore, to some extent, in Form GSTR-9 of FY 23-24, values in Table 8A will be inflated in respect of FY 22-23 at the same time values will be lower than expected in respect of FY 23-24, hence there will be a mismatch between the two tables i.e. 8A and 8C few of which are as follows-
Issue |
Reporting in GSTR-9 of F.Y. 2023-24 |
Invoice of FY 23-24 but the supplier has not reported upto March 2024.
As a result, this amount is not auto populated in the Table 8A of GSTR-9 for FY 2023-24 because it is the part of next years GSTR-2B. |
Taxpayer shall report such ITC in the Table 8C and in Table 13 as this is the ITC of FY 2023-24. This is in line with the instructions to the Table 8C and Table 13 of GSTR-9. |
Invoice of FY 23-24 and ITC has been claimed in FY 23-24.
But, due to payment not made to supplier within 180 days, ITC was reversed in 23-24
And this ITC is reclaimed in next Year FY 2024-25, after making the payment to supplier. |
This reclaimed ITC shall be reported in the table 6H of GSTR-9 for FY 24-25 hence not in the Table 8C and Table 13 of GSTR-9 of FY 2023-24. |
Invoice of FY 2023-24 but goods not received in 23-24 therefore ITC is claimed in Table 4A5 of GSTR-3B and reversed in Table 4B2 as per the guidelines of Circular 170
And such ITC reclaimed in next FY 2024-25 till the specified time period. |
Taxpayer shall report such reclaimed ITC in the Table 8C and Table 13 as this is the ITC of FY 2023-24. |
Invoice of FY 22-23 which is appearing in the Table 8A of GSTR-9 of FY 23-24 , as the supplier would have reported the same in GSTR-1 after the due date of filing of GSTR-1 for the tax period of March 23. |
This is the ITC of last year (2022-23) and was auto populated in table 8A of GSTR-9 of FY 22-23. Hence, aforesaid value need not to be reported in the table 8C and Table 13 of GSTR-9 for FY 23-24. |
ITC for an Invoice which belongs to FY 2023-24, and which is claimed, reversed and reclaimed in the same year |
As already clarified by the CBIC press release 3rd July 2019 in the para k, It may be noted that the label in Table 6H clearly states that information declared in Table 6H is exclusive of Table 6B. Therefore, information of such input tax credit is to be declared in one of the rows only.
Further, as the claim and reclaim is reported only in one row therefore the same should not be reported in the reversal under table 7 of GSTR-9 of FY 23-24. |
Aggregate value of reversal of ITC which was availed in F.Y. 2023-24 but reversed in returns filed for the months of April, 2024 to October, 2024 filed upto 30th November, 2024 |
This shall be declared in Table 12 of GSTR-9. Table 4(B) of FORM GSTR-3B may be used for filling up these details.” |
Any ITC which was reversed in the FY 2023-24 as per second proviso to sub-section (2) of section 16 but was reclaimed in FY 2024-25,
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The details of such ITC reclaimed shall be furnished in the annual return for FY 2024-25 |
3.Payment of any unpaid tax: Section 73 of the CGST Act provides a unique opportunity of self – correction to all taxpayers i.e. if a taxpayer has not paid, short paid or has erroneously obtained/been granted refund or has wrongly availed or utilized input tax credit then before the service of a notice by any tax authority, the taxpayer may pay the amount of tax with interest. In such cases, no penalty shall be leviable on such tax payer. Therefore, in cases where some information has not been furnished in the statement of outward supplies in FORM GSTR-1 or in the regular returns in FORM GSTR-3B, such taxpayers may pay the tax with interest through FORM GST DRC-03 at any time.
4. Reverse charge in respect of Financial Year 2023-24 paid during Financial Year 2024-25- It may be noted that since the payment was made during FY 2024-25, the Input tax credit on such payment of tax would have been availed in FY 2024-25 only. Therefore, such details will not be declared in the annual return for the FY 2023-24 and will be declared in the annual return for FY 2024-25.
5. New inserted Tables in GSTR-9 from F.Y. 2023-24- Following Tables 4G1 and 5C1 is inserted in GSTR-9.
4G1 |
Aggregate values of all the supplies (net of amendments) on which tax is to be paid by the ecommerce operators under section 9(5) is to be reported by e-commerce operator. Table 15 and 15A of FORM GSTR-1 may be referred for filling up these details
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5C1 |
Aggregate values of supplies (net of amendments) made by suppliers through e-commerce operators on which e-commerce operators are liable to pay taxes under section 9(5) is required to be reported here by supplier. Table 14(b) and 14A(b) of FORM GSTR-1 may be referred for filling up these details.
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In last we suggest all taxpayer to begin the GSTR-9 preparation process well in advance to avoid last-minute mistakes. |