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BRIEF OVERVIEW OF GST AND RELATED ISSUES OFINDIAN RAILWAYS
14.05.2019
• M/s. Lakshmikumaran & Sridharan (L&S) appointed as GST Consultant to
Railway Board w.e.f. 16.10.2017.
• The scope constituted the following:
Part I - Process and Documentation review including contract review for
GST implementation
Part II - GST compliant IT solution
Part III - Capacity Building, review of Manuals and Handholding
TERMS OF REFERENCE
PART 1
PROCESS AND DOCUMENTATION REVIEW
INCLUDING CONTRACT REVIEW FOR GST
IMPLEMENTATION
• Study of commercial billing system with a view to revamp system
functionality for issuing receipt, debit/credit notes, etc. as per GST regime.
• Assistance in remodelling of Railways Business processes to ensure ITC
maximization.
• Review of intra organisation supplies within State/inter-State to appreciate
GST implication.
• Preparing and drafting of representation before GST council
• Ensure appropriate documentation and implementation through the IT
system
PROCESS AND DOCUMENTATION REVIEW INCLUDING
CONTRACT REVIEW FOR GST IMPLEMENTATION
PROCESS REVIEW:
GST AND INDIAN RAILWAYS- COMPLEX STRUCTURE
8 Production Houses
17 Zonal Railways
29 States
+
7 Union Territories
Ministry of Railways
Railway Board
Challenges:
1. IR exercise control over its operations through various Zonal Railways.
2. One State may fall within the jurisdiction of more than one Zone.
3. Books and records are maintained zone wise. 4. GST allow state wise registration.5. Representation to MOF for allowing Zone based
registration in vain .
Actions taken:
1. IR took registration in all States and Union Territories except Lakshwadeep.
2. Nodal officer were appointed by RB for all GSTINs.
PROCESS REVIEW: PLACE OF SUPPLY
1
2
3
4
5
Transportation of GoodsRegistered Recpt.- Location of recipient Unregistered Recpt. - Location where goods
are handed over
Transportation of Passengers
Registered Recpt.- Location of recipient Unregistered Recpt. - Place of Embarkment
for Continuous Journey
Sale of Coaches, Scrap, etc.-When movement involved
Place where movement terminates for delivery
Renting of Immovable property
Location of Immovable Property
Sale of Coaches, Scrap, etc.-When movement not involved
Location at the time of delivery
PROCESS REVIEW: INVOICE ISSUANCE TIME LIMIT
Issue of Invoice for Supply of Goods
• Before/at time of removal of goods (where movement involved)
• Before/at time of delivery of goods (where movement not involved)
Sale of Coaches, Scrap, etc.
• Within 30 days from date of supply of services
• Before or at time of recording of such supply in books of Accounts of IRor
• Before expiry of the quarter during which the supply is made(whichever is earlier)
Goods
Services
Goods/Passenger Transport Services, etc.
Intra Railway Supplies
PROCESS REVIEW: TIME OF SUPPLY FOR GOODS
Taxable under Forward Charge Taxable under Reverse Charge
Earlier of
Date of receipt of goods
Date when payment is made
Date immediately following 30 days from the date of invoice
Earlier of
Date of issuance of invoice
Last date on which invoice has to be issued
Date of receipt of payment*
(not relevant - N/N: 66/2017- CT)
Date of Invoice26/07/2019
Last date to Issue Invoice
25/08/2019
Date of Receipt of payment
24/07/2019
Sale of Coach
26/07/2019
Time of Supply26/07/2019
Date of Receipt31/07/2019
Date of Payment2/09/2019
30 days from Invoice Date 25/08/2019
Purchase of Silk Yarn
Invoice Date 26/07/2019
Time of Supply31/07/2019
PROCESS REVIEW: TIME OF SUPPLY FOR SERVICES
Taxable under Forward Charge Taxable under Reverse Charge
Earlier of
Date of payment
Date immediately following 60 days from the date of invoice
Invoice issued in 30 daysEarlier of:
• Date of issuance of invoice, or
• Date of receipt of payment
Invoice not issued in 30 daysEarlier of:
• Date of provision of service, or
• Date of receipt of paymentIn case of Intra IR Supplies, date of entry in the books of accounts of recipient of supply
