Draft Disclosures for GST Audit Report

Draft Disclosures for GST Audit Report for F.Y. 2017-18 and 2018-19

• The notes for GST Audit are for guidance only.
• The GST auditor will have to make suitable observations, remarks, qualifications, etc. depending on the facts of the audit.
• AS THE GST LAW IS EVER CHANGING

GSTR-9C and where to put reasons, comments, observations and qualifications and etc

• Reasons for unreconciled differences in Table 6,8,10,13 and 15.
• Part-B certification, Para 2 report on maintenance of books of accounts and if has not maintained books of accounts /records /documents specified below. Here the list of books of accounts not maintained like stock register, etc. as per Sec 35 read with rule 56 to 58 of CGST Act, which is as follows:

List of documents required to be maintained include –

• Inward and outward supply of goods or services or both
• Stock of goods
• Input tax credit availed
• Output tax payable and paid
• Goods and Services imported and exported
• Supplies attracting payment of tax on reverse charge mechanism along with relevant documents such as invoices, credit notes, debit notes, refund vouchers, bill of supply etc.
• Advances received, paid and adjustments thereof.

The above is not an exhaustive list and the registered person may have to maintain additional records and registers in support of its GST Returns, GST Payments and Input Tax Credits.

Disclosure 1: Notes to GSTR-9C for true and fair disclosure

As per notification no. 56/2019 dated 14 November, 2019, the word “True and Fair” is substituted for “True and Correct”. We have audited the books of accounts and based on our examination of books of accounts, we hereby certify that books of accounts are “true and fair” in all material aspect.

Also, Cash-flow is provided in cases where it is available as per the notification no. 56/2019.

Disclosure 2: Notes to GSTR-9C on Para 2

• As per the information and explanation given to us and on the basis of our examination of records of the taxpayer, the taxpayer has maintained proper records of books and documents listed in Sec 35 read with Rule 56 to 58 of CGST Act, except
• Stock of goods wherein memorandum stock statement is prepared.
• Partially maintained documents of supplies attracting payment of tax on reverse charge mechanism along with relevant documents such as invoices, credit notes, debit notes, refund vouchers, bill of supply etc.
• According to information and explanation given by the management and in our opinion the same are not material

We have relied on the report of statutory audit conducted under Companies Act, 2013 or Tax Audit under Income Tax Act,1961.

• In Para 3(b)(B) proper books of accounts have been/ have not been (to be selected from the drop down menu) needs to be mentioned.
• In Para 3(b)(C) P&L, BS and CFS are in agreement/not in agreement (to be selected from drop down menu) with the books of accounts.
• In Para 5, the auditor may provide observations and qualifications in the said of Form No.GSTR-9C and comment subject to are true and correctness.
• Here Table is provided wherein it can be given. 15 rows and 1000 characters in each row can be given in the form of observations and qualifications.
• Further the auditor may attach notes to GST Audit in a separate statement along with attachment of annual audited statements if required.

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