Menu Close

Guide on GSTR-9A (Annual Return Composition Dealer)

Guide on GSTR-9A will help you to understand the various provisions of GSTR-9A. This guide is prepared serial number wise which will help you to understand how to file correct information in every table of GSTR-9A.

Form GSTR-9A is the relevant form prescribed in terms of Rule 80 of the CGST Rules, 2017. This Form GSTR-9A in Part I seeks to capture the basic details of the registered person which has 5 clauses. Each of the clauses in Part I is significant in terms of the disclosure requirement.

Analysis

Part – I

Sr. No. 1 – Financial Year

This clause requires disclosure of the “financial year” to which the Annual Return relates to. Normally the financial year relates to 1st day of April to 31st day of March. However, for the financial year 2017-18, since the GST Laws stood applicable only for nine months commencing from July 2017 to March 2018, in this clause one may mention “2017-18” (9 months commencing 1st July 2017 and ending on 31st March 2018).

Sr. No. 2 –  GSTIN

GSTIN means the “Goods and Services Tax Payer Identification Number” of the tax payer or the registered person.

Sr. No. 3A and 3B – Legal Name and Trade Name

1. The word “legal” used in clause 3A in Form GSTR 9 in Part I is used in the backdrop of a legislation. Therefore, it must be lawful. While a “name” is a word(s) by whom a person is known, the expression “legal name” is with reference to a Statute. 2. For instance, a person can be named “Sandy”, but his legal name could be “Santosh”. This is what is to be borne in mind while this column in being filled in. Another instance could be “HUL” which legally is Hindustan Unilever Limited. 3. The word “Trade” used in clause 3B of Part I may not be limited to the occupation or business. It could be a connotation. The word “Trade” ought to be understood in its ordinary sense without any reference to “business”. For instance, “Indigo” could be a trade name while its legal name is “InterGlobe Aviation Limited”. Likewise, “Chancery Pavilion” is a trade name and “Elixir Enterprises & Hotels Private Limited” is legal name. 4. Therefore, trade name is a name used by trade and industry to identify their businesses symbolizing their reputation. Caution must be exercised in listing out the trade name and legal name in clauses 3A and 3B.

Conclusion – Therefore, the 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.

Sr. No. 4 – Period of composition scheme during the year (From —- To —-)

The clause “Period of composition scheme during the year (From —- To —-)” seeks to capture the start and end period of the composition scheme. A registered person could be registered as a Regular Registrant on migration and later opted to migrate to composition scheme. Therefore, the start period shall be the period at which the composition scheme commenced.

The option to pay tax under the Composition Scheme shall be effective:

1. For persons already registered under pre-GST regime: Appointed Day 2. Registered under GST and person switches to Composition Scheme: Date of filing of the Intimation.

Sr. No. 5 – Aggregate Turnover of Previous Financial Year

1. Aggregate turnover for the previous financial year is the turnover of the financial year previous to the year for which the return is being filed. 2. For example, for the annual return for FY 2017-18, the aggregate turnover of FY 2016-17 shall be entered into this table. 3. It is the sum total of turnover of all GSTINs of the said person on the same PAN.

Part – II

Details of outward and inward supplies declared in returns filed during the financial year

Sr. No. 6 – Details of Outward supplies on which tax is payable as declared in returns filed during the financial year

1. 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 details pertaining 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; 2. However, data in this table should include all the amendments made during the period July 2017 to March 2018.

Sr. No. 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.

Table 7 of GSTR 9A contains the details of inward supplies in respect of which the Registered Person is liable to pay tax on reverse charge basis.

Sr. No. 7A – Inward supplies liable to reverse charge received from registered persons

The relevant instructions given to this Form reads “Aggregate value of all inward supplies received from registered persons on which tax is payable on reverse charge basis shall be declared here ”. But it is relevant to note and understand that this table deals with the provisions 9(3) of CGST Act, 2017. One may utilise the details provided in the following Tables to Form GSTR 4 as follows:

1. Table 4B: Inward supplies received from a registered supplier (attracting reverse charge); 2. Table 5: Amendments 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. 3. Table 8 A: Advance amount paid for reverse charge supplies in the tax period (tax amount to be added to output tax liability). The table 8 to Form GSTR 4 reads:

Validation

The turnovers that are to be reported can be directly derived from the tables of Form GSTR 4 of the tables mentioned above.

It is suggested that the following reconciliations be carried out for reporting of correct values:

(a) Reverse Charge paid / payable on inward supplies from a registered taxable person liable to tax; (b) Payment vouchers (required to be issued when making payments to a supplier if the supplies fall under reverse charge).

Sr. No. 7B – Inward supplies liable to reverse charge received from unregistered persons

The relevant instructions issued to Form GSTR 9A in this regard states “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 here. Table 4C, Table 5 and Table 8A of GSTR-4 may be used for filling up these details”. One may utilise the details provided to in the following Tables to Form GSTR 4 as follows:

1. Table 4C: Inward supplies received from an unregistered supplier

Attention is invited to the relevant notifications issued – viz. (i) NN 8/2017-CT(R) dated June 28, 2017 which exempts intra-State supply of goods or supply of services does not exceed Rs.5,000/- per day regardless of number of suppliers involved. (ii) NN 38/2017-CT(R) dated Oct 13, 2017 which excluded the value limit previously prescribed. (iii) Corresponding exemption from payment of Integrated Tax was issued for the first time in NN 32/2017-Int(R) dated Oct 13, 2017 in respect of inter-State supplies.

