GSTR 9 must be submitted by December 31 of the fiscal year. As a result, it will be December 2022 for FY 2021–22 and December 2022 for FY 2022–23. But, in response to taxpayer requests, as they did in FY 2019–20 and FY 2020–21, government agencies will extend some deadlines.
It’s a challenge to fill out the GSTR 9 form. Consequently, it should not be surprising that the GSTR 9 deadline has been extended numerous times due to various factors, including the forms and filing’s complexity. GSTR 9 filings have become more complicated in recent years for both enterprises and CAs. As they work to comprehend the sophisticated GSTR 9 form, their quarterly and monthly filed returns are being added to their books of accounts for the extension of GST audit 23.
Did You Know? Several extensions have been made to the GSTR 9 due date for the fiscal years 2017–18 and 2018–19.
When is the Deadline for Filing GSTR 9?
The filing deadline for GSTR 9 extension for FY 2022-23 was extended. Due to the challenges CAs and taxpayers have encountered in submitting GST returns for FY 2021–22, the deadline of March 31, 2022, has been extended a second time. 31st December 2023 is the new deadline for FY 2022-23.
Also Read: GSTR 9: Annual Return Filing, Format, Eligibility and Rules
Common Challenges Faced by the CAs in Filing GSTR9
Let’s examine the typical difficulties that CAs encounter when submitting GSTR 9 in more detail:
1. Mismatch in ITC between GSTR 2A and GSTR 9 Table 8A
Due to a discrepancy between the input tax credit that shows on the GSTR 2A that is automatically generated and the input tax credit that will appear on the GSTR 9, input tax credits have caused a lot of grief for taxpayers. As you can see, there are numerous explanations.
- Input tax credits for purchases made during FY 21-22, declared after April 30th, 2022, won’t automatically appear in GSTR 9.
- On all invoices with a place of supply in the supplier’s state rather than the recipient’s, GSTR 9 excludes input from tax credits.
- Invoices sent to beneficiaries during that GST annual return 2022-23 due date extension period in which they submitted an application form for a composition type of scheme do not have an input tax credit entry in the GSTR 9.
- After considering modifications, the final results have been provided in GSTR 9 extensions for FY 2022-23 compared to the net figures in GSTR 2A.
2. Details of Outward Supply in Part III, Columns 6C and 6D of GSTR-9
RCM must be disclosed in a one-line column of GSTR-3B format. There was no distinction regarding whether the reverse fee was paid under section 9(3) or 9(4). Likewise, whether or not the supplier was registered had no bearing on whether the reverse fee was paid under a compulsory system. Trade needs to prepare the necessary data. Hence, the new format should enable taxpayers to provide accurate information on RCM Paid and Input Tax Credit claims.
3. Data Not Separated in Annual Return
Data from numerous fields, including input tax credits, HSN codes, demands, and refunds, to name a few, must be divided for the annual GST return. When submitting monthly or quarterly GST returns, this degree of data was not necessary. Thus, finding and accurately reporting this information in the GSTR-9 return will require extensive digging into the books of accounts.
4. Bifurcation of Input Tax Credit Required in GSTR-9 and GSTR 9C
All input tax credits used for capital goods, inputs, and input services had to be divided into separate categories for GSTR-9. The form thus demands a thorough examination of a taxpayer’s accounting records and auditor verification. Since not all taxpayers maintain track of this split, it causes excessive stress to find the information to avoid subsequently misreporting it.
5. Turnover for Submitting Form GSTR-9C
All taxpayers with aggregate revenue over Rs 2 crore in a fiscal year must file Form GSTR-9C. The full calendar year must be considered to assess turnover from 1 April 2022 to 31 March 2023. For instance, taxpayers must file form GSTR-9C if they have a combined turnover of Rs. 2.1 crore from 1 April 2022 to 31 March 2023, and Rs. 1.9 crore from 1 July 2022 to 31 March 2023.
6. Having Trouble Filling out GSTR 9 Table 4F
The tax paid on a specific advance is stated without invoices generated in Table 4(F) of that GSTR 9. The source of information for the extension of GST audit 23 in this table should come from table 11(A) of the GSTR 1 return, as mentioned in the explanation for filling it out. This technique works well on a monthly level. Still, taxpayers must consider all the relevant adjustments made throughout the GSTR 9C extension for FY 2023 when making any annual decision. The information from the GSTR 1 return table 11(B) will also be included.
7. Data Auto-Populated
Data auto-populated in GSTR-9 in table 8A provides figures that cannot be reconciled because it is never specified in writing which figures are considered when uploading auto-populated data. In some circumstances, the auto-populated value considers the supplier’s invoice uploaded to the GSTR-1 reports between April 2018 and March 2019. It occasionally does not take the numbers into account. It is unclear whether or not the automatically generated figure in Table 8A of GSTR-9 takes into account changes to invoice-level data.
8. RCM Liability Disclosure in GSTR-9
It has been unclear how the CBIC clarified the declaration of responsibility under RCM. This was due for FY 20–21 but paid in FY 21–22. This is because the Central Tax notification, released on June 28, 2022, used the phrase “additional responsibility.” In contrast, the press release from June 4th used the words “increased external supply” with no reference to RCM. Taxpayers must declare the corresponding tax percentage of such liabilities under “Tax Payable” in table 9 while reporting the total unreported liabilities under table 4(G) of GSTR-9.
9. Authority to Modify Incoming & Outgoing Supply Parties
There isn’t a mechanism for return revision at the moment. The Return Amendment is the sole means of obtaining invoice information. So, it is essential to remember that this situation still exists even after the deadline for claiming these unclaimed credits was extended to March 2019.
However, the system delayed giving the drop-down option for 2022–23 for longer. It should be noted that as of now, B2C invoice rectification is not possible for July 2023. So, it is evident from the facts above that the system is not entirely keeping up with the updates and modifications made/announced by the government.
Also Read: Form GSTR 9A – Due dates, Format and Online Filing
Additional Issues When Filing GSTR-9
There are further problems that taxpayers have encountered when submitting their GSTR-9
- Only tables 5(M), 5(N), and 5 of the GSTR-9/9C offline program allow the copying of negative values (O). While negative values are transferable to other places and JSON is produced, GSTN does not handle them.
- The JSON file is not uploaded even if no error is present.
- In some instances, the GSTR-9 filed return had two final PDF copies. The problem has not yet been fixed on the GSTN portal.
- Although the DRC-03 set-off has been completed, taxpayers can still not submit the same.
Conclusion
To bring order to indirect taxes regulations, the Indian government implemented the Goods and Services Tax Act (GST) throughout the country on July 1st, 2023. The ordinary taxpayer must submit the annual GST return form GSTR 9. It offers comprehensive information on all inbound and outbound purchases, taxes, refunds, and ITCs received during a specific fiscal year. They encounter numerous difficulties when using the online system and adding up the books of accounts and records.
Owing to these problems, the government twice extended the due date for GSTR 9 for FY 2023. This was to relieve pressure and ensure accurate return submission.
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