Date of Provision of Service
25/08/2019
Date to Issue Invoice
31/08/2019
Date of Receipt 02/09/2019
Transportation of Goods by Rail
ServiceTime of Supply
31/08/2019(Invoice issued
in 30 days)
Date of Payment25/10/2019
60 Days 23/09/2019
GTA Service
Invoice Date 25/07/2018
Time of Supply23/09/2019
PROCESS REVIEW:
CONDITIONS FOR AVAILMENT OF ITC BY IR
Time Limits (E.g. FY 18-19)
Earliest of:
➢ Filing of return for September 2019
(last date: 20th Oct 2019)
➢ Filing of Annual Return for FY 18-19
(last date: 31st Dec 2019)
Limiting
factors
No Credit beyond
specifiedperiod
Possession of prescribed documents
Receipt of Goods/Services
Payment to be made within
180 Days
Monthly returns are
filed
e.g. GSTR 3B
Supplier has paid tax to “Appropriate Government”
2
3
5
4
1
6➢ Tax Invoice issued by supplier
of goods or services
➢ Debit note issued by supplier
➢ Purchase invoice issued by IR on supply of goods or services by an unregistered person on which IR is liable to pay tax under reverse charge
PROCESS REVIEW: MANNER OF UTILIZATION OF ITC FOR TAX PAYMENT
ITC of IGST
1
The amount of ITC available in the ledger shall be utilized in the following order of utilization:
IGST
CGST SGST/UTGST
ITC of CGST
1
2
CGST
IGST
ITC of UTGST
1
2
UTGST
IGST
ITC of SGST
1
2
SGST
IGST
• ITC of CGST and SGST/UTGST can not be used unless ITC of IGST has been exhausted completely
• CGST cannot be used for paying SGST or UTGST or vice versa.• ITC of SGST/UTGST cannot be used for paying IGST unless
ITC of IGST and CGST has been exhausted completely.
2
➢ Important that all the transactions are correctly captured to avoid last moment hustle.
➢ Non reporting/ Non compliances attracts serious consequences
PROCESS REVIEW: NON COMPLIANCE INTEREST/FEES/PENALTIES
Late fee
Late fee of up to Rs 100 per day can be levied in case of delay in filing of return
Interest
Interest @ 18%/24% can be recovered on the short payment of tax
Penalty
Penalty equivalent to the amount of tax short paid can be imposed
DOCUMENTATION REVIEW: TYPES OF DOCUMENTS UNDER GST
S. No. Documents Purpose of Documents IR Specific Documents
1. Invoice Taxable Supply RR, Tickets (AC/First Class
Coaches)
2. Bill of supply Exempt supply RR, Tickets (Non AC
Coaches)
3. Delivery Challan Transportation of goods without issue of
invoice
Delivery Challan
4. Debit Note Amend the value of tax invoice on the higher
side
Excess Fare Ticket
5. Credit Note Amend the value of tax invoice on the lower
side
Cancelled RR, Tickets
6. Advance Receipt
voucher
On receipt of advance Advance Receipt voucher
7. Refund Voucher On repayment of advance received due to non
supply
Refund Voucher
CONTRACT REVIEW: CONTRACT CLAUSES HIGHLIGHTED FOR MODIFICATION
• Clauses related to breaches, damages, penalties to be reviewed for possible GST
implication
• Pricing clause should be exclusive of taxes
• Person liable to pay tax, RCM or forward charge, place of supply, type of tax (CGST /
IGST) should be clearly defined
• Liability as to expenses on freight, insurance, etc., to be reviewed
• Composite contracts – Decision to be taken from tendering stage
• SPV/JV/PSUs- contract clauses were re-visited
PART II
GST COMPLIANT IT SOLUTION
• Assistance in drawing business rules for optimum operationalization of
CRIS systems.
• Regular interaction and feedback session conducted with CRIS to
enhance performance of the system.
• Assistance in developing module for filing of TDS returns.
• Integration of ITC flagging within CRIS system to optimize credit
maximization.
GST COMPLIANT IT SOLUTION
IPAS
PRS / UTS
PMS
FOIS
IREPS
MANUAL UTILITY
IPAS
-System Software to record inward transactions
-100 % data captured
- ITC also captured
-ITC flagging is the key feature
PRS- Passenger Reservation
PMS- Parcel management
FOIS- records good transactions
IREPS- caters procurements through tender
Manual Utillity
For recording division and station level data
- Captures all postal bagggage and MR transactions.
