On the 4th of September 2018, the Central Board of Indirect Taxes and Customs (CBIC) had issued the notification for the GST annual return forms i.e. Form GSTR 9 and Form GSTR 9A, and on the 13th of September 2018, the CBIC had issued the notification for the annual return form i.e. Form GSTR 9C, in accordance with the CGST rules. The last date for all these forms was notified as the 31st of December 2018. However, a few days back, on 7th December, the CBIC and the GST Council decided to extend the due date for filing Form GSTR 9, Form GSTR 9A and Form GSTR 9C till the 31st of March 2019.

As you all must be aware, GSTR 9 is the annual return form for regular taxpayers, GSTR 9A is the annual return form for composition taxpayers while GSTR 9C is a reconciliation statement. Almost all registered taxpayers under GST are required to file annual returns, whereas businesses with an annual turnover of over INR 2 crore pan India, also need to file an audit report in the form of GSTR 9C.

The notification has also mentioned that the required forms will be made available on the GST portal shortly, and the relevant order for the same will also be issued.

4 reasons why GST Annual Return dates got extended

For a long time, several businesses, tax practitioners and trade & industry bodies have been urging the finance minister Mr. Arun Jaitley to extend the last date for filing the GST annual return. The 4 main reasons, why the CBIC finally extended the dates, are listed below:

Unfamiliarity with GST Annual Return

One of the topmost reasons seem to be unfamiliarity with the annual returns process. A few days back, the Confederation of All India Traders (CAIT) had raised the concern that the format for filing the annual GST returns was not available anywhere including the GST website. This meant, that filing the annual returns within the stipulated period would obviously be very difficult. Also, annual compliance in the GST regime was happening for the first time, and it would obviously take time for the business ecosystem to get familiar with the same. CAIT also urged that the format for filing annual returns should be made available in regional languages, so that traders are more at ease while going through the process.

Time consumed to resolve past GST returns

In several petitions to the Finance Ministry, industry bodies expressed that tax payers and practitioners will need to spend a lot of time in resolving their past returns. In fact, tax payers will have to scrutinise all their past purchases and past monthly returns, in order to fill up the particulars in the annual return. This could be a challenge for most small businesses, who may not yet have access to the right technology, to immediately pull and review all their past records. Also, the dates for filing Form GSTR 3B were extended for different months, making compliance on interest and late fee payment a complicated deal.

Effort required for compiling GST audit report

One of the important aspects of the GST annual returns is the GST audit report, which will basically require a reconciliation of the entire financials of a small business, such as, the balance sheet and P & L with the GST returns on a State-wide basis. For large companies, have registration across the country, creating such a virtual report across more than 30 States and Union Territories would surely be a huge task.

Hassle of declaring HSN wise details

Last but not the least, HSN-wise declarations of inward and outward supplies have always been a huge hassle for the tax payers. The HSN code was not mandatory to be declared for the monthly Form GSTR 3B returns, but the same must be mentioned in the annual returns.

In conclusion, it can be said that the extended timeline will surely provide a huge relief to both taxpayers and practitioners. After all, there is a stringent procedure of levying a late free of INR 200 per day, subject to a maximum of 0.25% of the said Financial Year’s turnover. Given the volume of transactions, businesses will have to scrutinise and review, this extension will definitely ensure a smoother GST annual return filing experience.

Pramit Pratim Ghosh

Author: Pramit Pratim Ghosh

Pramit, who has been with Tally since May 2012, is an integral part of the digital content team. As a member of Tally’s GST centre of excellence, he has written blogs on GST law, impact and opinions - for customer, tax practitioner and student audiences, as well as on generic themes such as - automation, accounting, inventory, business efficiency - for business owners.