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December 3, 2022

Gujarat sales tax bar association requested to submit HSN details optional for F.Y. 2021-22 in GSTR-9 – Annual Return

Gujarat sales tax bar association requested to submit HSN details optional for F.Y. 2021-22 in GSTR-9 – Annual Return


Smt. Nirmala Sitharaman,

The Union Minister of Finance,

Government of India &

Chairperson — GST Council

134, North Block, New Delhi — 110 001

Respected Madam,

Subject : Request to submit HSN details optional for F.Y. 2021-22 in GSTR-9 – Annual Return

GSTR-9 is a GST annual return form required to be furnished annually to all the taxpayer who is having turnover of more than Rs. 2 Crore. Due date to file GSTR-9 for F.Y. 2021-22 is 31/12/2022.

As far as filing of annual return for F.Y. 2021-22 is concerned, following are the mandatory requirements which is to be complied by the taxpayer while filing annual return :

  1. HSN wise summary of outward supplies are required to be reported in Table 17 for FY 2021-22. It will be mandatory to report HSN Code at four digits level having annual turnover upto 5 Cr and at Six digits level for taxpayers having annual turnover above 5 Cr.
  2. Details pertaining to RCM ITC for unregistered/ registered needs to reported separately in Table 6C & 6D.
  3. Non-GST supplies are to be reported separately in Table 5F of Form GSTR-9 .
  4. Table 9 regarding ‘Tax  Payable’ and ‘Tax  Paid’ shall be adequately filled.
  5. Credit Notes/Debit Notes/ Adjustments (if any) in respect of B2B Supplies and Export/Supply to SEZ with payment of taxes shall be reported separately. However, in case of B2C Supplies, net of Debit/Credit Notes shall be reported.

Up to F.Y. 2020-21 HSN summary table in GSTR-9 was optional however, for F.Y. 2021-22 mentioning of HSN code is mandatory while filing GST annual return. Although it was not needed while filing monthly GSTR-3B. The reporting of HSN of inward supplies become irksome if not maintained previously therefore , it is humbly requested that requirement of HSN which has made mandatory may please be make optional even for FY 2021-22 also. Since mentioning of HSN for both inward and outward
supplies is indeed a tedious task for the taxpayer who are not habitual in maintaining such kinds of records and same will cause unnecessary hassles for them. It is also time consuming and requires lot of additional efforts and I.T. skilled manpower.

Filing a GSTR-9 is an online process but not an easy one for the taxpayer. The taxpayers are facing multiple challenges while filing true and correct GSTR-9 annual return. Various issues and problems with the GSTR-9 are so confounding that most filers won’t be able to meet the deadline of December 31′ 2022. One of the biggest pain point for taxpayer is of mandatory mentioning of HSN and submitting of lot of information.

Such information are not required to be given in the monthly or quarterly return forms – GSTR -1 and GSTR – 3B.

Due to the complex structure of the annual return , taxpayers are afraid to file it as there is no provision in the law to rectify the annual return. Therefore, our association humbly request for waiver of mentioning of HSN code mandatory in annual return GSTR – 9 for FY 2021-22 and make it optional as it was in the earlier years . Your immediate action in the direction is highly solicited .

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