- Exempt supplies not fully captured.
GSP/CRIS
- Processing of data
- Validation check to avoid last moment rush
- Generate data in respective returns
- Share GSTIN wise information with Zonal Railway
IT ARCHITECTURE
• Avail eligible credit on time and save unnecessary stress on working capital
• Partial credit flagged as ITC Flag C2- Compute eligible ITC correctly
• Less burden on the users to clear last moment rush
• Avoid delay in filing of return
• Can save transaction cost: Interest and late fees
• Assistance in GST Audit
• System automated to determine the correct classification of tax
IT ARCHITECTURE- HOW IS IT HELPING?
PART III
CAPACITY BUILDING, REVIEW OF MANUALS AND
HANDHOLDING
• Capacity building within organisation by conducting Training staff as well as
master trainers.
• Preparation of GST manual.
• Drafting guidelines/circulars for all Zonal Railways/ Production Units.
• Integration of ITC flagging within CRIS system to optimize credit
maximization.
• Reviewing existing Codes and Manuals and rationalizing them with GST law.
• Handholding to address queries from Indian Railways.
CAPACITY BUILDING, REVIEW OF MANUALS
AND HANDHOLDING
HANDHOLDING: ADDRESSING ISSUES ON
OUTWARD SUPPLIES
OUTWARD SUPPLY-WAY LEAVE CHARGES
Renting of Immovable Property Service by Railways
Registered business entities
Reverse charge-payable by Business entities (w.e.f. 25.01.2018 vide Notification No. 3/2018 –
Central Tax (Rate) )
Unregistered business entities
Forward charge-payable by Railways (Sr. No.5 Notification No. 13/2017-Central Tax
(Rate)dated 28.07.2017)
Non business entities
Exempt from levy of GST (Sr. No. 7 Notification No. 12/2017-Central Tax
(Rate)dated 28.07.2017)
Grant of Way Leave Facility/ Easement Right on Railway Land.
The Nature of supply of way leave facility: Renting of
Immovable Property Service
www.indianrailways.gov.in/railwayboard/uploads
/directorate/accounts/downloads/Compendiu
m_2018/RBA_No_6_2018.pdf
OUTWARD SUPPLY-ZERO RATED SUPPLY
Zero rated Supply means:
Export of goods/services; or
Supply of goods/services to SEZ
Unit/SEZ Developer
Railways making supply to SEZ Unit
(Vedanta)=Zero Rated Supply
Endorsement in Invoices issued
ITC for Zero rated supply is available
to Railways
Supply to Vedanta (SEZ Unit)=Zero Rated Supply.
Railways can opt for either of:
Pay GST and claim refund OR
Execute LUT/Bond
without payment of GST
http://www.indianrailways.gov.in/railwayboard/uploads/directorate/traffic_comm/Rates-Letters/2018/SEZ_28032018.pdf
OUTWARD SUPPLY-HAULAGE SERVICE
Railway provides service of:
• Haulage of the wagons to Container
Train Operator (Gateway Rail
Freight Limited) &
• Maintenance of the wagons.
Haulage charge constitutes 95% while
5% charges are reckoned towards
maintenance.
Haulage Charge +
Maintenance Charge
Haulage service
Haulage + maintenance= Single supply or
multiple supplies (composite supply)?
SALE OF GOODS
Sale of Scrap amounts to supply of goods
Place of supply for sale of scrap to a registered person is
determined based on the GSTIN of the recipient.
Auction of unclaimed goods
Auction of unclaimed goods amounts to sale of goods by
Railways.
Railways to raise an invoice charging GST on goods (rate and
HSN depending on nature of goods) and discharge GST
liability on forward charge basis.
In case old and used goods are auctioned by Railways, the
registered recipient will be liable to discharge GST under
reverse charge.
Auction of goods=
supply
Old and used goods-
RCM
New goods-forward charge
www.indianrailways.gov.in/railwayboard/uploads/directorate/accounts/downloads/circular/2017/RBA_152_2017.pdf
WHARFAGE AND DEMURRAGE CHARGES
Demurrage:
charge for the detention of any rolling
stock after the expiry of free time.
Wharfage:
charge on goods for not removing
them from the wharf after the expiry
of free time.
Demurrage and wharfage charge-
an integral part of supply of
transportation service or a separate
supply?
