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Analysis of taxable Outward Supply in Form GSTR-9

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In our previous blog we have highlighted the key aspects of the Annual Return GSTR-9. We'll now take up the sections of GSTR 9 for detailed analysis.

This blog focuses on the Outward supply details to be included in GSTR 9

Outward Supply Details in GSTR 9 

Table 4 of GSTR 9 requires reporting of details related to taxable outward supplies (except Sl No G which relates to inward supplies which attract GST under reverse charge) like:

  1. Supplies made to unregistered Persons (B2C)
  2. Supplies made to Registered Persons (B2B)
  3. Zero rated supply (Export) on payment of tax (except supplies to SEZs)

  At the time of preparation of GSTR 9, whether the details required to be reported at Part 4 should be:

  1. Restricted to details reported in the GSTR 1 for the period July 2017 to March 2018; or
  2. Should include all the details pertaining to the period July 2017 to March 2018 irrespective of the period (Maximum period September 2018) when such details are reported in GSTR 1.

 

Based on the combined reading of Table 4 and Table 5 (Sl No 10 and 11) and the instructions related to these entries, one possible view is that:

  1. Invoices related to 2017-18 reported in any month in the GSTR 1 during 2017-18 along with Amendments relating to 2017-18 made by reporting such amendment in any subsequent month but within 2017-18 itself would be reported at Table 4 of GSTR 9; and
  2. Amendments to invoices related in any month in the GSTR 1 during 2017-18 made by reporting such amendment in the GSTR 1 during the months period April 2018 to September 2018 would only be reported in Part VI Sl.No. 10 of GSTR 9.

 

Table 4 of GSTR 9 contain Details of advances, inward and outward supplies on which tax is payable as declared in returns filed during the financial year

 

Sl.No. 4A. Supplies made to unregistered Persons (B2C)

 

Aggregate value of supplies made to consumers and unregistered persons on which tax has been paid shall be declared here. These would include details of supplies made through E-Commerce operators and are to be declared as net of credit notes or debit notes issued in this regard.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4A would be as follows:

 

Category of supply

Nature of supply

Relevant Table of GSTR 1

taxable outward inter-State supplies to unregistered Persons where the invoice value is more than Rs. 2.5 lakh (both through electronic commerce operator and otherwise)

Inter-State

Table 5

taxable supplies (Net of debit notes and credit notes) to unregistered Persons other than the supplies covered in Table 5 where the invoice value is up to Rs. 2.5 lakh (both through electronic commerce operator and otherwise)

Inter-State

Table 7

taxable supplies (Net of debit notes and credit notes) to unregistered Persons other than the supplies covered in Table 5 (both through electronic commerce operator and otherwise)

Intra-State

Table 7

Amendments to taxable outward supply details furnished in returns for earlier tax periods in Table 5 [including debit notes, credit notes, refund vouchers issued during current period and amendments thereof]

Inter-State

Table 9

Amendments to taxable outward supplies to unregistered Persons furnished in returns for earlier tax periods in Table 7

Both inter and intra-State

Table 10

 

 

Sl. No. 4B. Supplies made to Registered Persons (B2B)

Aggregate value of supplies made to registered persons (including supplies made to UINs) on which tax has been paid shall be declared here. These would include supplies made through E-Commerce operators but shall not include supplies on which tax is to be paid by the recipient on reverse charge basis. Details of debit and credit notes are to be mentioned separately.

