Comprehensive Checklist for GST Audit
Comprehensive Checklist for GST Audit by CA Pragya Singh
As the year is ending, the date for filing the GSTR-9 and GSTR-9C is getting closer. The GSTR-9 is for annual return and GSTR-9C is for the audit report. So, let us know more about what should be checked for GSTR-9C(Audit Report). Following are the components of the Comprehensive Checklist for GST Audit:
Related Topic:
Resolution to GST audit major issues based on ICAI’s Guide
Documents Llist:
| Particulars | Remark |
| Signed Financial Statements | |
| State wise financial statements | |
| GST User Id | |
| GST Password | |
| Monthly GSTR 3B | |
| Monthly GSTR 1 | |
| Monthly GST Workings | |
| Monthly ITC reversal workings along with final reversal | |
| Transitional Credits Availed along with workings | |
| List of supplies along with HSN and rate adopted | |
| Refund Claim filed along with workings | |
| Refund Claim Orders received | |
| List of Advance Rulings applied |
Comprehensive Checklist for GST Audit:
| S. No. | Particulars |
| 1. | Understanding Of Client Business |
| 2. | Registration |
| 3. | Supply |
| 4. | Documents Related To Supply |
| 5. | Place of supply |
| 6. | Reverse Charge |
| 7. | GST Payments & Input Tax Credit |
| 8. | Job Work |
| 9. | Filing of Returns |
| 10. | Refund |
| 11. | Accounts & Records |
| 12. | Miscellaneous |
| 13. | Management Representation Letters |
Download the Comprehensive Checklist on GST Audit bu CA Pragya Singh: Comprehensive Checklist on GST Audit
UNDERSTANDING OF CLIENT BUSINESS:
| S.No. | Particulars | Remarks |
| 1 | BASIC DATA | |
| a | Name of the client | |
| b | Constitution Type – Private, Public, Section 8 | |
| c | Registered Office | |
| d | Branches / Warehouses / Factory address | |
| e | Nature of Business | |
| h | List of supply along with HSN and rate | |
| 2 | MANAGEMENT | |
| a | Key Shareholders | |
| b | Key Managerial Personnel ( KMP ) / Other Key officers of the Company | |
| c | Directors and Constituion of the Board | |
| d | Independent Directors and Committees of the Board | |
| e | List of all Related Parties and nature of relationships | |
| 3 | INDUSTRY DYNAMICS | |
| a | Industry in which the client operates | |
| b | Seasonality / Trends in industry | |
| c | Present state and prognosis for industry | |
| d | Client state vs industry benchmarks | |
| e | Key Competitiors | |
| f | Key Suppliers | |
| g | Key customers and marketing relationships | |
| 4 | ACCOUNTING SYSTEMS AND INTERNAL CONTROLS | |
| a | Standard Operating Procedures | |
| b | Delegation of Powers | |
| c | IT enviroment in the entity | |
| d | Financial Reporting protocols | |
| e | Management Reporting protocols |
REGISTRATION
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Obtain the list of registrations in pre GST regime and ensure migration? | ||||
| 2 | Whether registration is obatined in every state from where supply is made ? | ||||
| 3 | Whether compulsory registration as required u/s. 24 of CGST Act is obtained? | ||||
| 4 | Whether the entity was registered as composition dealer at any time during the year? | ||||
| 5 | Whether additional places of business within a state are added in the registration certificate | ||||
| 6 | Whether registration for ISD has been obtained for transfer of ITC in respect of services | ||||
| 7 | Whether GSTIN is displayed in Name Boards |
SUPPLY:
SUPPLY & CLASSIFICATION OF SUPPLY
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether classification of supplies into goods or service is as per Schedule II to the CGST Act? | ||||
| 2 | Whether any revenue is classified as not a supply? Provide reasons. | ||||
| 3 | Whether supply of goods are appropriately classified as per customs tariff? | ||||
| 4 | Whether supply of services are appropriately classified as per Annexure to Notification 11/2017 – CGST (Rate)? | ||||
| 5 | Whether rate for goods is as per the notification 1/2017 read with subsequent amendments? | ||||
| 6 | Whether rate for services is as per the notification 11/2017 read with subsequent amendments? | ||||
| 7 | Whether exemption in case of goods is claimed as per the notification 2/2017 read with subsequent amendments? | ||||
| 8 | Whether rate is as per the notification 12/2017 read with subsequent amendments? | ||||
| 9 | Whether conditions for export of service as per definition in IGST Act is complied? | ||||
| 10 | Whether conditions for export of goods as per definition in IGST Act is complied? | ||||
| 11 | Whether conditions of notification in case of deemed supply has been complied? | ||||
| 12 | Whether conditions of notification in case of supplies to Merchant Exporter has been complied? | ||||
| 13 | Whether Composite and Mixed Supplies are appropriately taxed as per Section 8? | ||||
| 14 | Whether Tax on sale of capital goods has been discharged as per Section 18 and Rules made there under? | ||||
