The Tax Publishers

GST--Aggregate Turnover

Aggregate Turnover for GSTR 9 (Annual Return) and GSTR 9C (Reconciliation Statement)

CA. L. Venkataramanan

The learned author tries to explain the term "Aggregate Turnover" under GST law along with accounting and income tax principles, for the purpose of determining liability to file GSTR 9/9C.

1. Introduction

The word "Aggregate Turnover" is a very important term in deciding whether registered persons have to file GSTR 9 and GSTR 9C. If the Aggregate Turnover exceeds Rs. 2 crore in a financial year, it is necessary for the registered person to file FORM GSTR- 9(Annual Return) before 31st December every year [CGST Rule 80(1)]. Similarly, if the Aggregate Turnover exceeds Rs. 5 crore in a financial year [CGST Rule 80(3)], the registered person has to file FORM GSTR-9 along with FORM GSTR-9C. Practically, for calculating aggregate turnover, the turnover from profit and loss account is considered after adjusting some figures for the purpose of checking liability to file GSTR 9 and GSTR 9C. These adjustments are required to be made due to different principles of Income tax and GST. If these adjustments are not considered properly, the registered person may end up paying late fees of Rs. 200 (Rs. 100 CGST plus Rs. 100 SGST) under section 47(2) subject to maximum of half percent (one fourth CGST and one fourth SGST) of his turnover in the State or Union territory (defined under section 2(112) of the CGST Act) which may cause huge financial outflow for the company.

2. FORM GSTR-9/9A (Annual Return)

Every registered person, other than those specified under section 44 of CGST Act, shall furnish an annual return which may include a self-certified reconciliation statement, reconciling the value of supplies declared in the return furnished for the financial year, with the audited annual financial statement for every financial year electronically, within such time and in such form and in such manner as may be prescribed. (CGST Rule 80(1))

Notification No.10/2022-C.T dated 05-7-2022 exempts the registered person whose aggregate turnover in the financial year 2021-22 is up to Rs. 2 crores, from filing annual return (FORM GSTR-9) for the said financial year. Similarly, Notification No.31/2021 C.T. dated 30-7-2021 exempts filing of annual return for the financial year 2020-21, if the aggregate turnover did not exceed Rs. 2 crore rupees.

Further, if the aggregate turnover did not exceed Rs. 2 crores, it was optional for the registered person to furnish the annual return for the financial years 2017-18, 2018-19 and 2019-20.

From the above, it is important to understand the term 'Aggregate Turnover' so as to decide whether GSTR-9 has to be filed or get an exemption otherwise ending with paying late fees under section 47(2).

3. FORM GSTR-9C (Reconciliation Statement)

As per section 44 of CGST Act, read with rule 80(3), every registered person other than those specified, whose aggregate turnover during a financial year exceeds five crore rupees is also required to furnish a self-certified reconciliation statement in FORM GSTR 9C along with the annual return (FORM GSTR 9) referred to in sub-rule(1) on or before thirty-first day of December following the end of such financial year, electronically through the common portal either directly or through a facilitation centre notified by the Commissioner.

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