GST Registration, Returns and Notices - Chartered Accountants in Delhi

GST compliance is state-wise. A business operating in several states holds a separate registration in each, files a separate set of returns for each, and faces a separate assessing authority in each. We handle that complexity for businesses registered in one state and for businesses registered in many.

GST registration

We obtain new registrations, add places of business, amend existing registrations, and register for composition where it suits the business. Where a client operates across state borders, we advise on where registration is actually required before applying, because an unnecessary registration creates a permanent filing obligation.

Monthly and quarterly returns

We prepare and file GSTR-1 and GSTR-3B, reconcile input tax credit against GSTR-2B each month, and follow up supplier defaults that would otherwise cost the client credit. Reconciliation at the time of filing is what prevents a mismatch notice two years later.

Annual return and reconciliation — GSTR-9 and GSTR-9C

GSTR-9 is the annual return summarising the year's outward supplies, input tax credit and tax paid. GSTR-9C is a reconciliation between that return and the audited annual accounts, and applies above a turnover threshold notified by the government. Both are filed for each registration separately.

Replies to notices and departmental audit

We reply to scrutiny notices in Form ASMT-10, to demands raised in Form DRC-01, and to notices arising from input tax credit mismatch, place-of-supply disputes and classification questions. We represent clients in departmental audit and in appeal before the appellate authority.

A notice answered properly at the first stage is usually cheaper than an appeal, and the window to reply is short. Clients should send a notice to us on the day it is received, not on the day the reply is due.

Works contract and multi-state GST

Contractors and infrastructure businesses face questions that most taxpayers do not: place of supply on works executed in another state, treatment of retention money and mobilisation advance, valuation of running account bills, and credit on goods consumed at site. We advise on these and handle the registrations and returns across every state in which the contract runs.

Refunds

We file refund claims for exports, for accumulated credit under an inverted duty structure, and for excess balance in the electronic cash ledger, and we obtain and renew the letter of undertaking for export without payment of tax.

Questions and answers for this page

Does a business registered in several states file separate GST returns? Yes. GST registration is state-wise, and every registration files its own GSTR-1, GSTR-3B and annual return. Supplies between a business's own registrations in different states are treated as supplies between distinct persons, which affects valuation, input tax credit and place of supply.

What is the difference between GSTR-9 and GSTR-9C? GSTR-9 is the annual return summarising a financial year's supplies, input tax credit and tax paid. GSTR-9C is a reconciliation statement between that annual return and the audited annual financial statements, and it applies above a turnover threshold notified by the government. Both are filed per registration.

What should a business do on receiving a GST scrutiny notice in Form ASMT-10? Form ASMT-10 notifies discrepancies found on scrutiny of returns and requires an explanation within the period stated in the notice. The business should assemble the underlying records and reply within that period, because an unanswered scrutiny notice can lead to assessment on the officer's own estimate and to a demand under Section 73 or 74.

Do I need a chartered accountant to file GST returns? No. GST returns may be filed by the taxpayer or by a registered GST practitioner, who need not be a chartered accountant. A chartered accountant is required for specific functions, such as certification of GSTR-9C where applicable, and for certain refund and scheme certificates.