| 15 | Whether Supply falling under Schedule I of the CGST Act has been identified and tax has been paid? | ||||
| 16 | Whether change in tax rates has been dealt with correctly? | ||||
| 17 | Whether supply as per books of account matches with supply as per |
TIME OF SUPPLY
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether GST is paid on the basis of provisions of Section 12 & 13 of the CGST Act? | ||||
| 2 | Whether there was any change in the rate of tax and provisions of Section 14 of the CGST Act have been complied? | ||||
| 3 | Whether any goods were sent of approval basis and provisions of time of supply was compiled on the same? | ||||
| 4 | Whether any goods were sent on job work basis and not returned within prescribed time and provisions of time of supply was compiled on the same? |
VALUATION OF SUPPLY
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether all the inclusions and deductions as per Section 15 have been complied? | ||||
| 2 | Whether valuation is made as per valuation Rules of the CGST Rules? |
VERIFICATION WITH RETURNS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether supplies as per books of account and GSTR 1 are same? | ||||
| 2 | If not same, whether reconciliation statement has been prepared? | ||||
| 3 | Whether in the reconciliation statement any items are there on which GST was payable during the year? |
DOCUMENTS RELATED TO SUPPLY
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether invoice has all the prescribed particulars as required under Section 31 and rules made there under? | ||||
| 2 | Whether bill of supply is issued for exempt supplies/ non- GST supplies? | ||||
| 3 | Whether the time limit for issue of invoice has been adhered to? | ||||
| 4 | Whether Receipt voucher is issued for receipt of advance? | ||||
| 5 | Whether “Self Invoice” is raised in case of RCM transactions | ||||
| 6 | Whether Credit note/ Debit notes are issued as per the provisions of the GST law as per Section 34? | ||||
| 7 | If Credit note/ Debit notes are not issued as per Section 34, then no tax is reversed? | ||||
| 8 | Whether the Delivery challans are maintained? |
VERIFICATION WITH RETURNS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether document as per books of accounts match with GSTR 1 |
PLACE OF SUPPLY
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether inter state transactions are determined as per Section 7 of the IGST Act | ||||
| 2 | Whether intra state transactions are determined as per Section 8 of the IGST Act | ||||
| 3 | Whether the place of supply of goods in case of domestic supply has been determined as per Section 10 of the IGST Act | ||||
| 4 | Whether the place of supply of services in case of domestic supply has been determined as per Section 12 of the IGST Act | ||||
| 5 | Whether the place of supply of goods in case of international supply has been determined as per Section 11 of the IGST Act | ||||
| 6 | Whether the place of supply of services in case of international supply has been determined as per Section 13 of the IGST Act | ||||
| 7 | Whether the wrong payment of tax i.e. IGST in lieu of SGST/CGST is claimed as refund? |
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| 8 | Whether the wrong payment of tax i.e. SGST/CGST in lieu of IGST is claimed as refund? |
REVERSE CHARGE MECHANISM
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether Reverse Charge has been paid on all inward supplies notified u/s. 9(3) of the CGST Act and u/s. 5(3) of the IGST Act? | ||||
| 2 | Whether Reverse Charge has been paid u/s. 9(4) of the CGST Act and Section 5(3) of the IGST Act on supplies received from unregistered person until 12th October 2017 | ||||
| 3 | Whether ITC has been availed of the tax paid under reverse charge? |
VERIFICATION WITH RETURNS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether expenses on which RCM is payable reconciles with RCM as declared in GSTR 3B |
GST PAYMENTS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether tax has been paid within the prescribed due dates? | ||||
| 2 | In case of late payments whether interest has been paid? | ||||
| 3 | Whether GST collected has been remitted or there is any excess collection? |
INPUT TAX CREDIT
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether input tax credit is taken based on eligible documents having all the prescribed particulars as per the Rules made in this regard? | ||||
| 2 | Whether the goods / services on which ITC is claimed has been received by the entity before taking ITC? | ||||
| 3 | Whether in case of purchase of capital goods, if ITC is claimed, ensure no depreciation is claimed? | ||||
| 4 | Whether the vendors (other than RCM) have been paid within 180 days from the date of invoice? | ||||
| 5 | Whether the entity supplies both taxable and exempt/non-GST supplies?
