Various Disclosures to be made in GST Audit Report

GST Audit Report: Recent Updates

Since the GST Laws are everchanging for making them more viable for the taxpayers the government has notified certain disclosures to be made in the GST Audit Report by the auditor while conducting the audit. However, the GST Audit due date  for FY 2017-18 again extended for the taxpayers but these disclosures are must to be filed and reported.

List of Disclosures to be included in GST Audit Report:

There are around 60 disclosures that are to be incorporated in a GST Audit Report by the auditor. The list of disclosures is as follow-

  • Disclosure 1: For true and fair disclosure notes are to be provided in Form GSTR-9C.
  • Disclosure 2: Notes to be given in Para-2 of Form GSTR-9C.
  • Disclosure 3: Basis for conducting the GST Audit.
  • Disclosure 4: Reporting the Financial Year and Aggregate Turnover for the Fiscal Year 2017-18 in Table 5A.
  • Disclosure 5: Financial Year and the commenced business during the particular year.
  • Disclosure 6: Business closures during the year.
  • Disclosure 7: Details of additional place of business whose turnover was considered in the GST Return but it was not included in the Registration Certificate.
  • Disclosure 8: If there are Multiple Registrations in a state then turnover of each one of them is to be mentioned in Table 5A.
  • Disclosure 9: In case the taxpayer has activities at multiple states, then the available trial balance is to be shown in the GST Audit Report.
  • Disclosure 10: In case trial balance is not available for taxpayer having multi state activities, it is to be mentioned as well.
  • Disclosure 11: Revenue for the beginning of the year that were unbilled have to be shown in Table 5B.
  • Disclosure 12: Unadjusted advances at the beginning of the year are to be reported in Table 5C and at the end of the financial year are to be mentioned in Table 5I.
  • Disclosure 13: The deemed supplies are to be mentioned in Table 5D of the GST Audit Report.
  • Disclosure 14: In Table 5E the credit notes that were issued at the end of the fiscal year but not reflected and disclosed in the annual returns for Financial Year 2017-18 are to be reported.
  • Disclosure 15: Credit notes that were issued after the end of the financial year but not disclosed in the annual returns for the fiscal year 2018-19 have to filed in Table 5E.
  • Disclosure 16: Trade discounts that were accounted in the annual return filing but were not permissible under Goods and Services Tax have to be mentioned in Table 5F.
  • Disclosure 17: In Table 5G of the GST Audit Report, turnover for the period April 2017 to June 2017 in the Fiscal Year 2017-18 has to be reflected.
  • Disclosure 18: Unbilled revenue at the end of the financial year in Table 5H.
  • Disclosure 19: Credit Notes that were accounted in the audited annual financial statements but were not permissible under GST have to be mentioned in Table 5J.
  • Disclosure 20: Turnover for the period that was under composition scheme is to be mentioned in Table 5L.
  • Disclosure 21: The cash sales and the composition scheme period turnover are to be mentioned in Table 5L of the GST Audit Report.
  • Disclosure 22: Any adjustments in turnover under section 15 and rules thereunder in Table 5M.
  • Disclosure 23: Adjustments made due to fluctuations in foreign exchange in Table 5N.
  • Disclosure 24: Sales of any fixed assets in Table 5O of the GST Audit Report.
  • Disclosure 25: Adjustments made in the turnover due to any other reason that is not listed above for financial years 2017-18 and 2018-19 in Table 5O.
  • Disclosure 26: In Table 7B of the GST Audit Report mention the value of Nil-rated, exempted, no supply, Non-GST supply turnover.
  • Disclosure 27: No supplies in Table 7B.
  • Disclosure 28: Any Zero-rated supply without any tax payments in Table 7C.
  • Disclosure 29: Report the RCM to be paid by the recipients in Table 7D.
  • Disclosure 30: Tax liability on outward supplies rate-wise in Table 9.
  • Disclosure 31: Reporting the payment of interest in Table 9L.
  • Disclosure 32: Reporting the penalties in Table 9N.
  • Disclosure 33: Any additional tax liability recommendations in Table 11.
  • Disclosure 34: Input Tax Credit of multiple state registrations.
  • Disclosure 35: Input Tax Credit of a single GSTIN entity.
  • Disclosure 36: Input Tax Credit for taxpayers providing the cash system accounting.
  • Disclosure 37: Trans-credit in Table 12B of the GST Audit Report.
  • Disclosure 38: Any ITC claimed in the current financial year but was booked earlier in the previous financial year in Table 12B.
  • Disclosure 39: Goods in the transit and ITC on them in Table 12C.
  • Disclosure 40: In Table 12C, mention the ITC that is to be claimed in subsequent year but has been booked in the current financial year.
  • Disclosure 41: Reversal of ITC and the 180 days, time period is to be mentioned in the GST Audit Report by the auditor.
  • Disclosure 42: Ineligible Input Tax Credit and the exempted turnover.
  • Disclosure 43: Input Tax Credit as per GSTR-2A and GSTR-9C.
  • Disclosure 44: Credit Notes and ITC availed as per GSTR-2A and GSTR-9C.
  • Disclosure 45: A PDF copy of the contents in Table 8A to 8D have to be attached along with the GSTR-9C.
  • Disclosure 46: ITC is to be reported in Table 12C.
  • Disclosure 47: Reporting the RCM in the financial year 2017-18.
  • Disclosure 48: Reporting the RCM in the financial year 2018-19.
  • Disclosure 49: Reporting of RCM.
  • Disclosure 50: Reporting of RCM in the financial year 2017-18.
  • Disclosure 51: ITC that is expense head-wise is to be reported in the GST Audit Report in Table 14.
  • Disclosure 52: In Table 12C, the reconciliation of declared ITC in annual return Form GSTR-9 with availed ITC on expenses according to the books of accounts have to be mentioned.
  • Disclosure 53: Accounting treatments and disclosing the ITC on GST.
  • Disclosure 54: Accounting treatment and disclosure about the capital goods and ITC.
  • Disclosure 55: Any non-taxable miscellaneous outward supplies that are not included in the taxable value of the inward supplies.
  • Disclosure 56: Capital assets inward supplies like motor car not included in the taxable value of inward supplies.
  • Disclosure 57: Turnover in the URD Period included in the GST Audit Report.
  • Disclosure 58: Non-GST turnover of the petrol pump taxpayers in motor spirits.
  • Disclosure 59: Stock registers that are non-maintained.
  • Disclosure 60: Converting a firm to partnership from proprietorship.

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    Author: Anil Agrawal
    EZYBIZ India Consulting LLP, New Delhi. The firm is business and tax consultancy firm providing consultancy in Taxation, Regulatory, Transfer pricing, Valuation, Corporate funding and Business set up matters. He may be reached at 9899217778 or anil@ezybizindia.in.