Annual Return GSTR-9A: Understanding Past Applicability, Deadlines, Penalties, and Format
This article explores GSTR-9A, the annual Goods and Services Tax return previously filed by taxpayers registered under the composition scheme in India. It details the form's applicability, filing deadlines, late submission penalties, and required data. While GSTR-9A has been discontinued since the 2019-20 financial year, replaced by a revised GSTR-4, understanding its former requirements offers insight into the evolution of GST compliance for composition scheme dealers.
The Goods and Services Tax (GST) framework requires registered taxpayers, including those operating under the composition scheme, to submit annual returns. The Central Board of Indirect Taxes and Customs (CBIC) initially introduced GSTR-9 for regular taxpayers and GSTR-9A for composition taxpayers, along with specific instructions.
However, GSTR-9A was abolished starting from the financial year 2019-20. It was superseded by a revised GSTR-4 as the annual return for composition taxpayers.
This document provides historical information about GSTR-9A, which was applicable until the financial year 2018-19. It covers:
- What GSTR-9A entailed
- Its applicability criteria
- Associated due dates
- Penalties for delayed submission
- The structure and details required in GSTR-9A
- Guidance on its preparation
- Frequently asked questions
Latest Updates
In the 53rd GST Council meeting held on June 22, 2024, it was suggested that taxpayers with an aggregate annual turnover of up to Rs. 2 crore might be exempt from filing GSTR-9/9A for the financial year 2023-24.
Additionally, the deadline for filing GSTR-4 for the financial year 2024-25 and subsequent years was extended from April 30th to June 30th of the following financial year.
Understanding GSTR-9A
GSTR-9A served as the annual return for taxpayers who opted for the composition scheme under GST during a specific financial year, up to FY 2018-19. This return consolidated all details previously submitted in the quarterly returns by composition taxpayers throughout that financial year.
Applicability of GSTR-9A
All taxpayers registered under the GST composition levy scheme were obligated to file GSTR-9A. However, certain entities were exempted from this requirement:
- Non-resident taxable individuals
- Input Service Distributors
- Casual taxable individuals
- Persons responsible for paying TDS under Section 51 of the Act
- E-commerce operators liable for paying TCS under Section 52 of the Act
GSTR-9A Due Date
GSTR-9A was due on or before December 31st of the year immediately following the financial year for which the return was being filed. For instance, a composition taxpayer filing for FY 2017-18 needed to submit it by December 31st, 2018.
Penalties for Late GSTR-9A Filing
Late submission of GSTR-9A incurred penalties as follows:
| Under CGST | Under SGST/UTGST | Total |
|---|---|---|
| Rs.100 per day of default | Rs.100 per day of default | Rs.200 per day of default |
The maximum daily late fee could not exceed 0.25% of the turnover within the State or Union Territory under CGST/SGST/UTGST.
GSTR-9A Format: Required Details
The GSTR-9A form was structured into several parts, each requiring specific information:
| Sl. No. | GSTR-9A Section | Required Information |
|---|---|---|
| 1 | Part-I | Basic taxpayer details such as GSTIN, legal name, trade name (auto-populated), previous financial year's annual turnover, and the duration of the composition scheme during the year. |
| 2 | Part-II | Summarized details of outward and inward supplies reported in regular quarterly returns (either GSTR-4 or CMP-08) filed throughout the financial year. This section provided a consolidated view from all quarterly submissions. |
| 3 | Part-III | Information regarding the tax paid, as declared in returns filed during the financial year. This included tax paid under various heads like IGST, CGST, SGST, Cess, Interest, Late Fee, and Penalty. |
| 4 | Part-IV | Particulars of transactions from the previous financial year that were declared in returns filed between April and September of the current financial year, or up to the date of filing the annual return, whichever was earlier. This section summarized any amendments or corrections related to prior financial year entries, including additions or omissions. |
| 5 | Part-V | **Additional Information, including:**Particulars of Demands and Refunds: This section required details of any tax demands from the department, tax paid against such demands, and any outstanding amounts. It also included information on refunds claimed, received, and pending.Details of Credit Reversed or Availed: If a taxpayer transitioned between the regular and composition schemes, Input Tax Credit (ITC) adjustments (reversal or addition) were reported here.Late Fee Payable and Paid: Any late fees incurred due to delayed tax payments or return filings were specified in this section. |
Preparing GSTR-9A
The format for Form GSTR-9A was last updated by CGST Notification No. 74/2018 Central Tax on December 31, 2018.
It was crucial to disclose accurate and complete information in the annual return. The data provided in the annual return served as the basis for departmental assessments. Additionally, the annual return offered an opportunity to rectify errors made during the filing of quarterly GSTR-4 or CMP-08, up to FY 2018-19. All information reported in GSTR-9A had to be cross-referenced with financial records and regular returns/forms submitted for the entire financial year.
It's important to note that any additional tax liability not declared in quarterly GSTR-4 or CMP-08 could be reported in GSTR-9A, with tax and interest voluntarily paid using Form DRC-03.