Decoding GSTR 9A

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Section 44 read with proviso to Rule 80(1) stipulates that a person paying tax under the composition scheme is required to file the Annual Return in Form GSTR 9A within the due date specified under the Act. Initially, the data which has been specified in the Act is 31st​​ December for the filing of GSTR 9A which has been extended firstly to 31st​​ March 2019 vide Order No. 1/2018​​ ​​ Central tax dated 11th​​ December 2018 and further extended to 30th​​ June 2019 vide Order No. 3/2018​​ ​​ Central tax dated 31st​​ December 2018.

Whether Composition supplier requires to get his Accounts audited under the GST Act?

No, as per the provisions of Section 10(1), the person can avail the Composition scheme only when the turnover did not exceed Rs. 1.5 Crores in the preceding FY and the provisions of audit are applicable to the suppliers whose turnover exceed Rs. 2 Crores. Hence, the Audit provisions do not apply to the Composition suppliers.

Whether a NIL return can be filed?

Yes, a NIL return can be filed if the Composition supplier has:-

  • Not made any composite supply

  • Not received any inward supply

  • No late fee payable

Whether Annual return to be filed when registered as Normal tax able person during the relevant FY

Even if the taxable person is registered for a single day as composition dealer, the dealer is required to file GSTR 9A.

For instance​​ ​​ Mr. X is registered as normal taxable person from 1st​​ July 2017 to 31st​​ December 2017 and afterwards, he opts for the composition scheme. In this case, Mr. X has to file the GSTR 9 for the period 1st​​ July 2017 to 31st​​ December 2017 and GSTR 9A for the period 1st​​ January 2018 to 31st​​ March 2018.

Analysis of Form GSTR 9A

Form GSTR 9A has been divided into 5 parts and 17 tables. Let’s analyse the form part wise.

Part I​​ ​​ Basic details