Reporting Supplies In GST Annual Return

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What shall be the disclosure for Supply without consideration in the Annual Return?

In general, Supply without consideration does not attract GST provisions. As a result of which it is also not required to be reported in Annual return.

But, if these transactions are covered in the Schedule I of the CGST/SGST Act, they shall be disclosed in GSTR 1 of the relevant period. Reporting in GSTR 1 will also attract simultaneous reporting in Annual return GSTR 9.

There are some incorrect supplies reported by vendors but appearing in Form GSTR-2A. Do we need to exclude it while filing Annual Return?

Under Part III requires disclosure of certain additional details, which compares the credit reported under Sl.No.6(B). The values reported in Form GSTR-2A which are incorrect and not pertaining to the Assessee, can be reduced under Sl.No.8(F) since the same is not a credit which can be availed by the Assessee.

How mismatch between turnover reported in the Form GSTR-1 and Form GSTR-3B be reported in annual return?

The intention of the Annual return is to provide a summary of transactions reported in the monthly returns, such as

  • Supplies on which output tax is paid/payable
  • Tax exemption claimed / considered as Zero-rated
  • Input tax credit availed and reversed

Let us consider three possible situations

Outward supplies reported in Form GSTR-3B but not reported in Form GSTR-1:

To consider values reported in Form GSTR-3B and also the details of payment (if any) would be reported in Table 9 of the Annual Return

Outward supplies reported in Form GSTR-1 but not reported in Form GSTR-3B:

To consider value reported in Form GSTR-1 and also the details of tax payable (if any) would be reported in Table 9 of the Annual Return. However, if such transaction is included in Form GSTR-3B of the subsequent financial year, the same may be excluded in the Annual Return to be filed for the subsequent financial year so that there is no duplication/reporting of same transaction in annual returns of two years

Mismatch in values reported in Form GSTR-3B and Form GSTR-1:

To consider the correct value for the purpose of reporting in Annual Return. Excess/short payment would get captured in Table 9 of the Annual Return. It is also suggested to rectify the

What needs to be included in the Annual return in terms of “Non GST Supply”. The details should be same as periodical returns or can be changed?

Non GST supply are the transactions on which Goods and Service Tax provisions are not applicable. There are namely two supplies which are still outside the purview of GST,

  • Alcoholic liquor
  • Petroleum products

Since, the same does not attract GST there is no liability as to reporting or disclosure relating to these two products under GST law.

Wherein, sometimes it is noticed that people often misinterpret schedule III transactions i.e. neither supply of goods nor supply of services transactions also as Non GST supply, which is completely wrong. Neither supply of goods Nor supply of services transactions and Non GST supply are two different terms and have different treatments.

No Supply transactions are required to be disclosed in requisite forms GSTR 3B or GSTR 1 as per instruction to table 5D, 5E and 5F. But, suggested way is if a taxfiler has disclosed this item in periodical returns for the current financial year or in return for the month of Sep in next financial year, then, shall also disclose them in Annual return (table 5F). Otherwise, can directly report them in Audit Report or Reconciliation statement of 9C to be filed in Dec.

Is reporting relating to High Sea Sales, warehousing sale and merchanting sale needs to be done in the Annual Return?

There is no GST liability in terms of High Sea Sales, warehousing sale and merchanting sale. But, they are covered under Schedule III and hence are “No Supply” for which a reporting has to be made in Table 5F of Annual Return (as per the recent amendment brought into the provisions of Goods and Service Tax Law).

The tax liability on outward supply missed to be declared upto March 2018 and also till Sep next year in Form GSTR-1 and GSTR-3B. Can it be shown in the Annual Return?

In GSTR 9 annual return supply is reported under,

  • Part II – transactions already disclosed in periodical Goods and Service Tax Returns are reported here,
  • Part V – transactions which have been declared till the end of September of the next financial year i.e. Sep 2018 or the date of filing of Annual Return i.e. 31st Dec, whichever is earlier, are reported.

Since, in the given scenario disclosure has not been in made in periodical returns. Neither in periodical GSTRs till Sep next financial year. The same cannot be reported in annual return.

As an escape details can be shown in reconciliation statement to be field in audit Form GSTR 9C.

