Self Certified GSTR-9C For FY-20-21|GST Audit Due date and changes

Table of Contents

On 30th July 2021 CBIC notified changes to Sections 35(5) and 44 of the CGST Act. The requirement to get a GST audit and certification done by a CA/CMA now stands removed.

What is GST Audit?

GST Audit is basically scrutiny of Accounts with filed GST returns, Input tax credit claimed, refund claimed, interest to be paid on delayed tax payment, mismatch in GSTR-3B and GSTR-2A, mismatch in GSTR-3B and GSTR-1, Reverse Charge paid duly according to provisions of the GST Act.

Types of GST Audit

TypesPerformed ByWhen Initiated
Turnover based AuditChartered Accountant or Cost Accountant appointed by the taxpayerNow Optional after changes to Sections 35(5)
Normal audit/General AuditCommissioner of CGST/SGST or any Officer authorized by himOn the order of Commissioner by giving 15 days prior notice  
Special auditA Chartered Accountant or Cost Accountant, nominated by CommissionerOn the order of Deputy/Assistant Commissioner with prior approval of Commissioner

What is GSTR-9 and GSTR-9C?

GSTR-9 is an annual return where details of the Whole year is presented and modified if necessary the details are of:

Outward supply details and ITC details and onward tables divided under different tables

GSTR-9C is a reconciliation form that has to be self-certified by the taxpayer instead of being certified by CA/ CMA. And Verification table by CA/CMA in Part B of Form GSTR-9C has been deleted. Now, only verification by the registered person is required in GSTR-9C for applicable registered taxpayers.

Turnover limit for GST Audit

Annual turnoverGSTR 9GSTR 9C
Up to 2 CrOptionalN/A
More than 2Cr. – 5 CrFilling is mandatoryOptional (Benefit Given)
More than 5CrFilling is mandatoryThe filling is mandatory( for FY-20-21 can be self-certified without a CA or CMA )

GST Audit or GSTR-9 and 9C due dates

GSTR-9 and GSTR-9C are due on or before 31st December of the subsequent fiscal year. The due date of the GST audit for the financial year 2021 is 31st December 2021.

Late fees on GSTR-9 and GSTR-9C late filing

Any registered person failing to furnish the GSTR-9 by the due date shall be liable to pay a late fee of INR 200 (INR 100 for CGST and SGST each) every day during which such failure continues subject to a maximum of an amount calculated at a half percent of his turnover in the State or Union territory. Further, while calculating maximum late fee, ‘turnover in State’ or ‘turnover in Union territory’ should be taken into consideration.

GST Audit Checklist

Below particulars need to be verified

1. Reconciliation with GSTR 1 & 3b

2. Taxes on Reverse Charge Mechanism (RCM)

3. Interest on late payment of GST

4. Reversal of Input Tax Credit for non— payment in 180 days

5. Requirement of E-Way Bill

6. Matching GST Audit Turnover with Income Tax Turnover

7. Stock transfer

10. Bifurcation of ITC availed

Changes in the Finance Act 2021 regarding GST Audit

  • The need for a GST audit by CA/CMA stands removed for FY 2020-21 and any later financial years.
  • Every applicable taxpayer must submit a self-certified reconciliation statement by reconciling values between the audited financial statements and the annual returns.
  • Some taxpayers may be exempted from complying with the annual return and reconciliation statement requirement through the CBIC notification.
  • Section 44 shall not apply to any central government or state government departments already subject to audit by the Comptroller and Auditor-General of India (CAG).

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