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GSTR-9C

“Clarification about GSTR-9C and It’s Fillings”

1) What is GSTR-9C , why It is Been Applied in GST ?

GSTR-9C is Audit  Reconciliation Certificate in which CA or CWA Declares and Certifies the Turnover Mentioned in GSTR-9 and all monthly GST Returns , Since Govt. of India Merged all type of Indirect taxes into one frame and named it as GST because of  Merging of Service Tax , Excise Tax , VAT The Liability and Credibility of the Accounts has Increased , Now a dealer engaged into Basic Trade can provide Service and Can Manufacture the goods under solidarity GSTN No. the Landscape area of the Tax Regime has increased so your Closing Stock and Sales Turnover , Purchase Accounts and if there are some in discrepancy is there needs to be notified and Corrected so that Future Demand Notices can be eliminated.

2) Who is Entitled to Prepare/ Certify GSTR-9C/GST Audit ?

You See GSTR-9C or GST Audit Must be Audited/Certified by Member of ICAI or ICWAI , A Charted Accountant or Cost Accountant.

3) Is There Any Turnover Applicability of GST Audit Turnover ?

If A Proprietorship/Partnership/Company/GST Taxpayer Annual Turnover Breaches the Limit of 2 Crore than they are entitled to have GST Audit .

4) What would be the period of Audit under GST for 17-18 Assesment Year ?

You See Generally Audit Period is Considerd from 01-Apr-17 to 31-Mar-18 , but GST Law came into force from 01-July-17 but so the Audit Period for 17-18 Assesment year will be 01Jul-17 to 31-03-18 .

5)  What  GSTR-9C will Contain ?

In Part A : Reconciliation Statement  ,   In Part B : Certification .

In Part A : Reconciliation Statement’s  Contents as Follows :-

Part 1 : Will Contain  Basic Detail about The Assessee  For Example  Financial Year , GSTN No. , Firm Name , Legal Name .

Part 2 :  Reconciliation of Audited Turnover Filed in Income Tax Audit and GSTR-9  , Unbilled Turnover ( Not mentioned in GSTR-9) , Unadjusted Advances , Deemed Supply  Under  Schedule 1 , Credit Notes  at the end of Financial Year , Trade Discounts  Given  , Turnover Fluctuation due to forex Fluctuation , Any other Turnover non Accounted .

Part 2 will also include reason for Turnover not Informed during filing of GSTR-9C . thereafter all the accounting to Reconcile your accounted/filed Turnover (+) Non Accounted/ Not Filed Turnover and Final Turnover Will Stand with The new Liability if Applicable .

Part 3 : Reconciliation  Rate wise liability paid / will Be Payable . As well as Reason for not making payment of Liability arising and Turnover Increasing due to Reconciliation of the Turnover. Additional Amount Payable Rate wise including Interest and Penalty.

Part 4 : Reconciliation of ITC Net  : It will include ITC Acquired Through Returns , ITC Allowed Through GSTR-2A , if there is any difference than Bills are ready for the Forensic Checking which are not filed by the counter party  and Also Any ITC is been recognized after filling of 30-09-18 Amendments of Returns as well as GSTR-9 which is not been taken into the GST Books, With Reason why ITC Still Needs to be Accounted in the GST , and if Excess taken With Reason why it is been taken and not reversed in GSTR-3B till 30-09-18 and GSTR-9 which had option of Correction . RCM and Freight Bills needs to Checked strictly as well as RCM U/S 9(3) of CGST act and 9(4) of CGST act .

Part 5: Auditor’s Recommendation on Additional liability arising through checking and finding Gaps and Indiscrepancies in Any Part given Above. Auditor will also give recommendation of Refund , Relaxation on Account of Human error of oversightness  , Wilful Offence by Assessee with reason of fraud , Auditor’s Responsibilty to check the Statutory Reports and give Conclusion will Have deep Impact on the Assesment of Returns under the GST Law.

PART – B- CERTIFICATION

I. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by the person who had conducted the audit:

* I/we have examined the –

(a) balance sheet as on ………

(b) the *profit and loss account/income and expenditure account for the period beginning from ………… ending on …… and

(c) the cash flow statement for the period beginning from ……………. to ending on ………………… , ——-
attached herewith, of M/s ……………….. (Name), …………………………..(Address),…………….. (GSTIN).

