FAQ – 15

Do I need to do Reconciliationreconciliation between the Financial Statements and GST Returns for the turnover / outward supplies while preparing the GST Audit Reconciliation Statement?

Yes, as per Ind AS – 18, revenue will be recognized only when the risks and rewards are transferred whereas in GST, at the time of Supply (section 13,14 & 15 of the CGST Act 2017) GST Liability has to be accounted.

Example: Goods shipped on 29th March from Delhi to Chennai and they are delivered on 3rd April at Chennai. As per GST, liability has to be accounted and paid in the March months return and as per Ind AS -18, it will not be booked as revenue if the Risk & Reward is not transferred.

FAQ – 14

As a taxpayer, if I do not file the Annual return by the due date or on the due date, is there any late fee i need to file if i am filing it after the due date?

Yes, a late fee is applicable and the provisions for the same are given in Section 47(2) of the CGST Act. Late is Rs 100 per day or maximum up to 0.25% of the turn over in a state.

FAQ – 12

FAQ -12: My turnover during the period July 2017 to March 2018 is Rs 71.25 Lacs and basis of the Notification No 12/2017-Central Tax dated 28th June 2017, i have not shown HSN Codes on the Tax Invoice. In the Annual Return do i need to show the HSN Summary?

The said notification is only for the purpose of display on the tax invoice and not for the Returns, so you have to show the HSN Summary in the Annual Return, We need to wait and see if it is Mandatory or Optional when it is made available.

FAQ – 10

For determining the eligibility for the GST Audit, do I need to consider the turnover as per the financial statements or I need to compute it separately?

It has to be considered separately as the turnover given in the Financial statements is based on the accounting standards and for GST it is based on Aggregate Turnover and Supply also includes some transactions even if consideration is not received as detailed in Schedule 1 of CGST Act.

FAQ – 8

FAQ – 8 : A Taxpayer has operations in three different states and his total turnover as per GST in all the three states is Rs 2.25 Crs. Turnover in State A is Rs 2.04 Crs, State B is Rs 14.00 Lacs and turnover in State is Rs 7.00 Lacs. Does the taxpayer has to file GSTR – 9C only for State A or all the three states?

The taxpayer has to file GSTR – 9C for all the states. As Section Section 35(4) uses the word “turnover” and it is not defined anywhere in the Act but Rule 80(3) the wording used is “aggregate turnover”. There are additional wordings used in 35(4) “in such form and manner as may be prescribed” meaning the process and other provisions as prescribed, that means here we can conclude that the Rules do not override the Act.

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GST Tip – 408

As per Notification No 65/2017 – Central Tax,  an electronic commerce operator who is supplying services under section 9, sub-section 5 and having a turnover is not above Rs 25 Lacs in a financial year at all India basis is exempted from taking registration under GST.

GST Tip – 199

The input service distributor (ISD) will distribute the credit to all the recipients where the inputs are consumed on pro rata on the basis of the turnover. The recipient can be registered under GST or not registered under GST or engaged in making exempt supply.