GSTR-9/9C has been enabled in GSTN for F.Y. 2022-23

Author has observed that GST Annual Return in Form GSTR-9 & 9C for F.Y. 2022-23 has been enabled on 16.05.2023 in GSTN (www.gst.gov.in).

Author has filed GSTR-9 for a taxpayer (Corporate as well as Non-Corporate ) and observed the following :

1. Prima facie structurally there is no change in Form GSTR 9.
2. Figures auto-populated in various tables of GSTR-9 based on GST Returns filed are prima facie appearing to be correct. Thorough check is required to be done to reach the assurance as a prudent policy.
3. Data auto-populated in table 8A is as on 30.04.2023 which is after considering GSTR-1/IFF Invoices uploaded up to that date only.
4. Offline utilities for the Form GSTR 9 and GSTR 9C are not updated for the FY 2223.
5. GSTR-9C will be opened after GSTR-9 is filed. Hence, no comment on that as of now.
6. Filing of GSTR 9 won’t be permitted if any of GSTR 1/GSTR 3B are pending for FY 22-23.
7. In AIS/TIS information, GST Returns filing details are updated till 28.02.2023 for each GSTIN Numbers.
8. Data auto populated in Table 8A ( downloadable in ZIP file under annual returns tab) has following issues as of now viz. IGST /CGST/SGST Invoices are not reflected or several invoices are missing all together making it difficult to correlate the data. There appears to be some technical glitch in Table 8A data which may be addressed in future.
9. Data auto populated in Table 8 of GSTR 9 reflects all the data that is appearing in yearly GSTR 2B for FY 2223 correctly as it is observed in some of the sample data sheets

Readers may decide appropriately to plan their compliance suitably. It is recommended to wait for couple of weeks till the prima facie glitches are addressed on the GSTN Portal.

Few important points:

1. The due date of filing Form GSTR-9 & Form GSTR 9C for F.Y. 2022-23 is 31.12.2023 with extreme minuscule chances for any extensions .
2. The requirement of Audit u/s 35(5) by CA/CMA is done away and now it is based on self certification by the RTP.
3. A taxpayers having aggregate turnover as defined u/s 2(6) of CGST Act, 2017 up to INR 2 crores have been exempted from filing GSTR-9 till FY 21-22 but no such notification changing such requirements has been issued for FY 22-23 as of today. Author is of considered view that even if the exemption that would be provided in future, he recommends all the RTPs to file GSTR 9 as per the provisions of GST Act, 2017 as it is a last opportunity to correct any apparent errors/mistakes in GST Returns which needs to be rectified post time limit of 30.11.23 as provided u/s 16(4) of CGST Act, 2017.
4. A taxpayer with aggregate turnover as defined u/s 2(6) of CGST Act, 2017 more than INR 2 crores and up to INR 5 crores is mandatorily required to file GSTR 9 till FY 21-22 but no such notification changing such requirements has been issued for FY 22-23 as of today.
5. A taxpayer with aggregate turnover as defined u/s 2(6) of CGST Act, 2017 more than INR 5 crores has to file both GSTR-9 & 9C till FY 2122 but no such notification changing such requirements has been issued for FY 2223 as of today.