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4B would be as follows:

 

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

taxable outward supplies to Registered Persons (including supplies made to UINs) other than those attracting reverse charge and supplies through e-commerce operators

Both inter and intra-State

Table 4A

taxable Outward Supplies to Registered Person through e-commerce operators

Both inter and intra-State

Table 4C

 

Sl. No. 4C. Zero rated supply (Export) on payment of tax (except supplies to SEZs)

4C of GSTR 9 contains information relating to a sub-set of all zero-rated supplies comprising of exports of goods and exports of services out of India. 4C does not include supplies to SEZ. Further, exports are permitted in two ways, namely, export with payment of tax and export without payment of tax. 4C contains information pertaining only to exports on payment of tax and not exports without payment of tax.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4C would be as follows:

 

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Aggregate Value of Exports (excluding supplies to SEZs) on which tax has been paid

Inter State

Table 6A

 

4D. Supply to SEZs on payment of tax

4D of GSTR 9 contains information relating to a sub-set of all zero-rated supplies comprising of supplies to SEZ being a Developer of the SEZ or a Unit in the SEZ. It would include supplies to SEZ whether by an SEZ to another SEZ or by a DTA unit to SEZ. 4D does not include supplies to SEZ without payment of tax.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4D would be as follows:

 

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Aggregate Value of supplies to SEZs on which tax has been paid

Inter State

Table 6B

 

Sl. No. 4E. Deemed export

 

4E of GSTR 9 contains information regarding ‘deemed export’. Section 147 allows the Government to notify certain supply of goods to be deemed exports where the goods supplied do not leave India and the payment for such supplies is received either in Indian rupees or in convertible foreign exchange if such goods are manufactured in India. The deeming fiction of this kind of supply as deemed export allows a person to enjoy all the tax benefits as available in case of zero-rated supply.

 

Section 147 and NN 48/2017-Central tax dated 18th October 2017, prescribes the following supplies to be regarded as deemed exports:

(a) Supply of goods against advance authorization

(b) Supply of capital goods against EPCG authorization

(c) Supply of goods to EOU (export-oriented undertakings)

(d) Supply of gold by bank/PSU specified in Notification no. 50/2017-Customs dated 30th June 2017

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4E would be as follows:

 

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Aggregate value of supplies in the nature of deemed exports on which tax has been paid

Inter State

Table 6C

 

 

Sl. No. 4F. Advances on which tax has been paid but invoice has not been issued

4F of GSTR 9 contains details of advances received in certain special circumstances. As per rule 50, upon receipt of advance, Receipt Voucher is required to be issued but tax Invoice is not required to be issued until actual supply in respect of said advance. Tax is payable on advance even though supply is pending. 4F to contain details of advances received and tax Invoice is yet to be issued.

Refer NN 40/2-17-CT dated Oct 13, 2017 that exempted payment of tax on advances received towards supply of goods, in case of taxable persons whose aggregate turnover is or is likely to be less than Rs.1.50 cr. Advances towards supply of services remained liable to payment of tax on advances. Suppliers of goods above this threshold limit also were liable to payment of tax on advances.

Refer NN 66/2017-CT dated Nov 11, 2017 that exempts from payment of tax on advances received towards supply of goods. As such, advances should have been subject to tax payment in all cases up to Nov 10, 2017 and in respect of advances relating to supply of services without the benefit of this exemption.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4F would be as follows:

 

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Advance received, and tax has been paid but invoices has not been issued in the current year

Both inter and intra state

Table 11A

 

 

4G. Inward supplies on which tax is to be paid on reverse charge basis

 

4G in GSTR 9 contains details of inward supplies in respect of which Registered Person is liable to pay tax on reverse charge basis.

Reverse charge provisions are guided through section 9(3) and 9(4) of the CGST Act in case of intra state supplies. In case of inter-state supplies, the corresponding sections of 5(3) and 5(4) of the IGST Act would be applicable.