Practice of charging GST on first RR by
Railways
http://www.indianrailways.gov.in/railwayboard/uploads/directorate/traffic_comm/downl
oads/compendium_Goods_Traffic/GST_08032018.pdf
OUTWARD SUPPLY-CATERING SERVICE
Catering service in trains
Transportation in Rajdhani + food &
beverage (IRCTC as licensee)
Vs.
Transportation in other trains + food
and beverage (other licensee)
Whether a Composite supply/Mixed
supply?
Rate ofTax?
Supply of food and beverages on
platform
Supply of food in train
Supply of food on
platform
Before 26.07.2018
[clarificatory order-31.03.2018]
After 26.07.2018 5% Rate No ITC
www.indianrailways.gov.in/railwayboard/uploads/directorate/traffic_comm/Comm_Cir_2018/CC__21_2018.pdf
HANDHOLDING: ADDRESSING ISSUES ON
INWARD SUPPLIES
INWARD SUPPLY- PURCHASE OF RAILS 1/2
Railway procures Rails from SAIL on
FOR destination basis
Railway supplies transportation service
to SAIL
Supply from SAIL to Railways:
Rails (goods) + transportation
(service) = composite supply
ITC utilization- blocked for Railways
Need for an alternative arrangement
Supply of Rails on FOR
destination basis at 18%
Supply of transportation
service at 5%
INWARD SUPPLY- PURCHASE OF RAILS 2/2
Railways will procure rails from SAIL
on Ex-factory basis
Rails will be inspected and loaded on
rakes and shall be the property of
Indian Railways.
SAIL to issue invoice for cost of rails
only (and not for transportation
service)
Supply of Rails
Ex-Works
Services by way of transportation of railway equipment or materials (Rails in the instant
case) by rail from one place in India to another is exempt from levy of GST vide sl.no.20 of
Notification No.12/2017-CentralTax (Rate) dated 28.06.2017, as amended.
INWARD SUPPLY- PROCUREMENT OF WAGONS
Railways supplies raw materials such
as steel, CTRBS and Wheelsets to
manufacturer on FOC basis
Manufacturer manufactures wagon
using other materials like couplers,
draft gears, bogies etc. procured by
them.
Supplies received from wagon
manufacturer –
Goods (wagons) or job work services?
Wagon
Manufacturer
Indian
Railways
Supply Wagon using other materials
Supply raw materials -FOC
INWARD SUPPLY- YATRITICKET SUVIDHA KENDRA(YTSK)
GST leviable on fare + service
charge collected from
passenger @ 5%
Passengers may book
ticket through YTSK
counter
Issue Invoice for service of facilitating
passengers in booking tickets
[@ 75% service charge]
FOC-ticket rolls and access
to the PRS and UTS
RR
Ticket Fare XX
+
Service
charge XX
------------------------------
Total XXX
+ GST @ 5% X
Service Charge shared
between IR and YTSK in
25:75 i.e. YTSK issues
invoice on IR for its
share (75%) in service
charge along with GST
at the rate of 18%.
www.indianrailways.gov.in/railwayboard/uploads/directorate/traffic_comm/Comm_Cir_2018/CC_05_2018_R.pdf
HANDHOLDING: MISCELLEANOUS ISSUES
Leasing of Infrastructure assets by IRFC
I
N
D
I
A
N
R
A
I
L
W
A
Y
S
I
R
F
C
License Agreement• IR grants license to IRFC in respect of a land for carrying out the development of
infrastructure assets thereon.
• IR will raise invoice on IRFC for a nominal amount (Schedule I + Section15 + Rule 28) for
granting of licensing rights.
Development Agreement• IRFC appoints IR as its agent to carry out the development works
• IR attains the right to request proposal and tenders in relation to the development work
• IR appoints W. C. for carrying out development works.
• W.C. will directly raise GST invoice on IRFC. IRFC will be eligible for availing ITC
• Payment will flow to WC through IR. IRFC will park funds with IR for this purpose.
• IR will raise invoice on IRFC for a nominal amount (Schedule I + Section 15 + Rule 28) for
provisioning of agency services.
Lease Agreement• IRFC will give the Infrastructure Assets on lease to IR with applicable GST thereon.
• IR shall be eligible to avail partial ITC under the Flag C2.
LIQUIDATED DAMAGES
Liquidated Damages - Damages on
breach of contract that are pre-
estimated.
