GST Audit Report & Reconciliation Statement Format Notified

UP GST GPS Tracking

[To be published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section

(i)]

Government of India Ministry of Finance (Department of Revenue)

Central Board of Indirect Taxes and Customs

Notification No. 49/2018 – Central Tax

New Delhi, the 13tSeptember, 2018

G.S.R……(E).-  In exercise of the powers conferred by section 164 of the Central Goods and Services Tax Act, 2017 (12 of 2017), the Central Government

hereby makes the following rules further to amend the Central Goods and Services Tax Rules, 2017, namely:

(1) These rules may be called the Central Goods and Services Tax (Tenth Amendment) Rules, 2018.

(2) They shall come into force on the date of their publication in the Official Gazette.


  1. In the FORMS to the Central Goods and Services Tax Rules, 2017, after FORM GSTR-

9A, the following shall be inserted, namely:-

“FORM GSTR-9C

See rule 80(3)

PART – A – Reconciliation Statement

Pt. I Basic Details
1 Financial

Year

2 GSTIN
3A Legal Name < Auto>
3B Trade Name

(if any)

<Auto>
4 Are you liable to audit under any Act?                  <<Please specify>>
(Amount in ₹ in all tables)
Pt.

II

Reconciliation of turnover declared in audited Annual Financial Statement with

turnover declared in Annual Return (GSTR9)

5 Reconciliation of Gross Turnover
A Turnover (including exports) as per audited financial

statements for the State / UT (For multi-GSTIN units under same PAN the turnover shall be derived from the audited Annual Financial Statement)

B Unbilled revenue at the beginning of Financial Year (+)
C Unadjusted advances at the end of the Financial Year (+)
D Deemed Supply under Schedule I (+)
E Credit Notes issued after the end of the financial year

but reflected in the annual return

(+)
F Trade Discounts accounted for in the audited Annual (+)
Financial Statement but are not permissible under GST
G Turnover from April 2017 to June 2017 (-)
H Unbilled revenue at the end of Financial Year (-)
I Unadjusted Advances at the beginning of the Financial

Year

(-)
J Credit notes accounted for in the audited Annual

Financial Statement but are not permissible under GST

(-)
K Adjustments on account of supply of goods by SEZ

units to DTA Units

(-)
L Turnover for the period under composition scheme (-)
M Adjustments in turnover under section 15 and rules

thereunder

(+/-

)

N Adjustments in turnover due to foreign exchange

fluctuations

(+/-

)

O Adjustments in turnover due to reasons not listed above (+/-

)

P Annual turnover after adjustments as above <Auto>
Q Turnover as declared in Annual Return (GSTR9)
R Un-Reconciled turnover (Q – P) AT1
6 Reasons for Un – Reconciled difference in Annual Gross Turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
7 Reconciliation of Taxable Turnover
A Annual turnover after adjustments (from 5P above) <Auto

>

B Value of Exempted, Nil Rated, Non-GST supplies, No-Supply

turnover

C Zero rated supplies without payment of tax
D Supplies on which tax is to be paid by the recipient on reverse

charge basis

E Taxable turnover as per adjustments above (A-B-C-D) <Auto>
F Taxable turnover as per liability declared in Annual Return

(GSTR9)

G Unreconciled taxable turnover (F-E) AT 2
8 Reasons for Un – Reconciled difference in taxable turnover
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
Pt.

III

Reconciliation of tax paid
9 Reconciliation of rate wise liability and amount payable thereon
Tax payable
Description Taxable Value Central tax State tax

/ UT tax

Integrated Tax Cess, if

applicabl e

1 2 3 4 5 6
A 5%
B 5% (RC)
C 12%
D 12% (RC)
E 18%
F 18% (RC)
G 28%
H 28% (RC)
I 3%
J 0.25%
K 0.10%
L Interest
M Late Fee
N Penalty
O Others
P Total amount to be paid as per tables above <Auto> <Auto> <Auto> <Auto>
Q Total amount paid as declared in

Annual Return (GSTR 9)

R Un-reconciled payment of amount PT 1
10 Reasons for un-reconciled payment of amount
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
11 Additional amount payable but not paid (due to reasons specified under Tables

6,8 and 10 above)

To be paid through Cash
Description Taxable Value Central tax State tax

/ UT tax

Integrated tax Cess, if

applicabl e

1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Interest
Late Fee
Penalty
Others

