GST Audits and Assistance

Integrated audits provide maximum assurance on your investment. Collaborative workflow, providing faster, more efficient information sharing at each stage of the audit provides critical insights that keeps your business moving forward.

In the fiscal 2017 – 18, India witnessed a regime shift in the Indirect tax regulations with the introduction of the GST effective 1st July 2017. In pursuance to such regulations, every ‘registered person’ under Goods and Service Tax (‘GST’) law, whose turnover during a financial year exceeds INR 2 crores is required to get his accounts audited.

Audit for this purpose in accordance with the provisions u/s Sec 35 & Sec 44 of the CGST Act, 2017 means – “Audit” means the examination of records, returns and other documents maintained or furnished by the registered person under this Act or the rules made thereunder or under any other law for the time being in force to verify the correctness of turnover declared, taxes paid, refund claimed and input tax credit availed, and to assess his compliance with the provisions of this Act or the rules made thereunder

Hence, now it is critical to start focusing on various compliances such as input and output reconciliations, preparation and filing of annual return and GST audit certification. All of these compliances will form an important basis for the first audit/scrutiny/assessment under the GST law.

The law prescribes multiple audits conducted by the authorities, an external auditor appointed by the authorities or audit certification by a person appointed by the company. The following are the audits which companies should be prepared for:

  • Audit by commissioner under section 65 of the CGST Act, 2017
  • Special audit in terms of section 66 of the CGST Act, 2017
  • Audit as part of the annual return process by an external Chartered Accountant (in Form 9C and 9D – draft submitted by the ICAI)

It’s important that companies start preparing for these audits in order to avoid any loss of credits, applicability of interest/penalties, etc. Some of the key aspects to be considered by companies are as follows:

  • Reconciliations: Ensure reconciliations of output tax/input tax between the books of accounts, returns and e-waybills issued (output side)/tax discharged by the vendors (input side).
  • Tax positions: Review the tax positions adopted by the company and also whether these are correctly reflected in documentation.
  • Credits: Review if any ineligible credits have been availed (including review of credits availed) and in the process also ensure completeness of credits.
  • Applicability: Applicability of other provisions like free of cost services/goods, valuation, and cross-charges between related persons/distinct persons.

Now is the perfect time for entities to ensure that they are well prepared for all the audits to be conducted by the authorities.