PART I: GST AUDIT REPORT COMMENTARY

Goods and Services Tax – GST – By: – AttnVivek Jalan – Dated:- 20-9-2018 – Part I: Commentary on Features of Audit Report under GST – Form 9C Form GSTR – 9C has been divided into 2 parts: Part – A: Reconciliation statement; Part – B: Certification by auditor; We hereby analyse Pt II as under – Part A : Pt II : Reconciliation of turnover declared in audited annual financial statement with turnover declared in annual return (GSTR – 9) 5A: Entities having multiple GSTIN s will have to derive their GSTIN wise turnover which has been reported in the financial statements for its reconciliation with the annual return. For Eg: an entity having Registrations in West Bengal (WB), Haryana (HY), Maharashtra(MH) and Karnataka(KT) and it is preparing the report for MH, then it has to deduct the turnovers of other states to arrive ah MH s turnover. It is specifically mentioned that reference to audited Annual Financial Statement includes reference to books of accounts in case of persons / entities h

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s it has not been taken in turnover; the same needs to be disclosed here. 5D: Details of supplies falling under Schedule I of the CGST Act, 2017 on which tax has been paid but not included in turnover reported in annual audited financial statements. For example, inter-branch transfers of goods, Principle to Agent Supply, Free Issues taxable under GST, etc. It is important to note that incase any transaction has been skipped but it is liable to tax, it also needs to be reported here. 5E: Identification of invoices issued in the relevant financial year for which credit notes have been issued in the subsequent financial year. The same is also required to be collated for table no. 11 of annual return (GSTR 9). For Eg: It is to be noted that only those Credit Notes which result in a difference between books and Annual return needs to be disclosed here. 5F: Trade discounts which are accounted for in the audited Annual Financial Statement but on which GST was leviable (being not permissible)

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ference in valuation of supplies shall be declared here. Eg: incase of Forex dealers, Race Courses, sellers of Lottery tickets, etc where special valuation methods are adopted. 5N: Any difference between the turnover reported in the Annual Return (GSTR 9) and turnover reported in the audited Annual Financial Statement due to foreign exchange fluctuations shall be declared here. The difference due to Forex fluctuations do not effect GST turnover as under Rule 34 GST is paid at specific Forex rates. 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. Eg: On sale of Capital Goods, only profit/loss is recognized in Financial Statements, although under GST, Tax is paid on full amount. The final turnover derived post addition / deletion of above details should match with the turnover disclosed in the annual returns. In case there is a difference be

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