GST Refunds on Exports

Types of disclosures GST Auditor can make in GST Audit Report

Form GSTR-9C: Where to put reasons, comments, observations and qualifications in GST Audit Report

  • The reasons for un-reconciled differences have to be put in Table 6, Table 8, Table 10, Table 13 and Table 15 of Form GSTR-9C.
  • The maintained books of accounts are reported in the Para 2, in Part-B Certification in Form GSTR-9C. In case, the same has not been maintained then a comprehensive list of documents are to be maintained under Section 35 read with Rule 56 to Rule 58 of the Central Goods and Services Tax (CGST) Act, 2017. This list is not exhaustive therefore, a person having GST Registration has to likely maintain additional documents, registers and records for supporting the GST Returns, Input Tax Credits and GST Payments. The list of documents are as follows-
  • Stocks of goods
  • Payable and paid output taxes
  • Availed Input Tax Credit
  • Received and paid advances and adjustments thereof
  • Imported and exported Goods and Services
  • Inward supply and outward supply of goods and services or both
  • Supplies that attract tax payments based on reverse charge mechanism supported by relevant documents like-
  • Credit notes
  • Debit notes
  • Refund vouchers
  • Supply bills
  • Purchase bills
  • Invoices and receipts
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Disclosures to be made in Form GSTR-9C:

  • Disclosure 1: Notes for disclosing the True and Fairness in Form GSTR-9C

The terms “True and Correct” has been substituted by the word “True and Fair” as per the new Notification No. 56/2019 issued on 14th November, 2019. The GST Auditor has to audit the books of accounts and the financial statements of the company to verify its correctness for making disclosures in the GST Audit Report. The same has to be filed in the Form GSTR-9C and is to be certified by a Chartered Accountant for its correctness. Also, the Notification No. 56/2016, provides the cases for which the cash flow is available for the company.

Related Articles: Various Disclosures to be made in GST Audit Report

  • Disclosure 2: Notes on Para 2 in Form GSTR-9C
  • The record of proper maintenance of books of accounts and the documents provided in Section 35 read with Rule 56 to Rule 58 of the CGST Act, 2017 are to be provided by the taxpayer. The auditor has to examine them thoroughly and is to be disclosed in Form GSTR-9C.
  • The stocks of goods for which the statement of stock memorandum has been prepared are not considered in the above stated Sections and rules.
  • Documents of all the supplies attracting tax payments based on the reverse charge mechanism that are partially maintained by the company and along with these all the relevant documents such as the credit notes, debit notes, bills of supply, bills of purchases, refund vouchers, invoices and receipts are to be examined by the auditor and disclose the same in Form GSTR-9C.
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The auditor has to consider the management’s furnished information and explanation and then provide their opinions about the same for its materiality.

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