GST Audit – Reconciling GSTR 3B and GSTR 1

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GST Audit – Reconciling GSTR 3B and GSTR 1

The rush for filing GSTR 9 and GSTR 9C is also catching up now a days.GST has played a major role in the Indian economy in the past one year. Now, it’s GST Audit which has become crucial now a days.

How to map GSTR 1 v/s GSTR 3B

GSTR-1, filed by the supplier, contains invoice-wise and category-wise details of all outward supplies made in a year

GSTR-3B is the summary return based on which tax is deposited by the supplier. It contains category-wise summary of both inward and outward supplies and tax payment details.

Now, the reconciliation of GSTR-3B and GSTR-1 is of utmost importance since GSTR-3B is a manual return, i.e. it is not auto populated on the basis of GSTR-1 and GSTR-2A. There might be instances where supplier has shown an invoice in GSTR-1 but has not paid tax on that invoice in GSTR-3B.

Thus, GST department uses data analytics to reconcile GSTR-1 and GSTR-3B filed by a supplier. That means it automatically reconciles GSTR-1 with GSTR-3B and issues a GST notice for mismatches.

One of the main reasons of the differences is, wrong calculation of revenue & tax liability at the time of filling GSTR-3B. For a large business organization, it is very common to have differences in Actual turnover & the turnover recorded in books. This may result in GST liability if turnover as recorded in books of accounts is less than the actual turnover. Again this may result in late payment of GST, which may lead to applicability of interest. Nominal difference in is still accepted, but large data gaps is matter of concern because this can result in heavy interest liability

Problems in mapping the GSTR 9 & 9C:

  1. Downloading all files – All files for each branch and each month need to be downloaded from GST Portal.
  2. Conversion to excel – for starting any kind of mapping firstly all the files need to be converted into excel in a format that it can be manipulated.
  3. Identifying data points to be matched – There are multiple data points in the forms which can be mapped. As GSTR 1 is a detailed return and mapping it with 3B required submission of a number of columns in GSTR 1 for mapping with column of 3B.
  4. Huge data and complex sheets – When preparing this sheet for multiple clients and years the data can become too large to handle. The formulas become complex and chances of manual errors  cannot be ignored

What are the Key points that can be mapped?

For the purpose of GSTR 3B and GSTR 1 mapping from their summaries only 4 from GSTR 3B and and 9 from GSTR 1 are relevant:

GSTR 3B section 3.1(a) maps with following columns of GSTR 1

  • +  4A, 4B, 4C, 6B, 6C
  • + 5A, 5B
  • – 9B (registered)
  • – 9B (unregistered)
  • + 7 B2C
  • + 11 A (1), 11A(2) Advances received
  • – 11 B (1), 11B (2) Adjustment of Advances

GSTR 3B section 3.1 (b) maps with following columns of GSTR 1

  • + 6A

GSTR 3B section 3.1 (c) maps with following columns of GSTR 1

  • + section 8 but only Nil and Exempted Column

GSTR 3B section 3.1 (e) maps with following columns of GSTR 1

  • + section 8 but only Non- GST Supplies

Whereas GSTR-9C is the reconciliation statement to be submitted by those GST registered taxpayers to whom GST audit applies. GST Audit applies to those taxpayers whose turnover exceeds Rs. 2 crore. Audited financial statements must be filed by the taxpayers along with this after obtaining certification from the auditor or a Chartered Accountant or a CMA.

 FY 2017-18 is the first financial year for filing annual returns and GST audit.

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