As the deadline for GSTR 9 is approaching, there is a consternation on how various railways can solve the data conundrum related with GSTR 9 in order to complete it in a time-bound fashion.This article is an attempt to share the methodologies which South Central Railway has been using in order to analyse various types of data sets available to it and find the accurate output tax liability which the railway is responsible for .
Disclaimer:This is a result of our playing with data .It is not a recommendation to any railway so kindly don’t treat it as one.We are sharing it because we feel it might help others.
The following data set is available with our railways as of now:
Data Set 1 : CRIS data summary available on manual offline utility.It displays all the invoices pertaining to 2017-18 which were either submitted in 2017-18 to NSDL or were submitted in subsequent years to NSDL.
Data Set 2 : GSTR 1 details which was generated by NSDL and given to railways on the monthly basis.
Data Set 3: GSTR 3B details which include output tax liability which a railway is suppose to pay.
LOGIC :We have used the below two equations to come to accurate output tax liability
∑ CRIS data(2017-18 only) +Advances (received through ARV’s) –GSTR3B(Output Tax Libility only)>0
then remaining tax has to be paid to the GST department
∑ CRIS data(2017-18 only) +Advances (received through ARV’s) –GSTR3B(Output Tax Libility only)<0
then remaining tax has to be recovered from GST department
What is nearly matching?
Our close analysis for two states of Andhra Pradesh and Telengana reveals that there is something we should be happy about.
The total amount advise By Nsdl for output tax liability in GSTR 3B(i.e. Data Set 3) is closely matching (with some minor differences)with CRIS ADVISE given recently.This shows NSDL was quick to realize that whatever CRIS was submitting, entire amount had to be paid and therefore, it more or less advised that amount to respective railways.
By CRIS ADVISE we mean ∑CRIS data for 2017-18 (only including the receipts of 2017-18 and not of subsequent years) plus the advances received from various parties like NTPC. Every railway needs to calculate this figure from CRIS advice and advance which they have received
For example the state of telangana, total invoices generated in 2017-18 but submitted in 2017-18 year and subsequent years total upto 174 crores.But out of this 148 crores belong to only 2017-18 and thus,
∑CRIS data for 2017-18 (only including the receipts of 2017-18 and not of subsequent years) for state of telangana is 148 cr and the advance received from NTPC is around 23 cr.
the total becomes 171 crore which had to be paid by us and incidentally, GSTR -3B is also showing nearly the same liability with some minor difference which may have to be settled either by payment or recovery.
What may not match?
GSTR1 and GSTR 3B should match ideally but may not match practically.The reason is GSTR 1 is based on the invoices uploaded in the GST portal and sometimes those invoices may not get uploaded because of wrong GSTIN numbers and other reasons.But do we need to really worry about that.Yes, we need to worry but it is not the right time.We first need to see whether our liability is discharged fully or not and that depends on GSTR 3B(output tax liability calculated by NSDL) and CRIS summary advise giving the calculation generated by it applications.
So, what we should worry about?
We should use the above two equations to find the differences and try to see how much is the difference and take the proper action to discharge our liabilities.We have almost everything in place now and we should try to find out the difference if any.
Why we should not include receipts uploaded in 2018-19 but pertaining to 2017-18?
Most of the receipts generated offline on railways in 2017-18 were uploaded in the subsequent years in the offline utility.But once they were uploaded in the subsequent year , the tax belonging to that invoice was also paid in that year.So , we don’t have any tax liability towards this invoices.We only need to focus on data generated in 2017-2018 and submitted 2017-18 which includes the advances received in that year.
Once we are done with this calculation we will be fully prepared to file our GSTR 9 accurately and in time.So, let us keep playing with the data and keep progressing towards timely completion of GSTR 9.
As per your analysis it is not clear that what action is to be taken by other railways. We have also played with data and fortunately lies in equation 2 for state of rajasthan. It is not clear yet:
1. RCM output tax liability which was advise d to our railway in the month of dec.18( and in general to all of the railways RCM liability was not advised during the GSTR3B xls data details in 2017-18). My clear means is that what action is to be taken for that liability actually this is not included in CRIS data(i.e. actually earning data only).
2. You denotes ARV to be added …My question is here that Why it should be?? This has already been captured in Utility in the year data itself. Except few railways no railways has this advance received. Yes. i agree that in year 2018-19 most of the railways have received advance from NTPC,CONCOR etc. (ARVs) but this will effect next financial year or say GSTR9 of 2018-19.
3. CRIS data now providing clear picture of data pertaining to year 2017-18 which was punched in months of 2018-19.. Then how it is ascertained that tax liabilities for those invoices which were left out have been considered in 2017-18 definitely this liability been discharged in 2018-19. Then we should minus that values form CRIS data summary of 2017-18.
4 CRIS data summary for 2017-18 CGST AND SGST amounts are not equals. Then what action is to be taken. ??
In continuation to my earlier comment–
1.I think if details/tax liability for invoices pertaining to fy 2017-18 intimated in 2018-19 are not be considered in GSTR9 of 2017-18. As such CRIS should provide data accordingly.
2. CRIS should include the ITC claimed and utilised in 2017-18.
3.GSTR9 also desires HSN wise summary of all outward supply invoices/values. CRIS should provide that too.
Dinesh kumar sharma
Nice observations :
1)for ARV’s they were generated on 31st march 2018 and submitted on 6th April 2018 and it was accounted in gstr1 of 2017 and 2018.
2)For the data sets related to invoices which belong to next year has been given to us by CRIS on experimental basis and we have verified that invoices submitted in the subsequent year are there in gst portal for the month of that year.But your doubt was genuine as that data set is not freely available.