It has been 2 years since the GST Regime in force, we have seen the lot of changes not only in the act but also with respect to compliance. It was proposed in the Act that GSTR-2 and GSTR-3 should be filed monthly, but both of them were suspended and GSTR-3B was announced instead of GSTR-3B, now new system of filing of return announced again. Coming to the Annual Compliances, we have to delve into the depths of various Annual Returns to be filed under GST

Different types of Annual Returns under GST:

• GSTR9
• GSTR9A
• GSTR9B
• GSTR9C

Let us see about GSTR9

Persons exempted from Filing the Annual Return GSTR9:

• Persons who collect TDS under Section 51 of CGST Act
• Non-Resident taxable person (non-resident person who supply goods or services or both in the territory of India)
• Casual Taxable Person (Person who has no permanent establishment of business in the place where he would like to conduct business)
• Input Service Distributors (Person who distributes the Input Tax Credit to the branches/divisions of his business)
• Person who opted Composition Scheme.

Analysis: It means all the taxpayers other than the ones who are specified above are required to file GSTR9, as per the due date.

Due date for filing GSTR9:

GSTR9 is supposed to be filed on the earliest of the following dates:

• 20th October of the following Financial Year or
• 31st December of the following Financial Year

Due to the difficulties faced by the business entities, the Due date for filing the GSTR-9 for FY 2017-18 has been extended to 31st August 2019.

How-ever the due-date for the FY 2018-19 is as usual unless the Government has extended as done for FY 2017-18.

Analysis: : Even though the earliest of the Dates was mentioned as Due Date for filing the returns, but the wording of the Act is stating that the tax-payer has to file the Annual Return by 20th October of the following Financial Year.

Annual Return once filed cannot be revised, therefore the return must be filed without any errors.

Pre-requisites for Filing Annual Return(GSTR-9):

Data of GSTR-1 and GSTR-3B for all the months is required for filing the return.

Analysis: : Information of GSTR-1 and GSTR-3B is required to file the Annual Return, filing both the monthly returns is mandatory before filing the Annual Return because we cannot revise the Annual Return filed once.

Let us see about GSTR9A

Eligibility to file Annual Return (GSTR9A):

Tax-payer who opted for Composition Scheme are eligible to file this return

Due Date for filing the Annual Return:

GSTR9A is supposed to be filed on the earliest of the following dates:

• 20th October of the following Financial Year or
• 31st December of the following Financial Year

Due to the difficulties faced by the business entities, the Due date for filing the GSTR-9A for FY 2017-18 has been extended to 31st August 2019.

How-ever the due-date for the FY 2018-19 is as usual unless the Government has extended as done for FY 2017-18.

Let us know about GSTR9B

Eligibility to file this return:

E-Commerce Operators who have filed GSTR8 during the Financial Year.

Let us know about GSTR9C

What is GSTR9C?

GSTR9C is basically a reconciliation statement between the

• GSTR9 filed for the FY and
• Figures as per the Audited Annual Financial Statements of the tax payer.

Eligibility to file GSTR9C:

Every taxpayer whose turnover exceeds 2 crore rupees at any time in the Financial Year shall get the books of accounts audited by the Chartered Accountant(CA) or Cost Accountant(CWA/CMA). These taxpayers have to file GSTR9C which shall be certified by the Chartered Accountant(CA) or Cost Accountant(CWA/CMA).

Due Date for filing this return:

Due date for filing GSTR9C is same as that of GSTR9.

How-ever the due-date for the FY 2018-19 is as usual unless the Government has extended as done for FY 2017-18.

Annexure to be attached:

Audited Annual Financial Statement should be annexed while filing the certified statement in the portal.