Issues you must check before you sign off GSTR 9C - (Keshav R Garg) B.com, FCA, CS, ISA(ICAI), AMP-IIM-A, LLB
Issues you must check before you
sign off GSTR 9C
(Keshav R Garg)
B.com, FCA, CS, ISA(ICAI), AMP-IIM-A, LLB
Although most of the fields in GSTR 9 and GSTR 9C has been
made optional, it does not mean that as an auditor you can sit back and relax
and sign whatever comes your way. At the outset it must be understood that “optional”
does not mean “not required”, it certainly means that if the necessary data is
available, you must enter that while filing annual returns. Further if it is
becoming time consuming and is something which is making filing of annual
return difficult, you can leave those at the moment. But it is most likely that
the assessing authority would certainly call for these details at the time of
assessment proceedings. So with this background, as an auditor you must
understand that your responsibility has not been waived off, instead it would
be the auditor or the consultant who would have to clarify issues at the later
stage. So what are the check points you should be considering before signing
off GSTR 9C:
1. Understanding the flow of data:
As an auditor it becomes really
important that you understand the flow of data between GSTR 9 and GSTR 9C.
Please do not trust the data flow as being done by your software. It has been
largely found that most of the software are not well equipped and are not
flowing the data in right columns. The wrong coding of the software may lead to
wrong data entry which can prove damaging at the later stage. More than enough
study material is available to understand the data flow. Hence I shall not be
elaborating it again. But certainly readers can reach out to us for any
assistance. It is really important to understand the flow of information
entered in GSTR 1/3B during FY 2018-19 in respect of FY 2017-18. For instance
data in Table 5 of GSTR 9C should flow from summation of Table 4 and Table
10,11,12,13 collectively. Similarly Tax payable in Table 9 of GSTR 9C should flow
from summation of Table 9, 10, 11, and 14 of GSTR 9. So as an auditor it
becomes really very important to correlate GSTR 9 with GSTR 9c, otherwise you
may land up submitting wrong figures.
2. Analyzing the turnover in comparison
to audited Balance Sheet:
Though its your duty as an auditor to
verify the records of the auditee. But at the same time you must define the
boundaries for your work. You should not step out and interfere in the audit
function carried out by the statutory auditor of your client. So restricting
yourself to the figures posted in audited balance sheet, you must conduct your
audit around it. There might be several cases where the client would not have
paid GST on a supply he had been making. For instance rent received on
commercial property, commission income etc. These all can be verified only from
the audited balance sheet and annexures along with income tax return. There is
a high possibility that the turnover declared does not include these other
incomes as the former becomes part of the Trading Account whereas the latter is
reflected in P&L. Also as an auditor you must check whether there are any
valuation issues which is resulting into unreconciled turnover in GSTR 9C. For
instance for purposes of GST, Freight charged from customer becomes part of
value of supply, but while preparing books of accounts, statutory auditors
might have classified the same under the head freight instead of sales. These
all possibilities must be well worked out before you actually freeze the
figures.
3. Details of rate wise liability in
terms of HSN Codes:
The rates of GST has been changing
very often especially during FY 2017-18. It becomes important that the turnover
of the auditee must be properly classified at the different rates applicable at
different period of time. Levying one rate on whole turnover may lead to
unreconciled tax, answer to which might become difficult. In case you are
unable to figure out the same, it will be better to show the said tax amount
under the head “others” instead of showing it against the wrong tax rate.
Showing the tax under wrong rate head can lead to reconciliation issue not only
for tax payable purposes but also for reconciling turnover as well. Also you
must take all cautions while deciding the tax rate keeping in view the HSN
applicable on the output of the auditee.
4. Interest on delayed payment of tax:
Since GST portal has not been
charging interest on delayed payment of tax, it becomes the responsibility of
the auditor to calculate the same and get it discharged. As an auditor you must
prepare a chart of various due dates during FY 2017-18 and then work out the
interest payable by your client. Whether to charge interest on gross tax or net
of ITC can become tricky as an auditor. But keeping in view various judgments
and GST Council’s proposal to amend section 50, you can form your opinion and
mention it in the audit certificate. It is highly certain that your client may
not agree to pay interest on gross tax amount but as auditor you must make the
necessary disclosures, keeping your client well informed.