• Exemption vide S.No. 62 of Notification No. 12/2017-Central Tax (Rate) dt. 28.06.2017
(tolerating non-performance of a contract for which consideration in the form of fines or
liquidated damages is payable to the Government/UT/Local Authority).
• Forfeiture of Wagon Registration Fee by Indian Railways, if customer refrain from availing the
services on the transaction day.
• Liquidated damages received by Railways from customers exempted from GST
Annual Return: (GSTR 9)
ANNUAL RETURN UNDER GST
Every registered person is required to furnish an annual return for everyfinancial year electronically on or before the 31st December following theend of such financial year.
CBIC, vide the Central Goods and Services Tax (Third Removal ofDifficulties) Order, 2018 dated 31/12/2018, the due date for filing ofForm GSTR - 9 for FY 2017-18 has been extended to 30th June, 2019.
Late fee: Rs. 100 for every day during which such failure continues subject to a maximumof an amount calculated at a quarter per cent of his turnover in the State or Unionterritory.
Min : {Rs. 100 (CGST) + Rs. 100 (SGST) ] per day of defaultMax : {0.25% (CGST) + 0.25% (SGST)} of turnover in a state
• All returns in Form GSTR-1 & FORM GSTR-3B for the FY 2017- 18have to be filed before filing of Form GSTR-9.
• Any additional liability for the FY 2017-18, not declared in FORMGSTR-1 and FORM GSTR-3B, may be declared in this return. Theadditional payments, if any, can be made through FORM GST DRC-03only in cash.
• However, any ITC not claimed during FY 2017-18 can not be claimedthrough this return.
ANNUAL RETURN UNDER GST (CONT.)
PARTS OF FORM GSTR-9
Form GSTR-9 is divided into 6 parts comprising of 19 tables wherein the data withrespect to outward supplies, inward supplies, taxes paid, HSN wise summary, etc. are tobe furnished.
Parts
Part I
Basic Info
Part II
Liability
Outward (Taxable +
Exempted + Non Taxable)
Inward RCM
Part III
Input Tax Credit
Availed ReversedReconciliation with GSTR 2A
Part IV
Tax Paid Details
Part V
Amendments
Part VI
Others
• Details to be filled in Form GSTR-9 would be in respect of supplies‘made during the year’ and not ‘as declared in returns filed during theyear’.
• Data for most of the fields in the Form GSTR-9 can be captured fromthe base data used for filing of monthly returns in the Form GSTR-3B& Form GSTR-1.
• However, there are also some extra/new fields in Form GSTR-9beyond what is covered in base data.
CAPTURING OF DATA FOR FORM GSTR 9
• FY 2017 -2018: GSTR-3B filed before GSTR-1.
• GST paid through GSTR-3B, but invoices uploaded in GSTR-1 in subsequentmonths
• Some GSTR-1 rejected data modified and uploaded in later months
• So reconciliation of outward supplies taxable value and total tax paid thereon ataggregate level (July 17- March 19) should be possible between data in GSTR-3B and GSTR-1.
• To be followed by linewise reconciliation for interest computation
• Reconciliation of ITC as per GSTR-2A with ITC availed in GSTR-3B.
• If GSTR-2A is short, immediately follow up with vendors for filing GSTR-1
RECONCILIATION OF DATA
NEW FIELDS IN GSTR-9
The following details, which were not a part of the monthly or quarterly returns, needto be captured for the purpose of filing of Form GSTR – 9:
• Trifurcation of Input Tax Credit between Inputs, Capital Goods and Input Services.
• Details of supplies received from composition taxpayer.
• HSN/SAC summary of Inward Supplies.
• Separate details of gross value and credit/debits notes - Exempted, Nil Rated & NonGST supplies.
• Details of TRAN – I & TRAN – II credits.
• Bifurcation of unavailed GSTR 2A ITC between “ITC available but not availed” and“Ineligible ITC”
TRIFURCATION OF ITC BETWEEN INPUTS, CAPITAL GOODS AND INPUT SERVICES
• Table 6B of GSTR-9 requires total ITC availed to be classified into ITC on inputs,capital goods and input services.
• In order to complete this exercise, CRIS will provide to recipient railways thecomplete data of ITC availed.
• Zonal Railways- ITC is allowed only for services. Therefore, flag T4 & C2 denotes onlyservices (i.e., where ITC has been adjusted). All other transactions will be deemed tobe either capital goods or inputs. If an item is charged to revenue, then it will be aninput, if it is charged to Grant 16, it will be a capital good.
