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GST AUDIT LIMIT, DUE DATE, FORMAT & APPLICABILITY

August 18, 2018

GST AUDIT – LIMIT, DUE DATES & APPLICABILITY
(FAQ’s)

By CA Ankit Gulgulia (Jain)

B.COM (H), FCA, CIFRS,
CBV

Goods and Service Tax Act, 2017 has been a phenomenon of so many
changes since its implementation. The changes are for the slow but sure
evolution of both the law as well as practical implementation of GST on Ground.
One very important provision which can drive the concept of “Minimum
Intervention by Government” is Audit of GST Assesses by Chartered Accountants.

Below is the List of Details relevant to Understand, who are the assesses
required to comply the Audit Provisions under GST. Remember, beyond normal
Audits by CA, the GST law also envisages departmental audit or Special Audit by
CA nominated by Department. Current post does not discuss departmental audit.

S.No	Topics / Remarks	Remarks
1	How is Audit Defined under the Act?	Section 2(13) defines Audit as “The examination of records, returns and other documents maintained or furnished by the registered person under this Act or the rules made thereunder or under any other law for the time being in force to verify the correctness of turnover declared, taxes paid, refund claimed and input tax credit availed, and to assess his compliance with the provisions of this Act or the rules made thereunder.” Hence in nutshell, any non compliance under the GST Act can be assessed under Audit.
2	Under Which Section Audit is Prescribed?	Section 35(5) prescribes that, Every registered person whose turnover during a financial year exceeds the prescribed limit shall get his accounts audited by a chartered accountant or a cost accountant and shall submit a copy of the audited annual accounts, the reconciliation statement and any other prescribed document.
3	What is the Limit of Turnover & Applicability?	Aggregate turnover during a financial year exceeds 2 Crore Rupees. Note:- a) Aggregate turnover must exceed 2 Crores
4	How to Compute the Turnover?	The term “Aggregate Turnover” is defined as Aggregate Turnover = Aggregate value of all taxable supplies (excluding Reverse Charge) PLUS Exempt Supplies PLUS Export of Goods/ Service PLUS Interstate Supplies (excluding any CGST, SGST, IGST & Cess) on ONE PAN Number.
5	Is the Turnover State Wise or PAN Wise?	From Above it is Clear, the turnover is PAN Wise. One the limit exceeds 2 Crores all states registered under that PAN has to be audited.
6	What are the Documents to be Filed?	Annual Return, Audited Copy of Financial Statements & Reconciliation Statement.
7	What are the Forms to be Filed?	GSTR -9B For Audit Report & FORM GSTR-9C for Reconciliation Statements
8	Whether Rectifications after Return Based on Results of Audit under GST are permitted? If yes, whether Interest will be Payable?	If any taxable person, after furnishing a return discovers any omission/incorrect details (from results of audit), he can rectify subject to payment of interest. However, no rectification will be allowed after the due date for filing of return for the month of September or second quarter, (as the case may be), following the end of the financial year, or the actual date of filing o the relevant annual return, whichever is earlier. For example, X found during the audit that he has made a mistake in Oct 2017 return. X submitted an annual return for FY 2017-18 on 31st August 2018 along with audited accounts. He can rectify the Oct 2017 mistake within- 20th Oct 2018 (last date for filing Sep return) or 31st August 2018 ( the actual date of filing of relevant annual return) -earlier, ie., his last date for rectifying is 31st August 2018.
9	What is the Reconciliation Statement?	Section 44 Prescribes Reconciliation statement to be filed by assesses who are to be audited. Such reconciliation shall involve reconciling the value of supplies declared in the return furnished for the financial year with the audited annual financial statement, and such other particulars as may be prescribed.