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    With the requirement to get the records audited annually under GST Laws, the auditor is required to come up with reconciliation of turnover, input tax credit availed, taxes paid between Financial Statements and GST Records maintained. The said reconciliation statement is required to be prepared in the format as prescribed under Part A of Form GSTR-9C as notified under Notification 49/2018-Central Tax dated 13.09.2018.

    Upon careful consideration of this reconciliation statement, the information sought therein for reconciliation cannot be readily extracted from books of accounts or from GST records. It is required to draw certain other reconciliation statements before we proceed to work on the reconciliation required under GSTR-9C. This article focusses on such other reconciliation statements to be prepared for smooth preparation of the reconciliation statement as prescribed in GSTR-9C. These statements are indicative and are not exhaustive and would vary from one tax payer to another tax payer depending on their business structure, manner of record maintenance etc.


    The recent judgment of the Honourable Appellate Tribunal[1] of New Delhi in the case of 28 appellants who are the professors of a college, who has received salary advances in cash and the initiating officer (IO) treating such salary advances in cash are benami transactions under the Prohibition of Benami Properties Transactions Act, 1988 (PBPT) and quashing such actions of IO by the Honourable Appellate Tribunal is welcome move as it clears certain vital aspects pertaining to the PBPT Act laying more clarity.



    Circular No. 57/3/2018-GST dated 04.09.2018 has been issued to provide that the movement of goods between Principal and Agent would be considered as deemed supply under Schedule I of CGST Act, 2017 to attract GST, only when Agent undertakes to issue invoice in his own name. In cases, where Principal undertakes to issue invoice to customer, then supply of goods by Principal to Agent will not be considered as deemed supply and accordingly, no GST is payable.

    In view of this clarification, certain representations were made with respect to GST implications in case of Del-Credere Agent (DCA) who guarantees the payment to Principal even if there is a default by Customer. DCA effectively extends loan to Customer or charges interest for delay in payment for the goods supplied to him.

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