• Production Units- ITC is to be bifurcated by looking at HSN Code. If the HSN/SACstarts with “99”, it is to be classified as “Services” and the rest will be “Inputs”.
DETAILS OF SUPPLIES RECEIVED FROM COMPOSITION TAXPAYER• Table 16A of GSTR-9 requires to furnish the taxable value of supplies received from
composition taxpayers.
• In this regard, IREPS will open a window for the users from where the same can be fedinto the system.
• In order to determine whether the supplier is “composition taxpayer”, the followingmethod can be applied-• Such supplier shall mention the words “composition taxable person, not eligible to
collect tax on supplies” at the top of the bill of supply issued by him.• Such supplier shall mention his GSTIN on bill of supply issued by him, however,
shall not charge any tax from the recipient on supplies.• The details of any GSTIN can be checked online using the link
https://services.gst.gov.in/services/searchtp
HSN/SAC SUMMARY OF INWARD SUPPLIES
• Table 18 of GSTR-9 requires to furnish HSN wise summary of Inward Supplies.
• Details are required to be declared only for those inward supplies which in valueindependently account for 10 % or more of the total value of inward supplies.
• In this regard, an additional exercise is to be carried out to identify and report suchsummary from base data as the same is not being captured currently.
• In order to complete this exercise, CRIS will provide to recipient railways thecomplete data of Inward Supplies.
• If HSN/SAC is not fed in the data provided by CRIS, recipient railway will have to feedthe same based on the description.
SEPARATE DETAILS OF GROSS VALUE AND CREDIT/DEBITS NOTES - EXEMPTED, NIL RATED & NON GST SUPPLIES
• Table 5D, 5E, 5F of GSTR-9 requires to furnish the Gross Value of Exempted, Nil Rated& Non GST supplies.
• Table 5H, 5I of GSTR-9 requires to furnish separately the values of Credit/Debit notesissued in respect of the above said supplies.
• GSP will carry out this exercise from the data already available with them.
DETAILS OF TRAN – I & TRAN – II CREDITS
• Table 6K & 6L of GSTR-9 requires to furnish the details of Transition Credit availedthrough TRAN-I & TRAN-II respectively.
• Further Table 7F & 7G requires to furnish the details of reversal of such TransitionalCredit, if any.
• This data is not available neither with CRIS nor GSP and therefore Zonal Railwaysneed to collate this data from the filed Form TRAN- I & TRAN-II .
BIFURCATION OF UNAVAILED (LAPSED) GSTR - 2A ITC
• Table 8 of GSTR-9 is a multi purpose table which endeavours to:➢ Reconcile ITC availed in GSTR-3B and GSTR-2A➢ ITC to be lapsed in the current FY
• Aggregate value of ITC which was available in Form GSTR-2A but not availed inForm GSTR-3B need to be arrived at and further classified into the following twocategories-➢ Credit which was Available But Not Availed➢ Credit was not availed as the same was Ineligible Credit
WHO WILL DO WHAT?
S. No. What is to be done (New Fields) Table No. Who will do
1.Separate details of gross value and credit/debits notes- Exempted, Nil Rated & Non GST supplies.
5H, 5I GSP/CRIS
2.Trifurcation of Input Tax Credit between Inputs,Capital Goods and Input Services.
6B, 6C, 6D Recipient Railways
3. Details of TRAN – I & TRAN – II credits 6K,6L,7F,7G Recipient Railways
4.
Bifurcation of unavailed GSTR 2A ITC between ITCavailable but not availed and ineligible ITC.(Reconciliation between credit claimed in GSTR-3Band ITC as per GSTR-2A )
8E,8F Recipient Railways
5Details of supplies received from compositiontaxpayer.
16A Recipient Railways
6. HSN/SAC summary of Inward Supplies. 18 Recipient Railways
GST AUDIT U/S 35(5)
• Every registered person whose turnover exceeds Rs. 2 crore inthe financial year shall get his account audited by a CharteredAccountant/ Cost and Work Accountant.
• File GST Audit report along with – Annual Return andReconciliation statement.
• As per the CGST Amendment Act, 2018 the departments ofCentral Government whose books of accounts are audited byC&AG shall not be liable for GST Audit.
Statutory Provisions
Questions?
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