Indirect Tax (GST)
Indirect-tax at Y.K. Purohit & Associates covers GST registration, the monthly and annual return cycle, reconciliation in Form GSTR-9C, export refund advisory, and representation before GST officers and the Appellate Authority.
GST law has been amended repeatedly since rollout in 2017 — returns, thresholds, audit requirements and refund rules have all moved. We run the full compliance cycle (new registrations, monthly filings, annual reconciliation, refund claims) and defend clients in scrutiny, search, and appellate proceedings.
Goods and Services Tax (GST)
End-to-end GST work — registration, compliance, annual reconciliation, refunds, representation and advance rulings.
GST compliance
GST registration is mandatory once aggregate turnover crosses ₹40 lakh for suppliers of goods or ₹20 lakh for suppliers of services (lower thresholds apply to special-category states).
We handle the recurring GST calendar end to end — registration, monthly returns, annual returns, Letters of Undertaking, and the assorted forms and declarations the GST common portal requires.
- GST registration — applicability review, state selection, documentation, and filing on the common portal.
- Monthly returns — GSTR-1 (outward supplies), GSTR-3B (summary + tax payment), GSTR-IFF where applicable under QRMP.
- Annual return (Form GSTR-9) — mandatory for registered persons with aggregate turnover above ₹2 crore.
- Final return (Form GSTR-10) — on cancellation of GST registration, within three months of the date of cancellation order.
- Letter of Undertaking (LUT) — filing each financial year so exporters can supply without payment of IGST (Rule 96A).
- Other forms and declarations — ITC-04 (job work), RFD-11 (LUT), PMT-03, PMT-09 etc. as they arise.
GSTR-9C — reconciliation and annual return
Registered persons with aggregate turnover above ₹5 crore must file Form GSTR-9C — the reconciliation between audited financials and the annual return — self-certified by the taxpayer.
The mandatory CA audit under Section 35(5) of the CGST Act was removed by the Finance Act 2021 (effective from FY 2020–21). Form GSTR-9C is now self-certified by the taxpayer, but most businesses still engage a chartered accountancy firm to prepare the reconciliation — the complexity of mapping audited books to GST returns, ITC ledgers and turnover definitions is unchanged.
- Preparation and filing of Form GSTR-9 (annual return) with supporting workings.
- Reconciliation between books of account and the annual return — outward supplies, ITC, tax liability.
- Identification of errors carried from monthly returns (short-payment, ITC mismatches, classification issues) and the appropriate rectification route — DRC-03, ITC reversal, credit reclaim.
- Preparation and filing of Form GSTR-9C on the GST common portal.
Early implementation of GST (FY 2017–18 and 2018–19) is still a common source of open issues — short-paid RCM liabilities, ITC timing errors, and export refund mismatches. We work through these systematically before signing off on the annual return.
Representation and litigation
Under Section 116 of the CGST Act, 2017 we can appear before GST officers, the Appellate Authority, and the Appellate Tribunal on your behalf as your authorised representative.
Section 116(2) sets out who may act as an authorised representative — relatives, regular employees, advocates, chartered accountants, cost accountants, company secretaries, retired Commercial Tax Department officers (subject to conditions), and registered GST practitioners.
- Before the GST officer — assessments, scrutiny of returns under Section 61, audit under Section 65, special audit under Section 66, inspections / search / seizure under Section 67, and responses to summons and notices.
- Before the Appellate Authority — appeals under Section 107 against orders passed by a GST officer; pre-deposit workings and grounds drafting.
- Revisions — revision petitions under Section 108 against orders otherwise appealable.
- Demand and recovery proceedings — replies to show-cause notices under Sections 73 / 74, representation at personal hearings, and negotiation of payments under DRC-03.
Refund advisory (exports, inverted duty, excess cash)
Exporters can claim GST refund either on unutilised ITC (supplies under LUT without IGST) or on tax paid on zero-rated supplies — we run a cost-benefit on which route suits each financial year.
The refund options available under Section 54 include: ITC accumulated on zero-rated supplies, ITC accumulated due to inverted duty structure, excess balance in electronic cash ledger, and tax paid on exports where LUT was not filed.
- Eligibility and route selection — LUT vs. rebate, inverted duty rule, excess balance — with a working out of net working-capital impact.
- Online application via Form RFD-01 on the GST common portal, supported by Annexure-A / Annexure-B.
- Documentation setup — shipping bills, BRCs, FIRCs, supplier invoices and e-invoices, payment evidence.
- Reconciliation of ITC claimed in GSTR-3B against ITC auto-populated in GSTR-2B / GSTR-2A, to catch missed credits.