(please specify)

Pt. Reconciliation of Input Tax Credit (ITC)
IV
12 Reconciliation of Net Input Tax Credit (ITC)
A ITC availed as per audited Annual Financial Statement for the

State/ UT (For multi-GSTIN units under same PAN this should be derived from books of accounts)

B ITC booked in earlier Financial Years claimed in current

Financial Year

(+)
C ITC booked in current Financial Year to be claimed in

subsequent Financial Years

(-)
D ITC availed as per audited financial statements or books of

account

<Auto>
E ITC claimed in Annual Return (GSTR9)
F Un-reconciled ITC ITC 1
13 Reasons for un-reconciled difference in ITC
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
14 Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account
Description Value Amount of

Total ITC

Amount of eligible

ITC availed

1 2 3 4
A Purchases
B Freight / Carriage
C Power and Fuel
D Imported goods

(Including received from SEZs)

E Rent and Insurance
F Goods lost, stolen,

destroyed, written off or disposed of by way of gift or free samples

G Royalties
H Employees’ Cost

(Salaries, wages, Bonus etc.)

I Conveyance charges
J Bank Charges
K Entertainment charges
L Stationery Expenses

(including postage etc.)

M Repair and

Maintenance

N Other Miscellaneous

expenses

O Capital goods
P Any other expense 1
Q Any other expense 2
R Total amount of eligible ITC availed <<Auto>>
S ITC claimed in Annual Return (GSTR9)
T Un-reconciled ITC ITC 2
15 Reasons for un – reconciled difference in ITC
A Reason 1 <<Text>>
B Reason 2 <<Text>>
C Reason 3 <<Text>>
16 Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)
Description Amount Payable
Central Tax
State/UT

Tax

Integrated

Tax

Cess
Interest
Penalty
Pt.

V

Auditor’s recommendation on additional Liability due to non-reconciliation
To be paid through Cash
Description Value Central tax State tax

/ UT tax

Integrated tax Cess, if

applicabl e

1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Input Tax

Credit

Interest
Late Fee
Penalty
Any other

amount paid for supplies not included in Annual Return

(GSTR 9)
Erroneous

refund to be paid back

Outstanding

demands to be settled

Other (Pl.

specify)

Verification:

I hereby solemnly affirm and declare that the information given herein above is true and correct to the best of my knowledge and belief and nothing has been concealed there from.

**(Signature and stamp/Seal of the Auditor)

Place: ……………

Name of the signatory ………………… Membership No………………

Date: ……………

Full address ………………………

Instructions: –

  1. Terms used:

(a) GSTIN: Goods and Services Tax Identification Number

  1. The details for the period between July 2017 to March 2018 are to be provided in this statement for the financial year 2017-18.
  2. The reconciliation statement is to be filed for every GSTIN separately.
  3. The reference to current financial year in this statement is the financial year for which the reconciliation statement is being filed for.
  4. Part II consists of reconciliation of the annual turnover declared in the audited Annual Financial Statement with the turnover as declared
  5. in the Annual Return furnished in FORM GSTR-9 for this GSTIN. The instructions to fill this part are as follows :-
Table No. Instructions
5A The turnover as per the audited Annual Financial Statement shall be declared

here. There may be cases where multiple GSTINs (State-wise) registrations exist on the same PAN. This is common for persons / entities with presence over multiple States. Such persons / entities, will have to internally derive their GSTIN wise turnover and declare the same here.  This shall include export turnover (if any). It may be noted that reference to audited Annual Financial Statement includes reference to books of accounts in case of persons

/ entities having presence over multiple States.

5B Unbilled revenue which was recorded in the books of accounts on the basis of

accrual system of accounting in the last financial year and was carried forward to the current financial year shall be declared here. In other words, when GST is payable during the financial year on such revenue (which was recognized earlier), the value of such revenue shall be declared here.

(For  example,  if  rupees  Ten    Crores  of  unbilled  revenue  existed  for  the financial year 2016-17, and during the current financial year, GST was paid on rupees Four  Crores of such revenue, then value of rupees Four Crores rupees shall be declared here)

5C Value of all advances for which GST has been paid but the same has not been

recognized as revenue in the audited Annual Financial Statement shall be declared here.

