GST Audit turnover limit for FY 2018-19

Everyone is aware about applicability of GST audit as per Rule 80(3), every registered person whose aggregate turnover during a financial year exceeds 2 crores rupees shall get his accounts audited as specified under sub-section (5) of section 35 and he shall furnish a copy of audited annual accounts and a reconciliation statement, duly certified, in FORM GSTR-9C, electronically through the common portal either directly or through a Facilitation Centre notified by the Commissioner.

However, there seems to be a lot of confusion about the GST audit turnover limit for FY 2018-19. GST audit limit is Rs. 5 crores or Rs. 2 crores for FY 2018-19? GSTR-9 for taxpayers having turnover below 2 crores is optional or not ? GSTR-9 for taxpayers having turnover above 2 crore but less than 5 crores? Let’s find out the answer to all these Qs.

✅GST audit limit is Rs. 5 Crore or Rs. 2 Crore for FY 2018-19?
Rule 80(3) prescribed GST audit turnover limit of Rs. 2 Crore, but Notification No. 16/2020 – Central Tax dated 23rd March 2020 inserted a proviso under rule 80(3), which clearly state that, every registered person whose aggregate turnover during the financial year 2018-2019 exceeds five crore rupees shall get his accounts audited as specified under subsection (5) of section 35 and he shall furnish a copy of audited annual accounts and a reconciliation statement, duly certified, in FORM GSTR-9C.

So, it is clear GST audit turnover limit is Rs 5 crores for FY 2018-19

✅GSTR-9 for taxpayers having turnover below 2 crores for the FY 2018-19?
As per Notification No. 47/2019 – Central Tax dated 9th October 2019 and Circular No. 124/43/2019 – GST dated 18th November 2019, filing of GSTR-9 for those taxpayer having turnover less than Rs. 2 crore is optional. But, the said return shall be deemed to be furnished on the due date if it has not been furnished before the due date.

Now, it is also clear GSTR-9 is optional for taxpayers having turnover below Rs. 2 crores, but advisable to file it before due date.

✅GSTR-9 for taxpayers having turnover above Rs. 2 crores but less than Rs. 5 crores?
As per combine reading of notification no 16/2020 and notification no 47/2019 along with circular no 124/43/2019, it is clear GSTR-9 is mandatory for those taxpayers having turnover between Rs 2 crores and Rs. 5 crores.

Summary of the above discussion is simplified in the table: