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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