Step-by-Step Guide to Filing GSTR-9 for FY 2023-24

Filing the GST annual return is a critical requirement under the GST regime, designed to consolidate all the details of outward and inward supplies, taxes paid, and credits claimed throughout the financial year. For FY 2023-24, there are key updates and filing requirements taxpayers must be aware of to ensure compliance.

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1. Filing Deadline and Prerequisites

• Deadline:
  The GST annual return (Form GSTR-9) for FY 2023-24 must be filed on or before December 31, 2024.
• Prerequisites Before Filing:
  To ensure the accuracy of the annual return, taxpayers must first file:
  • All monthly returns (GSTR-1, GSTR-3B).
  • Quarterly returns, if registered under the QRMP (Quarterly Return Monthly Payment) scheme.
    These periodic returns provide the data used to auto-populate many fields in GSTR-9.

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2. Key Updates in GSTR-9 for FY 2023-24

The most significant change introduced this year concerns the sourcing and reconciliation of Input Tax Credit (ITC):

(i) Shift from GSTR-2A to GSTR-2B for Table 8A

• What Has Changed?
  • Previously, Table 8A of GSTR-9 was populated using data from GSTR-2A, a dynamic statement that changes based on supplier uploads.
  • From FY 2023-24, GSTR-2B, a static statement, will be used instead.
• Why the Change?
  • GSTR-2B is a static auto-generated ITC statement, created based on invoices uploaded by suppliers in their GSTR-1 and GSTR-5.
  • Unlike GSTR-2A, which updates dynamically, GSTR-2B reflects ITC details as of a specific cut-off date, ensuring consistency and reducing discrepancies.
• Impact on Taxpayers:
  • Taxpayers must ensure that their suppliers upload invoices promptly for the correct period. Delays in uploads will result in ITC not appearing in GSTR-2B for the financial year, leading to reconciliation challenges.

(ii) Changes in Table 8: ITC Reconciliation

• Table 8A: Reflects ITC auto-populated from GSTR-2B.
• Table 8D: Displays the difference between ITC claimed in GSTR-3B and ITC reflected in GSTR-2B.
  • Taxpayers will need to reconcile this difference and provide explanations if any discrepancies arise.

(iii) ITC Reporting in Table 6

• Taxpayers must report ITC utilization based on the actual claims made in GSTR-3B during the financial year. This ensures alignment with periodic filings.

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3. Who Needs to File the GST Annual Return?

Mandatory Filing

• Every GST-registered taxpayer, except certain specified categories, must file GSTR-9.
• Exemptions include:
  • Input Service Distributors (ISD).
  • Persons registered under TDS/TCS provisions.
  • Casual taxable persons.
  • Non-resident taxable persons.

Turnover-Based Criteria

• Turnover Up to ₹2 Crore:
  Filing GSTR-9 is exempt for taxpayers with turnover ≤ ₹2 crore.
• Turnover Above ₹2 Crore:
  Filing GSTR-9 is mandatory for taxpayers with turnover exceeding ₹2 crore.

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4. Filing GSTR-9C: Reconciliation Statement

GSTR-9C is an audit-cum-reconciliation statement that compares the annual return (GSTR-9) with the taxpayer’s financial records. The requirement to file GSTR-9C depends on turnover:

• Turnover Between ₹2–5 Crore:
  Filing GSTR-9C is optional but recommended for reconciliation clarity.
• Turnover Above ₹5 Crore:
  Filing GSTR-9C is mandatory to verify that taxes paid and credits claimed align with financial records.

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5. Steps to File GSTR-9

Step 1: Prepare Your Data

1. Ensure that all periodic returns (GSTR-1, GSTR-3B) for FY 2023-24 are filed.
2. Reconcile ITC in GSTR-2B with ITC claimed in GSTR-3B.

Step 2: Download and Review GSTR-9

1. Log in to the GST portal and download the auto-drafted GSTR-9.
2. Check pre-filled data for accuracy in various tables.

Step 3: Reconcile ITC

1. Match ITC in Table 8A (auto-populated from GSTR-2B) with your books of accounts.
2. Address any discrepancies noted in Table 8D.

Step 4: Validate and File

1. Fill in any missing details, such as ITC reversals, adjustments, or late fees.
2. Submit the return and pay applicable late fees if filed after the deadline.

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6. Implications of the Changes

1. Timely Supplier Compliance:
   • Suppliers must upload invoices promptly to ensure ITC is accurately reflected in GSTR-2B.
   • Any delay could result in ineligible ITC claims for the financial year.
2. Accurate Reconciliation:
   • The shift to GSTR-2B for ITC reporting simplifies the process but places greater responsibility on taxpayers to reconcile any differences.
3. Enhanced Compliance:
   • GSTR-9 and GSTR-9C aim to ensure consistency between returns filed, ITC claims, and financial records, promoting better tax compliance.

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7. Key Advice for Taxpayers

• Monitor GSTR-2B Regularly:
  Review your GSTR-2B monthly to ensure all eligible ITC is reflected and discrepancies are addressed promptly.
• Reconcile Periodically:
  Reconcile GSTR-3B with GSTR-2B and your financial records throughout the year to avoid a last-minute rush.
• Maintain Communication with Suppliers:
  Ensure suppliers upload invoices on time to prevent ITC mismatches.

By staying proactive and adopting a methodical approach, taxpayers can navigate the updated GSTR-9 requirements smoothly and avoid penalties or ITC rejections.