- Follow-through with the Refund Sanctioning Authority until Form RFD-06 is issued and the credit hits the bank account.
Advisory and written opinions
GST touches every business transaction, so the right question is usually asked before the deal closes — we give structured opinions on classification, ITC eligibility, and merger / restructuring implications.
- Transaction structuring — intra-group supplies, branch transfers, job work, e-commerce operator flows, and cross-state billings.
- Mergers, slump sales, demergers and asset transfers — Section 18(3) ITC transfer on change in constitution; Schedule II classification issues.
- ITC utilisation strategy — Rule 42 / 43 reversal, blocked credits under Section 17(5), cross-utilisation within a registration and within the same PAN.
- Startup advisory — whether to register voluntarily, place of supply and cross-border digital service rules, composition vs. regular.
- Written opinions on classification, rate, place-of-supply and time-of-supply questions where the position is not obvious from the Act and circulars alone.
Advance ruling
A GST advance ruling gives binding clarity under Section 97 on classification, applicability of a notification, ITC eligibility, registration requirement, or whether a proposed transaction attracts GST — before you commit to the transaction.
- Pre-assessment of whether an advance ruling is actually advisable — the ruling binds the applicant and the tax authorities within the state, so asking the wrong question can be worse than not asking.
- Preparation and filing of the application in Form GST ARA-01, with supporting documentation.
- Representation before the Authority for Advance Ruling (AAR) and the Appellate Authority for Advance Ruling (AAAR) if the ruling needs challenging.
- Implementation advisory once the ruling is issued — bookkeeping, invoice template, return disclosures.
Frequently asked questions
Short answers to the questions we hear most often about indirect tax (gst).
When is GST registration mandatory?
Registration is mandatory once your aggregate turnover crosses ₹40 lakh in a financial year for suppliers of goods, or ₹20 lakh for suppliers of services (₹20 lakh and ₹10 lakh respectively for special-category states). Certain categories — inter-state suppliers, e-commerce operators, casual taxable persons, persons liable to pay GST under reverse charge — must register regardless of turnover. Voluntary registration is allowed and often makes sense if your customers need to claim ITC on your invoices.
Who needs to file Form GSTR-9C?
Form GSTR-9C — the reconciliation statement between audited financials and the annual return — is mandatory for registered persons with aggregate turnover above ₹5 crore in a financial year. Since the Finance Act 2021 it is self-certified by the taxpayer (the earlier CA audit requirement under Section 35(5) was withdrawn effective FY 2020–21). Most mid-market businesses still engage a CA firm to prepare GSTR-9C because the reconciliation is the same exercise; only the certification language changed.
Who can represent me in a GST proceeding?
Under Section 116(2) of the CGST Act the list of permitted authorised representatives is fixed: a relative or regular employee, an advocate, a chartered accountant, cost accountant or company secretary holding a valid certificate of practice, a retired Commercial Tax Department officer of Group B rank or above (subject to a one-year cooling-off period), and a registered GST practitioner. We appear under the CA head and use the firm's authorisation letter in Form GST PCT-01 where the practitioner route applies.
How do exporters claim a GST refund?
Exporters typically supply under a Letter of Undertaking (LUT) — no IGST charged — and then claim a refund of the unutilised input tax credit. Alternatively, they can pay IGST on the export and claim a rebate. The LUT route usually wins on cash flow because no IGST is blocked; the rebate route can win when the inverted-duty profile means ITC would not otherwise be absorbed. The refund application is filed online in Form RFD-01 with supporting Annexure-A, shipping bills, BRCs and invoice reconciliation.
What is an LUT and when do I need to file it?
A Letter of Undertaking is filed in Form GST RFD-11 at the start of each financial year by persons who intend to supply goods or services for export (or to SEZ units) without payment of IGST. You declare, in the LUT, that IGST will be paid with interest within the period specified in Rule 96A if the export does not actually take place. Without a valid LUT for the year, every zero-rated supply has to be made by paying IGST upfront and then claiming a rebate — a slower and more working-capital-intensive path.
When should I apply for a GST advance ruling?
Apply when the classification, rate, applicability of a notification, ITC eligibility, or place-of-supply for a specific transaction or arrangement is genuinely unclear on the Act and circulars alone, and the amounts involved justify formal certainty. A ruling under Section 97 binds the applicant and the tax authorities within the issuing state. Avoid filing on well-settled points — a ruling the wrong way on an "obvious" question can bind you to an adverse position. We screen every proposed question carefully before filing.
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