Credit Note Disclosure In GSTR 9 Annual Return Filing

How to report Financial Credit Note issued by the supplier in the Annual Return?

Section 34 of the CGST Act specifies the credit notes for which a disclosure is required in the annual return. Financial Credit Note not being part of the same does not attract any disclosure requirement nor GST provisions are applicable on them. Hence, they are not required to be reported under GSTR 1 or 3B or 9/9A.
Still financial credit note might form part of GTSR 9C as they adjustments might be required for reconciling books of accounts and Goods and Service Tax Returns filed for the period.

Is there any separate disclosure requirement for credit note issued to registered and unregistered persons?

Yes, separate disclosure in annual return is required for credit note issued to registered and unregistered persons.

• Registered – As B2B supplies in Table 4(I)
• Unregistered – As B2C supplies (net off values) in Table 4(a)

Are B2C larges supplies (>2.5 lakhs) and other B2C supplies need to be disclosed separately?

B2C i.e. Business to customer supply and B2B i.e. Business to Business supply shall be bifurcated. But there is no requirement for further classification for B2C supply on the basis of large i.e. >2.5 lakhs sales and others. The B2C supply reported under GSTR 1 under Table 5 and 7 shall be disclosed net off of credit notes, in annual return under Table 4A.

An Invoice was issued under Service tax @ 14% in respect of the same Credit note was issued under GST @ 18%. Where to show such credit note in annual return?

Credit note issued for downward revision under GST, in respect of invoice issued under earlier tax law, shall as per section 142(2)(a) of CGST Act be deemed to have been issued under Goods and Service Tax. Hence, such credit notes shall be disclosed in 4(I) of the annual return.

Whether Year-end discount given to the distributor require reporting in Annual Return?

Credit note under GST is issued as per provisions of section 34 of the CGST/SGST Act. And, if the credit note has been amended for

• Adjustment permitted under section 15 i.e. in respect to an agreement existing on the date of supply – shall be disclosed while filing an annual return
• Adjustments as per agreement in force or Section 15 – no need of disclosure, no implication of GST.

State the disclosure of Credit Note issued and disclosed in Form GSTR-1 of the same Financial Year?

In this case, since both the issuance of credit note and its disclosure falls in the same year, there is no confusion as to its reporting. It shall be reported in the annual return to be filed for the respective year as

• For B2B – to be reported in the Table 4L
• For B2C – to be reported in the Table 4A (after net off)

A credit note pertaining to previous year has been issued next year and duly reported in GSTR 1. What shall be the treatment in annual return?

Credit note is generally issued next year when a sales done now, has been returned back in the next year. Which in itself is an ambiguous issue. And, there are two practices being adopted to adhere this,

• Some believe that it relates to sales made in a current year and shall be duly reported in annual return part V of the same year. For which a supporting is also found in Form 9C, which states to report adjustment in credit note reported in annual return GSTR 9 after the end of FY.
• Others have an opinion that since sales return is an independent event which has taken place in the next financial year, reporting of credit note shall not be made in annual GST return for the current year.

A credit note pertaining to the previous year was issued on time but reported in GSTR 1 of next year. What shall be the treatment in annual return?

Although there is a delay in disclosure of the credit note in GSTR 1. But, as it is related to the previous financial year and has been disclosed till Sep 2018. A disclosure in the annual return to be filed till 31st dec 2018 shall be made in part V.

A credit note pertaining to the previous year was issued on time and reported. But, was subsequently amended in GSTR 1 of next year. What shall be the treatment in annual return?

Credit note amended till Sep of the next financial year namely, Sep 2018 in this case, shall be reported in annual return part V, to be filed till 31st Dec 2018.

A credit note pertaining to the previous year was issued on time, reported and amended in GSTR 1 of the same year. What shall be the treatment in annual return?

There is no special provision as to reporting of credit notes amended and disclosed within the same financial year. It shall be reported in the annual return as per normal provisions, i.e.

• For B2B – Disclosure in the Table 4K / 4L
• For B2C – Disclosure in the Table 4A (after net off)