5D Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017

shall  be  declared  here.  Any  deemed  supply  which  is  already  part  of  the turnover in the audited Annual Financial Statement is not required to be included here.

5E Aggregate value of credit notes which were issued after 31st of March for any
supply accounted in the current financial  year but such credit notes were

reflected in the annual return (GSTR-9)shall be declared here.

5F Trade discounts  which  are accounted for in  the  audited  Annual  Financial

Statement but on which GST was leviable(being not permissible) shall be declared here.

5G Turnover included in the audited Annual Financial Statement for April 2017 to

June 2017 shall be declared here.

5H Unbilled revenue which was recorded in the books of accounts on the basis of

accrual system of accounting during the current financial year but GST was not payable on such revenue in the same financial year shall be declared here.

5I Value of all advances for which GST has not been paid but the same has been

recognized as revenue in the audited Annual Financial Statement shall be declared here.

5J Aggregate value of credit notes which have been accounted for in the audited

Annual Financial Statement but were not admissible under Section 34 of the

CGST Act shall be declared here.

5K Aggregate value of all goods supplied by SEZs to DTA units for which the

DTA units have filed bill of entry shall be declared here.

5L There may be cases where registered persons might have opted out of the

composition scheme during the current financial year. Their turnover as per the audited Annual Financial Statement would include turnover both as composition taxpayer as well as normal taxpayer. Therefore, the turnover for which GST was paid under the composition scheme shall be declared here.

5M There may be cases where the taxable value and the invoice value differ due to

valuation principles under section 15 of the CGST Act, 2017 and rules thereunder. Therefore, any difference between the turnover reported in the Annual  Return  (GSTR  9)  and  turnover  reported  in  the  audited  Annual Financial Statement due to difference in valuation of supplies shall be declared here.

5N Any difference between the turnover reported in the Annual Return (GSTR9)

and  turnover  reported  in  the  audited  Annual  Financial  Statement  due  to foreign exchange fluctuations shall be declared here.

5O Any difference between the turnover reported in the Annual Return (GSTR9)

and  turnover  reported  in  the  audited  Annual  Financial  Statement  due  to reasons not listed above shall be declared here.

5Q Annual turnover as declared in the Annual Return (GSTR 9) shall be declared

here. This turnover may be derived from Sr. No. 5N, 10 and 11 of Annual

Return (GSTR 9).
6 Reasons for non-reconciliation between the annual turnover declared in the

audited Annual Financial Statement and turnover as declared in the Annual

Return (GSTR 9) shall be specified here.

7 The table provides for reconciliation of taxable turnover from the audited

annual turnover after adjustments with the taxable turnover declared in annual return (GSTR-9).

7A Annual turnover as derived in Table 5P above would be auto-populated here.
7B Value  of  exempted,  nil  rated,  non-GST  and  no-supply  turnover  shall  be

declared  here.  This  shall  be reported  net  of  credit  notes,  debit  notes  and amendments if any.

7C Value of zero rated supplies (including supplies to SEZs) on which tax is not

paid shall be declared here. This shall be reported net of credit notes, debit notes and amendments if any.

7D Value of reverse charge supplies on which tax is to be paid by the recipient

shall be declared here. This shall be reported net of credit notes, debit notes and amendments if any.

7E The taxable turnover is derived as the difference between the annual turnover

after adjustments declared in Table 7A above and the sum of all supplies (exempted, non-GST, reverse charge etc.) declared in Table 7B, 7C and 7D above.

7F Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall

be declared here.

8 Reasons for non-reconciliation between adjusted annual taxable turnover as

derived from Table 7E above and the taxable turnover declared in Table 7F

shall be specified here.

  1. Part III consists of reconciliation of the tax payable as per declaration in the reconciliation statement and the actual tax
  2. paid as declared in Annual Return (GSTR9). The instructions to fill this part are as follows :-
Table No. Instructions
9 The table provides for reconciliation of tax paid as per reconciliation statement

and amount of tax paid as declared in Annual Return (GSTR 9). Under the head labelled ―RC‖, supplies where tax was paid on reverse charge basis by the recipient (i.e. the person for whom reconciliation statement has been prepared ) shall be declared.

9P The total amount to be paid as per liability declared in Table 9A to 9O is auto

populated here.

9Q The amount payable as declared in Table 9 of the Annual Return (GSTR9)

shall be declared here. It should also contain any differential tax paid on Table

10 or 11 of the Annual Return (GSTR9).

