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The Goods and Services Tax Regime in India An Accounting Perspective - Protected
The Goods and Services Tax Regime in India An Accounting Perspective - Protected
Abstract: This paper presents an accounting perspectives under a country-wide ambitious indirect tax
regime, the GST. The GOI has introduced a single tax regime for both goods and services for the
entire country (except J&K) with the roll out the GST w.e.f. July 1, 2017. The GST is a comprehensive
consumption based tax on supply of goods or of services or both and subsumed the majority of indirect
taxes into a single tax basket. In view of the majority of indirect taxes being merged into one tax,
impact is expected to be almost every business operation in India. The main goal of the GST regime is
‘one tax one market’, which aims at providing a cohesive tax approach across country. Previously, we
would have maintained individual accounts for each. But from an accounting perspective under the
GST regime, entities will have to make certain changes to their accounting system and processes
including charts of accounts (COA).
Keywords: Goods and Services Tax, Accounting Treatment: Financial records and Journal
entries.
JEL Classification: M4
INTRODUCTION
The Goods and Services Tax, addressed as the aspiring tax reform, is not only limited to
changes in the tax structure, but also comprehends the overhaul of the entire business financial
processes along with the recording, accounting and financial reporting structure. This is likely
to create a comprehensive impact on the treatment of GST in financial statements and chart of
accounts. As a result, the accounting system in companies will witness significant changes in
input supplies, output supplies, production, stock, financial and revenue reporting, import-
export, calculation of tax liability, reverse charge, and the way tax credit is written off [1]. To
fully assimilate the impact, companies will need to figure out the changes GST will bring on
the financial reporting and indirect tax accounting. Consequently, companies will be able to
evaluate the reshuffle in accounting and financial reporting for a correct revenue
recognizance.
In previous, accounting treatment of various indirect taxes were covered under the Indian
Accounting Standards (IAS) where various taxes were treated based on their nature and the
point of levy. For instance, excise duty was included in revenue since it was origin based or
production based tax. On the other hand, sales tax and VAT being levied at the time of sales
was not taken into account while calculating revenue. Because of several indirect taxes and
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Assessment in GST is mainly focused on self-assessment by the taxpayer’s themselves. This requires certain
obligations to be cast on the taxpayers for keeping and maintaining accounts and records.
Section 35 of the CGST Act and “Accounts and Records” Rules (hereinafter referred to as rules) provide that every
registered person shall keep and maintain all records at his principal place of business. It also provides that every
registered person whose turnover during a financial year exceeds the prescribed limit shall get his accounts audited
by a chartered accountant or a cost accountant.
Section 35 provides that every registered person shall keep and maintain, at his principal place of business, as
mentioned in the certificate of registration, a true and correct account of production or manufacture of goods,
inward and outward supply of goods or of services or both, stock of goods, ITC availed, output tax payable and paid,
import-export of goods and services and supplies attracting payment of tax on reverse charge.
In case more than one place of business is specified in the certificate of registration, the accounts relating to each
place of business shall be kept at such places of business. A registered person may keep and maintain such accounts
and other particulars in electronic form in such manner as may be prescribed.
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Period for preservation of accounts: All accounts maintained together with all invoices, bills of supply, credit and debit
notes, and delivery challans relating to stocks, deliveries, inward supply and outward supply shall be preserved for seventy
two months (six years) from the due date of furnishing of annual return for the year pertaining to such accounts and
records and shall be kept at every related place of business mentioned in the certificate of registration.
Electronic Records: The following requirements have been prescribed for maintenance of records in electronic form.
Proper Electronic back-up of records, Produce, on demand, the relevant records or documents, duly authenticated, in
hard copy or in any electronically readable format.
Records to be maintained by owner or operator of godown or warehouse and transporters: The transporters, owners or
operators of godowns, if not already registered under the GST Act(s), shall submit the details regarding their business
electronically on the Common Portal in FORM GST ENR-01. A unique enrolment number shall be generated and
communicated to them. A person in any other State or Union territory shall be deemed to be enrolled in the State or
Union Territory.
Every person engaged in the business of transporting goods shall maintain records of goods transported, delivered and
goods stored in transit by him and for each of his branches. Every owner or operator of a warehouse or godown shall
maintain books of accounts, with respect to the period for which particular goods remain in the warehouse, including
the particulars relating to dispatch, movement, receipt, and disposal of such goods. The goods shall be stored in such
manner that they can be identified item wise and owner wise and shall facilitate any physical verification or inspection,
if required at any time.
