19 Nov 2019Posted By: Mudit Handa

CBIC clarifies on Optional filing of Annual GST return

During the 37th GST Council meeting that was held on 20th September 2019, the Annual GST return was made optional. The annual GST return filing procedure in the Form GSTR-9 that was hitherto mandatory, had been waived off for all those taxpayers having GST registration whose aggregate turnover was not more than ₹2 crores.

In this regard, the Central Board of Indirect Taxes and Customs (CBIC) has now clarified regarding the Optional filing of the Annual GST Return in Form GSTR-9 and GSTR-9A for FY 2017-18 as well as 2018-19, for all those tax assessees having the GST registration and whose turnover is up to ₹ 2 crores. The CBIC has explained about the special provision for such registered persons.


1. What is the new provision of annual GST return filing?

It has been clarified by CBIC, that even if-

The annual return in Form GSTR-9 for FY 2017-18 and 2018-19 has not been furnished within the due date, by those registered persons whose annual turnover is up to ₹2 crores

The said annual GST return shall be deemed to have filed within the due date only.

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2. Whether the composition taxpayers need to file GSTR-9A? 

As per the notification, for the individuals having GST registration under the composition scheme, whose annual turnover is up to ₹2 crores, the annual GST return filing for FY 2017-18 and 2018-19 has been made optional. 

The taxpayers paying composition tax u/s 10 of the CGST Act 2017, may voluntarily file the FORM GSTR-9A for the FY 2017-18 and 2018-19. 

3. Whether the tax deductors/collectors need to file GSTR-9?

No, for the tax deductors u/s 51 and tax collectors u/s 52 of CGST Act 2017, whose annual turnover is up to ₹2 crores, the annual GST return filing for FY 2017-18 and 2018-19 has been made optional.

They may voluntarily file the FORM GSTR-9 for the FY 2017-18 and 2018-19.

4. What if I file the annual GST return after the current due date?

As per the CBIC’s clarification, if the annual GST returns are filed by the taxpayers whose annual turnover is up to ₹2 crores, after the current due date, there will be no late fee charged. 

However, after the current due date, the GST portal shall not permit the filing of the annual GST returns in FORM GSTR-9 for the said period.

5. What is the current due date for annual GST return filing?

The current due date for annual GST return filing is as below:

  • FORM GSTR-9 for the FY 2017-18: 31st December 2019.
  • FORM GSTR-9 for the FY 2018-19: 31st March 2020.

6. Whether there is a relief for filing of GST Audit report?

No, there is no relief given for the filing of GST Audit report (Reconciliation Statement) in the Form GSTR-9C. The GST Audit report is applicable for those taxpayers having GST registration whose annual turnover exceeds ₹ 2 crores.

Accordingly, it is mandatory to file Annual GST return in Form GSTR-9 for such taxpayers.

Moreover, the Annual GST return filing procedure has been simplified.

If you need any assistance regarding the annual GST return filing procedure, or the GST audit report please feel free to contact our business advisor at 8881-069-069.

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