10 Reasons for non-reconciliation between payable / liability declared in Table

9P above and the amount payable in Table 9Q shall be specified here.

11 Any amount which is payable due to reasons specified under Table 6, 8 and 10

above shall be declared here.

  1. Part IV consists of reconciliation of Input Tax Credit (ITC). The instructions to fill Part

IV are as under:-

Table No. Instructions
12A ITC availed (after reversals) as per the audited Annual Financial Statement

shall be declared here. There may be cases where multiple GSTINs (State- wise) registrations exist on the same PAN. This is common for persons / entities with presence over multiple States. Such persons / entities, will have to internally derive their ITC for each individual GSTIN and declare the same here. It may be noted that reference to audited Annual Financial Statement includes reference to books of accounts in case of persons / entities having presence over multiple States.

12B Any ITC which was booked in the audited Annual Financial Statement of

earlier financial year(s)but availed in the ITC ledger in the financial yearfor which the reconciliation statement is being filed for shall be declared here. This shall include transitional credit which was booked in earlier years but availed duringFinancial Year 2017-18.

12C Any ITC which has been booked in the audited Annual Financial Statement of

the current financial year but the same has not been credited to the ITC ledger for the said financial year shall be declared here.

12D ITC availed as per audited Annual Financial Statement or books of accounts

as derived from values declared in Table 12A, 12B and 12C above will be auto-populated here.

12E Net ITC available for utilization as declared in Table 7J of Annual Return

(GSTR9) shall be declared here.

13 Reasons  for  non-reconciliation  of  ITC  as  per  audited  Annual  Financial

Statement  or  books  of  account  (Table  12D)  and  the  net  ITC  (Table12E)

availed in the Annual Return (GSTR9) shall be specified here.
14 This table is for reconciliation of ITC declared in the Annual Return (GSTR9)

against the expenses booked in the audited Annual Financial Statement or books of account. The various sub-heads specified under this table are general expenses in the audited Annual Financial Statement or books of account on which ITC may or may not be available. Further, this is only an indicative list of heads under which expenses are generally booked. Taxpayers may add or delete any of these heads but all heads of expenses on which GST has been paid / was payable are to be declared here.

14R Total ITC declared in Table 14A to 14Q above shall be auto populated here.
14S Net ITC availed as declared in the Annual Return (GSTR9) shall be declared

here. Table 7J of the Annual Return (GSTR9) may be used for filing this

Table.

15 Reasons for non-reconciliation between ITC availed on the various expenses

declared in Table 14R and ITC declared in Table 14S shall be specified here.

16 Any amount which is payable due to reasons specified in Table 13 and 15

above shall be declared here.

  1. Part  V  consists  of  the  auditor’s  recommendation  on  the  additional  liability  to  be discharged by the taxpayer

due to non-reconciliation of turnover or non-reconciliation of input tax credit. The auditor shall also recommend if there

is any other amount to be paid for supplies not included in the Annual Return. Any refund which has been erroneously

taken and shall be paid back to the Government shall also be declared in this table. Lastly, any other outstanding demands

which is recommended to be settled by the auditor shall be declared in this Table.

  1. Towards, the end of the reconciliation statement taxpayers shall be given an option to pay their taxes as recommended by the auditor.

PART –  B- CERTIFICATION

  1. Certification in cases where the reconciliation statement (FORM GSTR-9C)

is drawn up by the person who had conducted the audit:

* I/we have examined the—

(a) balance sheet as on ………

(b) the *profit and loss account/income and expenditure account for the period beginning

from ………..…to ending on ……., and

(c) the cash flow statement for the period beginning from ……..…to ending on ………, —

attached herewith, of M/s …………… (Name), …………………….………… (Address),

..…………………(GSTIN).

  1. Based on our audit I/we report that the said registered person—

*has  maintained  the  books  of  accounts,  records  and  documents  as  required  by  the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

*has   not   maintained   the   following   accounts/records/documents   as   required   by   the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

1.

2.

3.

  1. (a) *I/we report the following observations/ comments / discrepancies / inconsistencies; if any:

…………………………………….

…………………………………….