2. Table 5: Amendments 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.

3. Table 8 A: Advance amount paid for reverse charge supplies in the tax period (tax amount to be added to output tax liability)

Advances reported in Table 7A to Form GSTR 9A shall not be considered once again in reporting the turnovers relating to this table. Any other advance payment to unregistered suppliers for which tax is payable on reverse charge mechanism should be reported here.

Sr. No. 7C – Import of services

Instructions issued to the relevant Form GSTR 9A which reads “Aggregate value of all services imported during the financial year shall be declared here. Table 4D and Table 5 of GSTR4” may be used for filling up these details.

Sr. No. 8 – Details of other inward supplies as declared in returns filed during the financial year

8A Inward supplies from registered persons (other than 7A above)

The relevant instruction to Form GSTR 9A reads “Aggregate value of all inward supplies received from registered persons on which tax is payable by the supplier of goods and / or services shall be declared here”. Due consideration has to be paid to Table 4A and 5 of GSTR-4 – Inward supplies received from a registered supplier (other than supplies attracting reverse charge).

Table 5 of GSTR-4: Amendments made to the above section shall also be considered finalising 8A.

8B Import of Goods

Aggregate value of all goods imported during the financial year shall be declared here.

Source of information

In this table, the taxable person should report the aggregate value of input tax credit availed on all imports (for all inputs and capital goods) from outside India or from SEZ units. Such data can be sourced from relevant inward supply registers duly matched with the financials, the bill of entry or other similar document prescribed under the Customs Act, Customs Tariff Act or rules made thereunder for the assessment of Integrated tax on imports.

Part – III

Sr. No. 9 Details of tax paid as declared in the returns filed during the financial year

Part – IV

Sr. No. 10, 11, 12 and 13

Particulars of the transactions for the previous FY declared in returns of April to September of current FY or up to the 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 here.

It must be borne in mind that in terms of the proviso to Section 39(9) the due date for furnishing of return for the month of September (i.e. GSTR-4) following the end of the financial year, or the actual date of furnishing of relevant annual return, whichever is earlier.

Sr. No. 14

Differential tax paid on account of declaration made in 10, 11, 12 & 13 above

Part – V

Sr. No.  15

Other Information Particulars of Demands and Refunds

Sr. No. 15A, 15B, 15C and 15D

Aggregate value of refunds claimed, sanctioned, rejected and pending for processing shall be declared here. Refund claimed would be the aggregate value of all the refund claims filed in the financial year and would 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 would be the aggregate amount in all refund application for which acknowledgement has been received and would exclude provisional refunds received. These would not include details of non-GST refund claims.

S.No.  15E, 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.

Sr. No. 16

Details of Credit reversed or availed.

Sr. No. 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.

In terms of Section 18(4) of the CGST Act, 2017 where any registered person who has availed of input tax credit:

  • opts to pay tax under section 10 i.e. Composition,
  • he shall pay an amount, by way of debit in the
    • electronic credit ledger or
    • electronic cash ledger,
  • equivalent to the credit of input tax in respect of
    • inputs held in stock and
    • inputs contained in semi-finished or
    • finished goods held in stock and
    • on capital goods, reduced by such percentage points as may be prescribed,
  • on the day immediately preceding the date of exercising of such option
  • Note: After payment of such amount, the balance of input tax credit, if any, lying in his electronic credit ledger shall lapse.

Calculation of input to be paid as per Rule 44 is as follows:

  • For inputs held in stock and inputs contained in semi-finished or finished goods.
    • Calculated on proportionately on basis of corresponding invoices on which credit has been availed by the registered taxable person on such input.
  • For Capital goods held in stock
    • Total input availed on capital stock should be reduced by the number of months used taking a five year as useful life for a capital goods.

Sr. No.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.

CGST Section 18(1) (c): where any registered person ceases to pay tax under section 10 i.e. Composition Scheme, he shall be entitled to take credit of

  • input tax in respect of
    • inputs held in stock,
    • inputs contained in semi-finished or
    • inputs contained finished goods held in stock and
    • inputs contained on capital goods
  • on the day immediately preceding the date from which he becomes liable to pay tax under section 9:

Provided that the credit on capital goods shall be reduced by such percentage points as may be prescribed;

1. Registered person should File for both Capital Goods and Inputs the –

✓ Electronic declaration the in-Form GST ITC-01;

✓ On common portal within 30 days from becoming eligible to avail credit

✓ Specify the details of inputs held in stock and inputs contained in semi-finished or finished goods held in stock and on capital goods held immediately the previous day when he became liable to pay tax under section 9.

2. The declaration shall be certified by a practicing CA or Cost Accountant if aggregate claim of CGST, SGST, IGST credit exceeds Rs. 2 lacs.

3. The credit ITC claimed under this clause shall be verified with the corresponding detail furnished by the supplier in Form GSTR-1.

4. As per rule 40 of CGST Rules, 2017 input tax credit on capital goods shall be claimed after reducing 5% of the tax portion per quarter or part thereof from the date of invoice or other documents till the date when he became liable to pay tax under section 9.

Values for this table 16B shall be fetched from Table 8 of ITC-01

Sr. No. 17

Late fee payable and paid

Late fee would be payable if annual return is filed after the due date.

Leave a Reply

Your email address will not be published. Required fields are marked *

CommentLuv badge