Update 26th August 2019: The finance ministry extended the last date for GSTR 9 Filing by three months to November 30 from 31st August 2019. _______________________________________________________________________
GSTR 9 Annual Return preparation is round the corner. With due date extended twice from 31st December 2018 to 30th June 2019 and from 30th June 2019 to 31st August 2019, it is expected that this time there won’t be any extensions.
The annual return is divided into 6 parts, Part I covers basic details while Part II is for outward supplies. Part III is important section covering ITC related reports in Table 6, Table 7 and Table 8.
Part IV is the actual tax paid during the financial year. This article covers the guidelines to fill Table IV of GSTR 9.
Payment of tax under Table 6.1 of FORM GSTR-3B may be used for filling up the details in Part IV of the Annual Return.
After capturing details relating to outward supplies in Part II and details of Input tax Credit availed and reversed in Part III of GSTR 9, Part IV requires the person filing an Annual Return to report the details of tax, interest, late fee, penalty and other amounts payable and paid thereon on a cumulative basis for the financial year.
The purpose of point number 9 in Part IV is to get the consolidated value of tax liability self assessed including tax payable on additional liability which has not been reported yet and tax paid, discharged in the monthly returns i.e Form 3B by the Registered Person for the period for which the Annual Return is being filed. The given details along with differential tax details declared in Sl. No. 14 in Part V of the Form shall assume the total tax liability for the financial year which is calculated, declared and discharged by the Registered Person up to the date of filing the Annual Return and balance has to be paid in cash through DRC-03.
A. For tax Payable and Tax Paid
Information required in this clause is of ‘tax payable’ and ‘tax paid’ (by cash or credit). Table 6.1 of GSTR 3B is meant for collecting information and including it here. The Table also contains ‘tax payable’ and ‘tax paid’. As regards ‘tax payable’, the same must be in alignment with taxable turnover in Sl.No. 4M of GSTR 9 and corresponding ‘tax payable’.
Accordingly, where taxable turnover reported in GSTR 1 and GSTR 3B are in matched with each other, there would be no ‘new’ tax liability identified for the first time in GSTR 9. However, where they are not in matched taxable turnover reported in GSTR 1 and that on which tax is actually discharged through GSTR 3B may not be in agreement. It is for this reason that Sl.No.9 captures ‘tax payable’ based on GSTR 9 (4N) but ‘tax paid’ based on GSTR 3B (6.1)
Hence, column “Tax Payable” would be derived based on 4N but column “Paid through cash” would flow from 6.1 of GSTR3B.
B. For Interest Payable and Paid
For reporting the amount of interest under the given column, interest actually admitted and paid must be reported here.
The details of interest actually paid under Section 50 can be captured from Table 5.1 of GSTR 3B filed for the financial year, if paid. Further, the details of interest paid, to be reported in Part IV of GSTR 9 can also be cross verified with Credit and Debit relating to interest in Electronic tax Liability Register. I
Interest liability re-calculated for compliance of provision of section 16 of the CGST Act, which provides for reversal of ITC if creditors for inward supply have not been paid in 180 days. Therefore, sundry creditors outstanding as on 31.03.2018 must be reconciled that no outstanding amount is lying for inward supplies made by them in between 1.07.2017 to 2.10.2017.
C. For Late Fees Payable and Paid
For reporting Late Fees duly paid during the period July 2017 to March 2018 for late filing of any of the GST Returns on which Late Fees was levied and paid by the Registered Person,.
Table6.1 of GSTR 3B shall be used. Further, the details of Late Fee to be reported in Part IV of GSTR 9 can also be cross verified with Credit and Debit relating to late fee in Electronic tax Liability Register.
D) For Penalty and Other Dues Payable and Paid
In GSTR 3B, there is no Table specified for payment of any Penalty or Other Dues. However, under the law there can be instances where a person filing an Annual Return might have paid penalty due to various instances such as like for causing movement of goods in violation of provisions of Rule 138 or due to any order passed by proper officer etc.
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