Whether adjustment of tax liability not declared upto March 2018 in the Form GSTR-1 and Form GSTR-3B be made in next year? Will some disclosure be also required in annual return?

Yes, A taxpayer if omitted to declare outward supply and tax liability can subsequently show transaction in GSTR 1 and subsequently pay tax liability in GSTR 3B. Circular No.26/2017 dated 29.12.2017 provides for the same.

However, when the transaction is skipped to be disclosed in the relevant Financial Year say FY 2017-18 and is shown later till the date of filing annual return. It shall be reported in annual return to be filed for the same financial year i.e. in Part V of annual return to be filed on 31 Dec 2018.

Does GSTR-9 requires any disclosure to anti-profiteering?

There is no explicit disclosure requirement as to report the amount of profit made through anti-profiteering activities in GSTR 9 Form. Instead, annual return has an integral component of verification. Which requires registered person to verify that in case of reduction in output tax liability, the benefit thereof has been/will be passed on to the recipient of supply.

No reversal for common input tax credits of taxable supply as well as exempted supply has been made for. Is any adjustment required be made in the Annual Return?

Annual return prescribes disclosure of actual reversals made in GSTR 3B. If reversals pertaining to FY 2017-18 have been made till Sep 2018, the same shall duly form part of annual return to be filed till Dec 2018. But, if the adjustment is given effect anytime later. It shall be disclosed under Annual Return of next year i.e. FY 2018-19 to be filed till Dec 2019.

Supply has been made to merchant exporter by charging GST @ 0.1%. Is it required to be disclosed in the Annual Return?

For manufacturer exporter such supply are in the nature of deemed exports and has to be disclosed in table 4 (E) of the Annual Return.

Whether Annual Return Requires disclosure if I have not declared exempted supply, Non GST supply and Nil rated supply in the monthly returns?

Table 5 of the Annual Return deals with disclosure of such supplies. although the heading of Table 5 provides for disclosure of “Details of Outward supplies on which tax is not payable as declared in returns filed during the financial year”, but considering the purpose of the Annual Return, it is suggested that all transactions pertaining to the previous year should be reported in the Annual Return whether or not such details have been shown in the periodical Return as the annual return would later be considered as the basis for preparation and filing of the Reconciliation statement.

Is input tax credits required to be identified and reported as expense in the Annual Return?

Annual return does not provide for categorization of input tax credit under various expense heads. The requirement to report credit availed against various expense heads is required to be reported in Form GSTR-9C

State the manner to disclose year end Provision made on unearned income in the Annual Return?

Provision for unearned income is not in the nature of supply. Rather, it is a reconciliation item. Hence, shall be disclosed in audit report form GSTR 9C and not to be reported in annual return GSTR 9.

How partially adjusted advances shall be reported in the Annual Return?

If there is a liability to pay GST on advance received then the said advance to the extent remaining unadjusted (i.e. in respect of which supply has not been made in the FY) has to be disclosed in the Table 4F.

Does Annual Return require reporting of liability on advances received on supply?

Table 4F requires disclosure of advances in respect of which tax is payable on receipt of such advance and invoice has not been issued in the FY. As there is no liability on the advances received towards supply of goods, there is no disclosure requirement of such advances in the Annual Return. However, if the advances have been received in the period when there was liability pay tax on advances received towards the goods also and invoice has not been issued in the FY, the same has to be disclosed in the Annual Return in Table 4F.

If Supplies to a registered persons have been disclosed as B2C supplies. Can it be corrected in Annual Return?

Rectification can be made only in Form GSTR-1 before the due date of furnishing the return for the month of September. Hence, the change of the nature of transactions from B2C supply to B2B supply have to be made in the GSTR-1. In the Annual Return, the supply should be disclosed under the appropriate head at the gross amount and adjustment should be shown in the amendment table.

CA Abhishek Soni
CA Abhishek Soni

Abhishek Soni is a Chartered Accountant by profession & entrepreneur by passion. He is the co-founder & CEO of Tax2win is amongst the top 25 emerging startups of Asia and authorized ERI by the Income Tax Department. In the past, he worked in EY and comes with wide industry experience from telecom, retail to manufacturing to entertainment where he has handled various national and international assignments.