  1. (b) *I/we further report that, –

(A) *I/we have obtained all the information and explanations which, to the best of *my/our knowledge and belief, were necessary

for the purpose of the audit/ information and explanations which, to the best of *my/our knowledge and belief, were necessary for the

purpose of the audit were not provided/partially provided to us.

(B) In *my/our opinion, proper books of account *have/have not been kept by the registered person so far as appears from*my/ our examination of the books.

(C) I/we certify that the balance sheet, the *profit and loss/income and expenditure account and the cash flow Statement are *in

agreement/not in agreement with the books of account maintained    at    the    Principal    place    of    business    at    ……………………and    **

……………………additional place of business within the State.

  1. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be furnished

under section 44(2) of the CGST Act is annexed herewith in Form No. GSTR-9C.

  1. In *my/our opinion and to the best of *my/our information and according to explanations given to *me/us, the particulars given in

the said Form No.GSTR-9C are true and correct subject to following observations/qualifications, if any:

(a) …………………………………………………………………………………… (b) …………………………………………………………………………………… (c) ……………………………………………………………………………………

………………………………………

………………………………………

**(Signature and stamp/Seal of the Auditor)

Place: ……………

Name of the signatory ………………… Membership No………………

Date: ……………

Full address ………………………

  1. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the

person who had conducted the audit of the accounts:

*I/we report that the audit of the books of accounts and the financial statements of M/s.

………………..…………………. (Name and address of the assessee with GSTIN) was conducted by M/s. …………………………………………..……….

(full name and address of auditor along with status), bearing membership number in pursuance of the provisions of the …………………………….

Act, and *I/we annex hereto a copy of their audit report dated

……………………………. along with a copy of each of :-

(a) balance sheet as on ………

(b) the *profit and loss account/income and expenditure account for the period beginning

from ………..…to ending on …….,

(c) the cash flow statement for the period beginning from ……..…to ending on ………, and

(d) documents declared by the said Act to be part of, or annexed to, the *profit and loss account/income and expenditure account and balance sheet.

  1. I/we report that the said registered person—

*has maintained the books of accounts, records and documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

*has not maintained the following accounts/records/documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

1.

2.

3.

  1. The documents required to be furnished under section 35 (5) of the CGST Act and Reconciliation Statement required to be

furnished under section 44(2) of the CGST Act is annexed herewith in Form No.GSTR-9C.

  1. In *my/our opinion and to the best of *my/our information and according to examination of books of account including other

relevant documents and explanations given to *me/us, the particulars given in the said Form No.9C are true and correct subject

to the following observations/qualifications, if any:

(a) …………………………….…………………………….……………………… (b) …………………………….…………………………….……………………… (c) …………………………….…………………………….………………………

………………………………………

**(Signature and stamp/Seal of the Auditor)

Place: ……………

Name of the signatory ………………… Membership No………………

Date: ……………

Full address ………………………‖.

[F. No. 349/58/2017-GST (Pt.)]

(Gunjan Kumar Verma) Under Secretary to the Government of India

Note:- The principal rules were published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i) vide notification No. 3/2017-Central Tax, dated the 19th  June,

2017, published vide number G.S.R 610 (E), dated the 19th  June, 2017 and last amended vide notification No. 48/2018-Central Tax, dated the 10th September, 2018, published vide number G.S.R 859 (E), dated the 10th September, 2018.

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CA Ankit Gulgulia (Jain)

He is Founder Member at AGA Advisory, Practicing Chartered Accountant, Editor in Chief at Chartered Online and Fellow Member of ICAI. AGA has been Handling matters related to Taxation, Audits, Assurances, Corporate Laws and Finance field etc since 2010 with clients across multiple domains & cities. He has authored Books, panelled on TV-Talk Shows and conducted seminars / Trainings at various forums. Link to Complete Profile of AGA and CA Ankit Gulgulia (Jain)

CA Ankit Gulgulia (Jain)
About CA Ankit Gulgulia (Jain) 1082 Articles
He is Founder Member at AGA Advisory, Practicing Chartered Accountant, Editor in Chief at Chartered Online and Fellow Member of ICAI. AGA has been Handling matters related to Taxation, Audits, Assurances, Corporate Laws and Finance field etc since 2010 with clients across multiple domains & cities. He has authored Books, panelled on TV-Talk Shows and conducted seminars / Trainings at various forums. Link to Complete Profile of AGA and CA Ankit Gulgulia (Jain)

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