5. Analyzing Profit and Loss Account:
Although Table 14 of GSTR 9C has been
made optional. But as mentioned in opening paragraph of this article,
“optional” does not mean “not required”. An Auditor must deeply analyse the profit
and loss account. Not only to check the ITC claimed or eligible ITC but other
way around as well. Deriving the value of expense from the ITC can give you a
fair idea about the expenses on which either GST has not been charged by the
vendor or it has not been claimed by the auditee. In the first case you should
also work out on tax liable to be paid under Reverse Charge in case of
purchases till 13th Oct 2017 made from unregistered vendors.
Analyzing Profit and Loss statement has the potential to reveal glaring
defaults made by your client. All these might become important for reporting
purposes. Not only you must analyse cash expenses but also non cash expenses
such as depreciation etc. Analysis of Depreciation might reveal the additions
made to fixed assets and whether your client has availed any blocked ITC.
Similarly would be the case of business promotion expenses. As an auditor,
profit and loss can bring out interesting results which you should consider
before finalizing your audit report.
6. Claims made during 2018-19 in respect
of FY 2017-18:
Adjustment made during FY 2018-19 in
relation to FY 2017-18 reflected in Table 10 to 13 of GSTR 9, must be minutely
scrutinized. There is huge possibility that these adjustments had been made in
to plug any tax omission/error in returns. This might call for any interest
which would become payable. Please note that it is not necessary that the auto
populated figures in GSTR 9 are correct. There could also be a possibility of
wrong data entry by the auditee himself. Also most of the taxpayer had been
inquiring whether they can change an invoice from B2C to B2B. The main
intention which I found as an auditor was to do carry out sale/purchase of
invoices. There is no actual movement of goods. Although this adjustment is not
possible in GSTR 9, but if your client asks you this question, you must get
prepared to verify the actual movement of stock by auditee and find if there
are any red flags.
7. Refunds taken by auditee:
Since most of MSMEs has been getting
their compliance done from people other than professionals, it has been found that
most of them has claimed wrong refund. For Instance, refund of ITC paid on
capital goods in case of exports under LUT or refund of ITC on services in case
of Inverted Duty structure, or refund of accumulated ITC in case of excess
purchases etc. All these cases though processed by the department, must be
minutely checked as an auditor. If you find that your client has encashed
something which he was not allowed, you must get that paid back in cash along
with interest in Form DRC-03. You must educate auditee about the repercussions
of Section 74 , if they do not reverse the said erroneous refund at the time of
filing GSTR 9.
8. Obtain Management Representation
For any issue which might have been
left unaddressed and more importantly to save your skin, you must procure a
detailed management representation from the auditee. You must mention the
complete details along with relevant figures in such representation. It will not
only make your client serious about the GST Audit but you shall feel relieved
by sharing the burden with your client. Management Representation indeed
becomes important in today’s world where most of the clients have tendency to
hide facts which are later revealed at the time of inspections and audits
carried out by the tax department.
9. Generate UDIN:
As an auditor, you must not forget to
generate UDIN before you sign off. Although you have 15 days from the date of
signing, but as a CA myself, I would recommend that you must do that before
hand to avoid any hassle at later stage. Since most of the software which we
are using for filing of annual return does not remind us of UDIN, it is most
likely that we may forget to generate it. So do it in time and relax instead of
facing any issue which may arise later.
10. Charge the professional fees you
deserve:
Last but not the least, don’t forget
to charge audit fees from your client. It is seen that clients tend to include
annual filing fees in the monthly retainership fees they had been paying you
for monthly returns. Please make it very clear with your client and educate him
about the amount of work you shall be doing. In country like ours, where you
are paid off only when someone is in trouble, you must make the auditee
understand the trouble GSTR 9 and GSTR 9C are going to pose on them. Charge
your fees well which you deserve. There must be no regrets when you actually
sign off an audit assignment.
Keshav R Garg
(B.Com, FCA, CS, ISA (ICAI), LLB)
3328, First Floor, Sector 27 D, Chandigarh, INDIA 160019
Phones: +91-172-461-3328, +91-98880-90008
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