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GST Act envisages three types of audits:-

First, mandatory audit if turnover exceeds the Rs. 2 crores [U/s 35(5)].
Second, special audit if complexities are involved in the calculations [U/s 66]
Third, the audit by tax authorities. [U/s 65]

Note:- The first two audits can be conducted by a CA & CMA.

If Taxpayer fails to get his accounts audited [U/s 35(5)]:-

Liable to pay a late fee of Rs. 200 Per Day or
5% of the annual turnover.

Whichever is Lower

Turnover based Audit:-

Not mandatory for any Govt. department subject to audit by CAG.

ICAI has clarified that an Internal Auditor can’t undertake GST Audit of the same entity.

Person Required to file Annual Return:-

Rule 80. Every registered person except,
- Input Service Distributor
- The PThe person paying tax under section 51 or section 52
- Casual taxable person
- Non-resident taxable person

Furnish an annual return in FORM GSTR-9 by 31st December of the next financial year.

Note :- Annual Return for F.Y. 2017-18 shall be furnished on or before the 30th June, 2019

(Order No. 03/2018 – Central Tax, Dated 31-12-2018)

A person paying tax under section 10 shall furnish the annual return in FORM GSTR-9A.
Electronic commerce operator required to collect tax at source under section 52 shall furnish the annual statement in FORM GSTR-9B.
Form GSTR-9C is divided into two parts :-
- Part A, Reconciliation Statement
- Part B, Certification by a Chartered Accountant or a Cost Accountant.
If the taxpayer has multiple GSTIN
- Needs to file Annual Return separately for every GSTIN.

Part A – Reconciliation Statement:-

In Part A of Form GSTR-9C, the auditor is required to furnish the following details:

Basic details about the registered person.
Reconciliation of taxes paid.
Reconciliation of input tax credit.
Additional liability due to non-reconciliation.
Reconciliation of turnover declared in the audited annual financial statement with turnover in Annual Return in Form GSTR-9.

Note:- The auditor shall also provide the reasons for unreconciled differences.

Part B – Auditor’s Certificate:-

The auditor shall issue a certificate in Part B of Form GSTR-9C

Possible differences in Reconciliation Statements

In the case of turnover:-
1. Transactions pertaining to last year or subsequent years.
2. Advance payments.
3. Transactions without consideration.
4. Credit Notes.
5. Trade discounts.
6. Valuation as per the Act.
In Case of Input Tax Credit:-
1. ITC not allowable.
2. Recipient forgotten to avail ITC, but available in GSTR-2A.
3. Timing difference in availment and utilisation.

Note :- If there are any difference in the turnover reported:-

Under Goods & Service Tax Regime
In Financial Statements
In Income Tax Returns

And the same is not reconciled and replied to the satisfaction of the concerned officer. Then notices can be issued as per provisions of Section 74,76,122,124,127 and 132.

PREREQUISITES/CHECK LIST FOR FILING OF ANNUAL RETURNS :-

Certain steps or process to be completed before starting the process of preparation of Annual Return.
- Ensures that there are no differences between the data shared and filed with various departments :
  - Income Tax
  - Registrar of Companies
  - Director General of Foreign Trade
  - Reserve Bank of India payment systems e-kuber

As on date, the department is verifying data between various returns filed.

Before finalizing the books of accounts for the Financial year verify / ensure that the following process is completed :-
- Tax invoices are accounted in the financial statements and reported in the GST Returns.
- Invoices issued for the inter branch transfer are accounted for properly.
- Stock transfer are issued under a cover of Delivery challan.
- Payments are mapped with a tax invoice, if not ensure that receipt voucher is issued for the same.
- Advance receipt vouchers are issued for the services after the Notification No. 66 – Central Tax Dated 15/11/2018.
- Proper applicability of advance receipt on Composition supply.
- Cross check the banking statements with the debtors/aging reports.
- Valuation process of all tax Invoices.
- E-waybill data filed matches with the tax invoice or not.
- Goods sent out for the job work are returned back within the time limit and filling of ITC-04.
- HSN codes are properly used as per the size of business.
- HSN codes along with UOM is followed as per the Customs Tariff Act.
- Provisions of the mixed supply are followed correctly. and also the highest tax rate is charged on the tax invoice.
- Tax rates is correctly followed on advance receipts.
- Anti profiteering provisions of Section 171.

– Ensure that benefit of the additional input tax credit is properly passed on.

Refund voucher is issued in case of the amount returned to customers partially or fully.
All GST Returns are filed up to 31st March 2018
Prepare Reconciliation statement among:-
- Inward Supply
  - GSTR-3B
  - GSRT-2A
  - Details as per Financials.

Outward Supply

ITC on Fixed Assets avail on or after the date of Capitalization.
Input tax credit is taken correctly as per the provisions of Section 16 and section 17 of the CGST Act 2018.
There are no debit notes issued to the supplier of goods or services or both.
Provisions of time of supply is followed correctly in case of reverse charge on the supply of goods falling under provisions of section 9(4) of the CGST Act.
Provisions of the place of supply are followed correctly else rectify them accordingly as per the provisions applicable.

CA Pankaj Aggarwal

PPT on GST Audit & Annual Return