GST Annual Return: What you need to know about
GST returns becomes of two types of return - periodic and annual returns. Periodic returns include both monthly or quarterly returns for showing the transactions which took place during the month or quarter, while annual return is for disclosing the summary of the periodic returns filed during a financial year. As the annual return is last return of the year thus, it assumes special message.
Who is required to file an annual return?
All taxpayers are required to file the returns who have obtained registration as:
- Taxable Persons' or 'Non-resident taxable persons'
- 'Input service distributors' to distribute the input tax credit of services that are invoiced in one Place however, are to be used in different States (for example - distribution of input tax credit related to advertisement services invoiced in one State, however, is used in other States)
What are the forms for the Annual return?
As per the GST Rules, various forms have been recommended for the purpose of return, depending upon the categories of the tax payers, which are as follows:
Category of taxpayer
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Return (GSTR) Form
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Composition scheme registered
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9A
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E-com operator deducting tax
|
9B
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Other where turnover (for all state put together) exceeds INR 2 crore
|
9C
|
Other where turnover less than INR 2 Crore
|
9
|
What is the deadline for filing the return?
Annual return for the financial year 2018-19 is required to be filed on before March 31st, 2020. For instance for the financial year 2018-19 (transactions undertaken from April 18 to March 19), the last date for filing is March 31st, 2020. Due date for the financial year 2017-18 was 31st January 2020.
What is the consequence of non-filing the return?
Failure to file an annual return shall suffer a late fee of INR 200 per day during the period of failure, subject to a maximum of 0.25% of the said Financial Year's turnover.
What are immediate deadlines in the run up to the return?
The target date for filing the annual return is a few months away, even taking into account the chances of extension of the target date for filing; there are some important compliances that need to be planned. Input tax credit related to invoices issued by the suppliers from 1 April 2018 to 31 March 2019 needs to be accounted for by 20 October 2019 in the GSTR 3B. As per the GST law, after 20 October 2019 credits pertaining to the said financial year cannot be taken.
This would also mean that satisfaction action should be undertaken, well before finally getting credits, to ensure that the supplier has also correctly uploaded the details and it appears in GSTR 2A.
Further, credit notes made for sales return during the last financial year should be accounted by 30 September 2018.
Before filing the annual return, for taxpayers with turnover of Rs 2 crore, GST audit would also need to be completed. Copy of audited annual accounts along with audit report and reconciliation statement of tax already paid and tax payable as per audited accounts needs to be submitted.
Due Date Extended for Annual Return FY 2018-19
GSTR 9 & GSTR 9C form due date is announced by the government i.e. 31st March 2020 for the FY 2018-19. Therefore it is mandatory to file the GSTR 9 annual return form and GSTR 9C audit reconciliation form as soon as possible to avoid any penalties.
It is also expected that the government will not extend the given due date for the FY 2018-19 now as it had already asked the taxpayers to file the same months earlier. The extension along with the due date of GSTR 9 & 9C, the government also said that these forms will now be easy to file as there are number of columns and files which have now been made as optional by the department.
As per the Central Board of Indirect Taxes & Customs (CBIC) notification, the amendments concerning the explanations of both the annual forms i.e. allowing GSTR 9 and GSTR 9C for taxpayers to not provide the input tax credit availed on inputs, input services and capital goods details. Also, there is now no need to give the HSN level details of outputs or inputs for the FY 2018-19.
The due dates extension for the form GSTR 9 & 9C have given another chance to the taxpayers to file their annual returns on time with clarity and correctness which is also observed by the government. GSTR-9 and GSTR-9C is required to file by the taxpayers for Financial Year 2018-19, by 31st March 2020 anyhow.
The deadline for annual GSTR 9 return has been extended owing to the continuous demands of various trade bodies. The non-availability of filing option with format is also a major problem faced by the taxpayers. GST annual return plays a key role in reviewing and rectifying their mistakes in any of the returns filed in that particular year as it gives a once-in-a-year opportunity to taxpayers. Therefore, businesses want to be given sufficient time and resources to analyze, understand and fill the form.
Extra petition was filed to the Finance Ministry, all of which put the focus on the difficulty of the GST returns filing process. According to a petition, correcting the returns is more time taken than filing them. Additionally, HSN code for inward supplies is also required while filing annual returns, which was not a mandate for GSTR-3B returns. This further adds to the inconvenience of the taxpayers.
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