Whether ITC on common inputs and input service has been reversed as per Rule 42 of the CGST Rules? |
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| 6 | Whether the entity supplies both taxable and exempt/non-GST supplies?
Whether ITC on common capital goods has been reversed as per Rule 43 of the CGST Rules? |
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| 7 | Whether ITC has been taken on list of blocked credits u/s. 17(5)? | ||||
| 8 | Any Reversal of input tax credit for the goods sent for job work? | ||||
| 9 | Whether Input tax credit is reversed against the receipt of Credit Note? |
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| 10 | Whether the conditions for availing transitional credits have been fulfilled | ||||
| 11 | Whether any ITC has been claimed as per Section 18 and whether conditions of Section 18 and rules made there under have been satisfied? | ||||
| 12 | Whether wrong ITC availed has been reversed along with interest? |
INPUTSERVICE DISTRIBUTOR
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether ISD registration has been obtained? | ||||
| 2 | Whether conditions for transfer of ITC on input services has been satisfied? | ||||
| 3 | Whether the transfer of ITC is appropriately calculated as per the methods prescribed in law? | ||||
| 4 | Is there is any reversal of Input tax credit and credit note is issued? | ||||
| 5 | Whether invoice for ISD issued contains prescribed particulars? |
JOB WORK
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether goods sent on job work have been received within the prescirbed time? | ||||
| 2 | Whether the documents prescirbed for job work has been maintained? | ||||
| 3 | Whether FORM ITC 04 has been filed quarterly? |
FILING OF RETURNS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether returns as applicable have been filed within the due dates | ||||
| 2 | In case of late filing whether late fees has been paid? | ||||
| 3 | Whether late fees waived has been credited in cash ledger? | ||||
| 4 | Whether transitional credit Returns are filed within the due date? | ||||
| 5 | Whether any amendments/omission/ correction in returns has been made between April 2018 to September 2018? |
REFUNDS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether the Supplier is eligible for Refund as per Section 54? | ||||
| 2 | Whether refund application has been made? | ||||
| 3 | Whether the calculation of refund is as per the Rules prescribed ? | ||||
| 4 | Whether refund order has been received or is rejected or pending ? | ||||
| 5 | Whether Refund rejected has bein Re-credited to Electronic Credit Ledger? |
VERIFICATION WITH RETURNS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether the Returns filed for refund have been appropriately accounted in the books of account? | ||||
| 2 | Whether rejection for refund has been recorded appropriately? |
ACCOUNTS & RECORDS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether books of accounts are maintained as specified in Section 35 r/w Rules 56, 57 and 58 of the GST Law? | ||||
| 2 | Whether Books of accounts are maintained electronically / Manually? | ||||
| 3 | Whether books of accounts are maintained at each place of business? | ||||
| 4 | Whether documents documents / agreements are available? | ||||
| 5 | Whether Transporter/Warehouse keeper has maintained the books of Account as per the law? | ||||
| 6 | Whether the Register E-way Bill/Delivery challan is maintained as per the law? | ||||
| 7 | Whether E- Way bills are used for Valid purpose? | ||||
| 8 | Whether the register of ITC-01, ITC-02, ITC-03 and ITC-04 is maintained as per the GST law? |
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| 9 | Whether the books of Accounts maintained are centralized or decentralized? |
MISCELLANEOUS
| S.No. | Particulars | Checked By | Yes / No / NA | Remarks | Action Taken |
| 1 | Whether the registered person has complied with Anti-Profiteering clause? | ||||
| 2 | Whether there was a reduction in the rate of GST and the provisions of Anti-Profiteering were complied? | ||||
| 3 | Whether there was a savings on account of ITC (on comparison with previous tax regime) and the provisions of Anti-Profiteering were complied? | ||||
| 4 | Whether any advance ruling was applied ? Whether the advance has been complied ? | ||||
| 5 | Are there any departmental inspection proceedings for Transitional Credits or any other demands created? | ||||
| 6 | Any adverse remarks by Statutory Auditor / Internal Auditor has been raised and whether those are rectified? |
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