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GST Audit

 

Did you know the Indian government recently released the 2023 Model All India GST Audit Manual? This comprehensive guide outlines best practices for both tax authorities and businesses navigating the often-daunting world of GST audits.

This in-depth newsletter from us should equip you with a comprehensive playbook to navigate the GST audit landscape stress-free. We'll delve into the intricacies of the audit selection process, dissect the various stages involved, and provide actionable insights to mitigate potential risks.

GST Audit Form and Applicability:

GSTR-9C is a form for annual GST reconciliation statements filed by applicable taxpayers. Every registered person whose aggregate turnover during a financial year exceeds Rs.5 crore rupees must file this form. They shall also furnish a copy of the audited annual accounts.

What is GSTR-9C?

GSTR-9C is a statement of reconciliation between:

  • The annual returns in form GSTR-9 filed for a FY, and

  • The figures are as per the audited annual financial statements of the taxpayer.

It will consist of gross and taxable turnover as per the Books reconciled with the respective figures as per the consolidation of all the GST returns for a FY. 

Hence, any differences arising from this reconciliation exercise will be reported in this statement, along with the reasons for the same and then certified by the taxpayers themselves. The certified statement shall be issued for every GSTIN. Hence, for a PAN, there can be several GSTR-9C forms to be filed.

GSTR-9C must be prepared and self-certified by the taxpayer. It must be filed on the GST portal or through a facilitation center by the taxpayer, along with other documents such as a copy of the Audited Accounts and Annual Return in form GSTR-9. This statement applies to all those taxpayers who must get their Annual Accounts audited under the GST laws. 

 

What is the Due Date for GSTR-9C?

The due date to file GSTR-9C is the same as the due date for submitting the Annual returns in GSTR-9. Hence, the GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant FY under audit. The due date can be extended by the Government if deemed necessary. For instance, the GSTR-9C due date for FY 2023-24 is 31st December 2024.

What is the reason for the GST audit?

Let's face it, a GST audit notice can feel like a punch to the gut. The initial worry is natural – have we made a mistake?  But before you lose sleep over missing paperwork or forgotten tax payments, let's take a deep breath and understand the rationale behind these audits.

The Indian tax authorities aren't out to get you. Instead, GST audits serve several crucial purposes designed to ensure a healthy and fair tax ecosystem for everyone. 

Here are some of the key reasons why your business might be selected for an audit:

  • The primary objective of a GST audit is to verify that your business is adhering to the provisions of the CGST Act. This involves scrutinizing your GST Returns to ensure they accurately reflect your income and expenses, and that you're claiming input tax credit (ITC) legitimately.

  • Sometimes, unintentional errors or inconsistencies can creep into your return filings. An audit acts as a safety net (for the GST Council anyway) to catch these discrepancies before they snowball into larger issues. We like to think of it as a friendly financial checkup to identify areas for improvement.

  • Not everyone plays by the rules. GST audits act as a deterrent against tax evasion. The routine checkups, after selecting businesses for scrutiny, send a strong message that non-compliance will be detected and addressed.

  • A robust tax system relies on fairness. GST audits help ensure that all businesses, big and small, are adhering to the same tax regulations. This creates a level playing field for everyone, fostering healthy competition within the market.

  • While an audit might seem adversarial at first, it can foster a more collaborative relationship with the tax authorities.

GST Audit Manual 2023

The Model Audit Manual GST was introduced in April 2023, to provide an important reference point for audit principles, practices and procedures for GST audit practitioners across the country.

The benefits, however, extend beyond the business community.  For tax authorities, the manual establishes a standardized framework for conducting GST audits. This ensures consistency across different states, streamlining internal operations within the tax department and fostering fairness in the audit process itself.

Furthermore, the manual paves the way for a more collaborative environment.  By clearly defining roles and procedures, it lays the groundwork for open communication between businesses and tax authorities. This spirit of collaboration can ultimately lead to a more efficient and effective tax system for all stakeholders.

Some Strategies for a Smooth GST Audit

  1. Meticulous record-keeping is the foundation of a smooth audit. Ensure your books of accounts (including ledgers, journals, and cash books) are meticulously maintained, up-to-date, and readily accessible.

  2. Embrace digitalization. Consider using accounting software or cloud storage solutions to streamline record keeping and facilitate easy retrieval of documents during an audit.

  3. Organize meticulously. Systematically categorize all documents related to purchases, sales, tax payments, advances, and ITC claims. This ensures auditors can efficiently locate the information they need.

  4. Retain everything. Don't discard invoices, receipts, debit/credit notes, or bank statements for at least the statutory period mandated by the CGST Act (at least 72 months). These documents serve as vital evidence to support your tax filings.

  5. Double-check your GST Returns through reconciliation (especially GSTR-1 and GSTR-3B) as even minor errors or inconsistencies can raise red flags for the authorities. So, conduct thorough reviews to eliminate discrepancies or missed information.

  6. Pay close attention to the rules governing input tax credit (ITC) claims and ensure that all claims are supported by valid invoices.

As we wrap up this newsletter, we recommend taking a look at the 2023 Model All India GST Audit Manual, as it serves as a valuable resource for businesses undergoing an audit. It equips you with a clear roadmap for navigating the audit process.

But if that feels like a lot of commitment, and you're feeling overwhelmed at the thought of doing this alone, then don't do it alone.

JJ Tax understands the complexities of navigating the GST landscape, including audits. That's why we offer a comprehensive range of services to empower Indian businesses:

You can chat with our experts directly through our website jjfintax.com/ or via our mobile app available on both the Play Store and App Store. Stay informed!

Stay compliant, stay informed, and stay ahead — with JJ Tax by your side.