2. Based on our audit I/we report that the said registered person-

*has maintained the books of accounts, records and documents as required by the IGST/CGST/GST Act, 2017 and the rules/notifications made/issued thereunder

*has not maintained the following accounts/records/documents as required by the IGST/CGST/GST Act, 2017 and the rules/notifications made/issued thereunder:

1.
2.
3.

3.

(a) I/we report the following observations/ comments / discrepancies / inconsistencies; if any:
…………………………………………….

3. (b) I/we further report that, –

(A) * I/we have obtained all the information and explanations which, to the best of my/our knowledge and belief, were necessary for the purpose of the audit/ information and explanations which, to the best of *my/our knowledge and belief, were necessary for the purpose of the audit were not provided/partially provided to us.

(B) In * my/our opinion, proper books of account *have/have not been kept by the registered person so far as appears frommy/ our examination of the books.

(C) I/we certify that the balance sheet, the *profit and loss/income and expenditure account and the cash flow Statement are in agreement/not *in agreement with the books of account maintained at the Principal place of business at ……………………………. and **……………………………. additional place of business within the State.

4. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be furnished under section 44(2) of the CGST Act is annexed herewith in Form No. GSTR-9C.

5. In *my/our opinion and to the best of *my/our information and according to explanations given to me/us, the particulars given in the said Form No.GSTR-9C are true and correct subject to following observations/qualifications, if any:

(a) …………………………….
(b) …………………………….
(c) …………………………….

**(Signature and stamp/Seal of the Auditor)

Place:…………………………….
Name of the signatory …………………………….
Membership No …………………………….
Date: …………………………….
Full address …………………………….

II. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the person who had conducted the audit of the accounts:

*I/we report that the audit of the books of accounts and the financial statements of M/s. ……………………………. (Name and address of the assessee with GSTIN) was conducted by M/s ……………………………. (full name and address of auditor along with status), bearing membership number in pursuance of the provisions of the ……………………………. Act, and *I/we annex hereto a copy of their audit report dated ……………………………. along with a copy of each of :-

(a) balance sheet as on …………………………….

(b) the * profit and loss account/income and expenditure account for the period beginning from ……………………………. to ending on ……………………………. ,

(c) the cash flow statement for the period beginning from ……………………………. to ending on ……………………………., and

(d) documents declared by the said Act to be part of, or annexed to, the *profit and loss account/income and expenditure account and balance sheet.

2. I/we report that the said registered person-

*has maintained the books of accounts, records and documents as required by the IGST/CGST/GST Act, 2017 and the rules/notifications made/issued thereunder

*has not maintained the following accounts/records/documents as required by the IGST/CGST/GST Act, 2017 and the rules/notifications made/issued thereunder:

A.
B.

3. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be furnished under section 44(2) of the CGST Act is annexed herewith in Form No.GSTR-9C.

4. In *my/our opinion and to the best of *my/our information and according to examination of books of account including other relevant documents and explanations given to me/us, the particulars given in the said Form No.9C are true and correct subject to the following observations/qualifications, if any:

(a) …………………………….
(b) …………………………….
(c) …………………………….

…………………………….

**(Signature and stamp/Seal of the Auditor)

Place: …………………………….
Name of the signatory …………………………….
Membership No …………………………….
Date: …………………………….
Full address ……………………………. “.

(                                                           )

Under Secretary to the Government of India

Note:- The principal rules were published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i) vide notification No. 3/2017-Central Tax, dated the 19th June, 2017, published vide number G.S.R 610 (E), dated the 19th June, 2017 and last amended vide notification No. 48/2018Central Tax, dated the 10th September, 2018, published vide number G.S.R 859 (E), dated the 10th September, 2018.

Concluded By
ADV. D.R Bohra & Anirudh Bohra
Advocate & TAX Consultant
Office at: D.R. Bohra & Associates
6, Ground Floor , Balaji Complex
Goldbuilding Circle , Jodhpur ( Raj.)
Contact No. 9414474395
Email :- devrajbohra@gmail.com

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