Refer NN 8/2017-CT(R) dated Jun 28, 2017 exempts intra-State supply of goods or supply of services does not exceed Rs.5,000/- per day regardless of number of suppliers involved. Refer NN 38/2017-CT(R) dated Oct 13, 2017 which excluded the value limit previously prescribed. Corresponding Integrated tax exemption was issued for the first time in NN 32/2017-Int(R) dated Oct 13, 2017 in respect of inter-State supplies.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 3.B. The various components of this Part 4G would be as follows:

Category of Supply

Nature of Supply

Relevant Table of GSTR 3B

Aggregate value of all inward supplies (including advances and net of credit and debit notes) on which tax is to be paid on reverse charge basis

Both inter and intra state

Table 3.1(d)

 

 

Sl. No. 4I. Credit notes issued in respect of transactions specified in (B) to (E) above

4I in GSTR 9 contains details of credit notes in respect of outward supplies in 4B to 4E of GSTR 9. Credit notes dated before Mar 31, 2018 alone is required to be reported and not Credit notes relating to 2017-18 but issued in 2018-19.  Aggregate value of credit notes issued in respect of B to B supplies (4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E) shall be declared here.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4H would be as follows:

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Aggregate Value of Credit Notes issued in respect of B2B supplies, Exports, Supplies to SEZs, Deemed Exports

Both inter and intra state

Table 9B

 

Sl. No. 4J. Debit notes issued in respect of transactions specified in (B) to (E) above

4J in GSTR 9 contains details of debit notes in respect of outward supplies in 4B to 4E of GSTR 9. Debit notes dated before Mar 31, 2018 alone is required to be reported and not debit notes relating to 2017-18 but issued in 2018-19. Aggregate value of debit notes issued in respect of B to B supplies (4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E) shall be declared here.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4J would be as follows:

Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Aggregate Value of Debit Notes issued in respect of B2B supplies, Exports, Supplies to SEZs, Deemed Exports

Both inter and intra state

Table 9B

 

 

Sl. No. 4K and 4L. Supplies / tax declared through amendments

4K

Supplies / tax declared through Amendments (+)

4L

Supplies / tax reduced through Amendments (-)

 

Details of amendments made to B to B supplies (4B), exports (4C), supplies to SEZs (4D) and deemed exports (4E), credit notes (4I), debit notes (4J) and refund vouchers shall be declared here. Table 9A and Table 9C of FORM GSTR-1 may be used for filling up these details.

 

As per section 39(9) of the CGST Act, if any Registered Person discovers any omission or incorrect particulars, he can rectify such omission or incorrect particulars in the return to be furnished for the month during which they are noticed.

Further, Circular no. 26/26/2017-GST dated Dec 29, 2017 prescribes the procedure for a person to correct any error or omission made in his GSTR 3B and GSTR 1. It is important to note that declaration of omissions and amendment to declaration already made are permitted in any subsequent month even in the returns of Apr to Sept 2018.

Such declarations and amendments by transposing from one month to another but within 2017-18 must be reported here. Continuation of such declaration and amendments in 2018-19 of data relating to 2017-18 is not permitted in point 4K. It is required to be carried in Pt. V point 10 and 11, as applicable.

 

The amounts that are to be reported can be directly derived from the Tables of GSTR 1. The various components of this Part 4K and 4L would be as follows:


Category of Supply

Nature of Supply

Relevant Table of GSTR 1

Amendments made in B2B supplies, exports, SEZ supplies, deemed exports due to incorrect invoice or shipping bills furnished earlier

Both inter and intra state

Table 9A

Amendments made in credit notes, debit notes and refund vouchers

Both inter and intra state

Table 9C




The implementation of GSTR 9 in GST system is in progress and once available for taxpayers and GSPs. Stay tuned with us for updates on GSTR 9. 

IRIS Business is a leading GST Suvidha Provider (GSP) providing easy and efficient solutions for GST (IRIS Sapphire) and E-way bill (IRIS Topaz) compliance. To have your GSTR-9 queries solved and to know more about our solution for filing GSTR-9, please contact us at support@irisgst.com or  +91 22 6723 1000

About Manoj Jain

Manoj Jain, a CA and CS, has been working with IRIS for over 8 years and is currently one of the key subject matter experts for IRIS’ GST compliance offerings. He also has been guiding the clients for GST law related matters. Before GST he was handling US compliance analyzing US financial statements and reviewing XBRL filings for US and India market. He enjoys listening to music and traveling.

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