GST UPDATE ON REPORTING OF CREDIT NOTES AND AMENDMENTS IN GSTR-9

In the earlier update we have discussed the issues regarding the bifurcation of the credit availed in the GSTR 3B in the categories inputs, input services and capital goods. This update intends to highlight issues related to credit notes and reporting of amendments in GSTR-9.
4I in GSTR 9 contains details of credit notes issued in respect of outward supplies in 4B to 4E of GSTR 9 which is briefly described as follows-
4B- Supplies made to unregistered persons(B2B)
4C- Zero rated Supply(Export) on payment of tax(except supplies to SEZs)
4D- Supply to SEZs on payment of tax
4E- Deemed Exports
Reporting under credit notes issued for outward supplies made (4I) consists of only those which are reported in Table 9B of the GSTR 1 for the financial year 2017-18. Any reporting made subsequently in 2018-19 even in respect of period July- March 2018 are not to be considered here for reporting in table 4I.
Any amendments made in the debit and credit notes itself in the same financial year will be shown under the table 4K/4L- Supplies/ Tax declared through Amendments. However, it must be noted that only net effects of the amendments needs to be captured i.e. the incremental or differential value. If the entire revised value of invoice is disclosed in the amendment table, it will result in duplication of data thereby leading to incorrect results.
Another important point to be noted is that there is separate Part V for reporting transactions of financial year 2017-18 which are declared in returns filed for the period from April, 2018 to September, 2018. Table 10 and Table 11 of GSTR 9, reflects the supplies/tax declared or reduced through amendments. The point for consideration is that whether omission of transaction is to be treated as amendment or not? Say for example, if a sales invoice pertaining to the month of February, 2018 was omitted to be reported in GSTR-1 for February, 2018 and was later reported in the return filed for the month of May, 2018. In such case, the supplies, even if declared first time are to be reported in table 10 of GSTR-9. Although, the serial no. 10 of GSTR-9 mentions supplies declared through amendments but since there is no other specific serial no. wherein such supplies can be reported, the omissions are also to be reported in serial no. 10 of GSTR-9 itself.

The reporting of credit notes and their amendments is illustrated with the help of an example. Supplies were made to registered person amounting to Rs. 1,00,000 in the month of July, 2017. A credit note was issued against this invoice amounting Rs. 20,000 and was reported in August, 2017. However, the correct value of credit note was reflected in GSTR-1 of March, 2018 with Rs. 30000.
Now, the credit note worth Rs. 20,000 is to be shown in the table 4I under GSTR 9. The differential amount i.e.(30000-20000)= 10000 is to be shown under table 4L in GSTR 9.
In the same example, if the correct value of credit note was reflected in GSTR-1 of April, 2018, then in such case, since the revision was carried in the period April, 2018 to September, 2018, the same would be reported in Table 11 of annual return.
One more issue that is haunting the minds of the assessees is reporting of credit notes issued against nil rated, exempted and Non GST supplies. These credit notes are to be duly reported under table 5H table in annual return. However, GSTR 1 does not give facility to report such type of transactions in online as well as offline mode as such credit notes do not impact GST liability. These credit notes are in the nature of financial credit notes and are not reported in GSTR-1. Therefore, clarification should be issued as regards reporting such credit notes in the table 5H of return.

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GST UPDATE ON REPORTING OF CREDIT NOTES AND AMENDMENTS IN GSTR-9

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