Demystifying GST Audit for High-Turnover Taxpayers
Understanding GST Audit for Taxpayers with Annual Turnover above 2 Crores
Since the financial year 2020-21, the mandatory GST audit requirement by a CA/CMA for taxpayers with a turnover exceeding Rs.2 crores has been abolished. Instead, taxpayers with a turnover of over Rs.5 crores are required to self-certify and submit Form GSTR-9C from FY 2020-21 onwards. The Finance Act, 2021, eliminated the requirement for GST audit and submission of GSTR-9C certified by a CA/CMA.
The Need for GST Audit and its Significance
GST audit involves the examination of records, returns, and other documents maintained by a GST registered person to ensure the correctness of turnover, taxes paid, refund claimed, input tax credit availed, and compliance with other GST Act regulations. Given that GST operates on a trust-based system, robust audit mechanisms are essential to verify taxpayer compliance.
Types of GST Audit
- Turnover-based Audit: Conducted by a Chartered Accountant or Cost Accountant appointed by the taxpayer if the turnover exceeds Rs.2 crores.
- Normal/General Audit: Conducted by the Commissioner of CGST/SGST or any authorized officer upon prior notice.
- Special Audit: Carried out by a Chartered Accountant or Cost Accountant nominated by the Commissioner, with approval from Deputy/Assistant Commissioner.
Turnover-based Audit under Section 35(5) of CGST Act
If a registered taxpayer’s annual turnover exceeds Rs.2 crores in a financial year, they must get their accounts audited by a Chartered Accountant or Cost Accountant annually. This audit applies to the 12-month period from April of one calendar year to March of the next.
Qualification of GST Auditor & Eligibility
Only Chartered Accountants or Cost Accountants can conduct GST audits under Section 35. Additionally:
- Internal auditors cannot simultaneously serve as GST auditors.
- GST practitioners are not authorized to conduct audits.
Conducting GST Audit & Issuance of GST Audit Report
- A GST auditor must review crucial accounts like sales, stock, purchases, expenses, and tax credits.
- Different forms of annual returns are applicable based on the taxpayer type.
- The finalized GSTR-9C can be certified by the auditor who conducted the audit or by another CA.
- Due dates for submission of GST audit reports are typically December 31st of the subsequent fiscal year.
Penalties for Non-submission of GST Audit Report
While there’s no specific provision for non-submission penalties, general penalties may apply, subject to a maximum of Rs.25,000.