Fig. 1: Key points that are significant from perspective of maintain of accounts and records [2,
3].
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In the previous scenario, there were various types of taxes such as excise, custom, VAT, CST
and service tax etc. for different business transactions and cross utilization of input credit was
not allowed. Therefore, a taxpayer required to separate ledger accounts for every tax law. A list
of the few accounts was required to maintain in previous indirect tax by the manufacturer,
trader or businessman (apart from accounts like purchase, sale, and stock). For e.g., a trader Mr.
A must maintain the minimum basic accounts.
Under the GST regime, all indirect taxes are subsumed into one account and there is dual GST
structure based on intra-state supplies and inter-state supplies. The CGST (Central Goods and
Services Tax) and SGST (State Goods and Services Tax) is a charge on intra-state supplies
whereas IGST (Integrated Goods and Services Tax) is a charge on all inter-state
supplies[1].Therefore, a taxpayer separate ledger accounts are required to maintain related to
CGST, SGST and IGST[3]. The same trader Mr. A is now required to maintain the following
A/c’s (apart from A/c’s like purchase, sale and stock).
Input CGST A/c
Output CGST A/c
Input SGST A/c
Output SGST A/c
Input IGST A/c
Output IGST A/c
Electronic Cash Ledger (to be maintain on Government GST portal to pay GST)
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Ledger accounts were required to be Ledger accounts to be maintained under GST regime
maintained under previous tax regime
Accounts Taxpayer Accounts Remark
Fig. 2: Ledger accounts maintain under previous and under GST regime.
Revenue Ledger
Party Ledger
Item
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Maintenance of all Relevant Documents & Important points related to Accounts and
Records [3].
Documents: The taxpayer should keep and maintain all the important documents including
Invoices, bills of supply, delivery challans, credit notes, debit notes, receipt vouchers,
payment vouchers, refund vouchers and e-way bills.
Place of Maintenance of Accounts & Records: The taxpayer shall keep the books of
accounts and other records at the principal place of business. If multiple places of business are
specified in the certificate of GST registration, then accounts and records shall be kept at the
related business places.
Period for Retention: As per the GST law the registered taxpayer shall retain the books of
accounts and other records until the expiry of seventy-two months (6 Years) from the last date
of filing of Annual Return (GSTR-9) for the year related such books of accounts and records
for e.g. Period of Retention for Accounts of FY 2017-18. If the annual return for the FY 2017-
18 is filed on 30.12.2018, then the books of account and other records have to be maintained
till 30.12.2024.
Period of retention, in case of pending proceedings (appeal, revision etc.) is pending before any
GST appellate authority or tribunal of court, then the taxpayer shall retain the books of
accounts related to the subject matters of such proceedings:
o Until the expiry of one year from the date of final disposal proceeding, or The period
specified records under section 42(1), whichever is later
Or
o Until the expiry of six years from the due date of the annual return. Whichever is later?
Records maintenance in Electronic form: The taxpayer can also maintain accounts and other
records in electronic form. The records maintained in electronic form shall be authenticated
through digital signature. The taxpayer shall produce authenticated hard copy of records and
documents whenever demanded by the department.
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So now we are going to discussed all accounting entries pertaining to purchase and sales
transactions (Input or Output supplies of goods or services to intra-state and inter-state), set-off
of input credit against output tax liability, reverse charge transactions for supplier and receiver,
refunds under export of goods or services and import transactions.
Sequence of Set-off of Input Tax Credit against Output Tax Liability [2, 3, 5]
Rules for calculation of tax liability and tax credit
In case of Intra-State sale, CGST and SGST will be charged and IGST will not be
charged.
In case of Inter-State sale, only IGST will be charged and no CGST / SGST will be
charged.
Output CGST will be adjusted only with input CGST and thereafter for IGST.
Output SGST will be adjusted only with input SGST and thereafter for IGST.
Cross adjustment of CGST with SGST and SGST with CGST is not allowed
Output IGST will be adjusted first with Input IGST, then with CGST and last with
SGST.
The terms B2B and B2C stands for ‘Business to Business’ and ‘Business to Consumers’,
these two are completely different type of transactions as far as GST is concerned because the
intention of transaction are totally different. B2B and B2C are totally different transactions as
far as GST is concerned. A single common provision in GST could also not be able to deal
with these two transactions impartially. The OECD has also suggested and drafted two
different sets of principles for cross border transaction to deal with B2B and B2C transactions.
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Transaction having a value above INR 2.5 Lacs. Transaction having a value less than INR 2.5 Lacs at the Inter-
State level and a transaction in Intra-State level with no limit.
