GST UPDATE ON ISSUES IN ANNUAL RETURN-PART-6

This update is in continuation of the series being prepared in respect of issues that will be faced by assessees in disclosure requirements of annual return format i.e. GSTR 9. We are hereby enlisting such issues-
1. One point for consideration is the reporting of debit notes/credit notes issued after end of financial year 2017-18 but pertaining to invoices issued during the financial year. Say for example, the assessee issued credit note of Rs. 5,000/- in the month of July. 2018 and reported the same in GSTR-1 of July, 2018 but the invoice for which credit note has been issued pertains to the month of January, 2018. Now, the question arises is that whether the credit note is required to be reported in the annual return? In this regard, the language of serial no. 10 and 11 is worth observing which reads as follows:-

10- Supplies/tax declared through amendments (+) (net of debit notes)
11-Supplies/tax reduced through amendments (-) (net of credit notes)
However, issue arises of reporting the debit notes or credit notes that are issued not by way of amendment in earlier issued debit notes/credit notes but are freshly issued and reported in GSTR 1 for the months April 2018 to September 2018 but actually pertaining to financial year 2017-18. According to our opinion, the credit note issued in our example in the month of July, 2018 will be reflected in serial no. 11 of the annual return. However, according to some experts, the debit notes and credit notes issued after the end of financial year 2017-18 but reported till September 2018 would be reflected in serial no. 4I of the annual return filed for financial year 2018-19.
2. Another point of consideration is the reflection of total refund claims filed and pending in serial no. 15 of the annual return. The heading simply mentions the particulars of demands and refunds and does not specify the period for which the disclosure is to be made. However, the instructions given below the format of annual return mentions reporting of aggregate value of all the refund claims filed in the financial year thereby meaning that the details of refund claim filed during the financial year only are to be reported. Say for example, if the refund of accumulated credit is filed for the month of January, 2018 in the month of July, 2018, the details of the refund would not form part of the serial no. 15 of the annual return for the financial year 2017-18. The details of the said refund would become part of annual return filed for the financial year 2018-19. The reporting is correct as the assessee can file refund claim before expiry of two years from the relevant date. Consequently, there should be provision for reporting the status of refund claims filed in the respective financial years irrespective of the fact that the refund claim actually pertains to another financial year.

3. Another issue that is worth observing is issuance of refund vouchers against an advance order cancelled and refunded back to the recipient. Online portal doesn’t provide a separate column for reporting of refund vouchers in GSTR 1. However, in such a case, logically the advance refunded on which tax has already been paid should reported under Column 11(B) - Adjustment of Advances in GSTR 1. As such, there is no clarity as regards reporting refund vouchers in GSTR-1. But according to instructions given in GSTR 9, any refund vouchers issued would be reflected in Table 4K and 4L . Ideally, if the annual return is to be filed in alignment with GSTR 1, then amount is already been adjusted in advances amount. Separate disclosure of refund vouchers in annual return would be an additional exercise.
These are though minor issues but can have major impact in filing of GSTR 9. One should be very cautious while disclosing amounts in correct tables. As the annual return is consolidated replica of GSTR 1 and GSTR 3B duly filed for the period July 2017 to March 2018, but correct disclosure in corresponding tables would be a mundane task.

This is solely for the educational purpose.
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GST UPDATE ON ISSUES IN ANNUAL RETURN-PART-6

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