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A supplier cannot take input tax credit of GST paid on Goods and Services used to make supplies on which the recipient
is liable to pay tax under reverse charge.
Fig.
The recipient can6: Input
avail InputTax Credit
Tax Credit under
of GST Reverse
amount Charge
that is paid Mechanism
under reverse inreceived
charge on GST regime.
of goods or services
by him.
GST paid on Goods or Services under reverse charge mechanism is available as ITC to the registered dealer/person
provided that such Goods or Services are used or will be used for business or furtherance of business.
The ITC is available by recipient cannot be used towards payment of Output Tax on Goods or Services, the payment of
tax under reverse charge only on cash.
Fig. 6: Input Tax Credit under Reverse Charge Mechanism in GST regime.
Reverse Charge Mechanism (RCM) Provisions applicability under GST: INR 5,000 per
day Transaction Limit
According to Section 9(4) of CGST Act, 2016, in respect of the supply of taxable goods or of
services or both by a supplier, who is an unregistered dealer or person (URD/URP) to a
registered dealer or person and tax shall be paid on such goods or services or both by such
registered dealer or person as if he is the person liable for paying tax.
Applicability of such exemption shall not be applicable where the aggregate value of such
supplies of goods and services or both received by a registered person from any or all the
supplies, who is or are not registered, exceeds INR 5,000 per day.
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Composition Scheme permit a registered taxable person, whose The taxable person should not affect any Inter-State supplies of
aggregate turnover in a financial year does not exceed INR 50 goods or of services or both
lacs, to pay tax at the rate not exceeding 1%, of the turnover.
This scheme would be applicable only to taxable person whose Person opting to pay tax under the Composition Scheme is
supplies are restricted to a particular State. In other words, a prohibited from collecting tax.
person effecting Inter-State supplies cannot opt for this scheme.
The taxable person should make an application exercising his Taxable person opting to pay tax under the composition
option to pay tax under this scheme. Once granted, the eligibility scheme will not be eligible for any Input tax Credit.
would be valid unless his permission is cancelled under law or
he becomes ineligible. There may be other conditions or restrictions which may be
prescribed under the Rules.
Let, I consider a few basic accounting transactions with the help of an examples for more
clarification (all amounts excluding GST) for the manufacturer, traders and service providers.
Illustration 1 Journal entries in the books of Entity A, had the following transactions in July
2017.
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GST is a globally accepted tax system and therefore, through it, India can boost its economy
but what it needs is an efficient administration and excellent implementation of GST. To
achieve its goal 'one tax one market' cohesive tax approach is very important. An ambitious
indirect tax reforms from the previous taxation procedures to GST regime, it may simplify the
remittance procedure, is bound to destabilize the indirect tax accounting as well as financial
reporting aspects of a majority of businesses. In order to easily digitize and streamline any
entities records maintenance, accounting and taxation procedures, standardization of invoice
capturing process, for both sales and purchases and statutory compliance requisites. As an
impact of input tax credit GST is likely to bring significant benefits to organizations by way of
tax credit. It is a well-established accounting principle that refundable taxes are not considered
as part of cost of acquisition of asset/expense and are accounted as an asset. Transition to GST
will require companies to reconfigure their inventory valuation or asset capitalization or
expense recording rules in their accounting system to ensure tax credits are accounted
appropriately in the GST regime. In a GST regime, the new COA for financial reporting will
depend on the type of business, credit availment rules and place of supply etc.
REFERENCES
1. The Institute of Cost Accountants of India. An Insight of Goods & Services Tax (GST) in
India (Volume I). India, 2015.
2. Central Board of Excise and Customs. Central Goods and Services Tax (CGST) Rules,
(Notification vide Notification No. 03 dated 19th June 2017, 07 dated 27th June 2017, 10
dated 28th June 2017, 15 dated 1st July 2017, 17 dated 27th July 2017, 22 dated 17th August
2017 and 27 dated 30th August 2017). India, DC: New Delhi GOI the Gazette of India,
2017.
3. Central Board of Excise and Customs. Notification No. 10/2017 – Central Tax dated 28th
June 2017, 2017. India, DC: New Delhi GOI the Gazette of India, 2017.
4. Central Board of Excise and Customs. (2017). The Central Goods and Services Tax Act,
2017 (No. 12 of 2017) dated 12th April 2017, 2017. India, DC: New Delhi GOI the Gazette
of India, 2017.
5. C. P. Goyal, E-book (No. 1) on Transactional Provisions on Input Tax Credit. India, 2017.
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