The Goods and Services Tax (GST), launched in India on July 1, 2017, streamlined indirect taxation, and Chartered Accountants (CAs) play a vital role in ensuring compliance through certifications. In the present blog eleven GST matters requiring CA certificates are listed. This blog provides a brief overview of these certifications, including GST refunds, to assist CAs in fulfilling their responsibilities.
List of GST CA Certificates
- 1. Certificate under Section 18(1)(a) of the CGST Act
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Purpose:
Certifies ITC eligibility for inputs held in stock, semi-finished, or finished goods on the day before a person becomes liable to pay tax, upon applying for registration within 30 days and receiving approval. -
Details:
Required for claims exceeding Rs. 2 lakh, filed via Form GST ITC-01 per Rule 40(1)(d). The CA verifies stock quantities, values, and tax invoices (not older than one year) to ensure compliance.
- 2. Certificate under Section 18(1)(b) of the CGST Act
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Purpose:
Verifies ITC for inputs in stock, semi-finished, or finished goods on the day before the grant of voluntary registration under Section 25(3). -
Details:
Mandatory for claims over Rs. 2 lakh, declared in Form GST ITC-01. The CA confirms stock details and ensures the applicant was not liable for mandatory registration under Sections 22 or 24.
- 3. Certificate under Section 18(1)(c) of the CGST Act
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Purpose:
Certifies ITC for inputs, semi-finished or finished goods, and capital goods (reduced by prescribed percentage points) when a registered person transitions from the composition scheme (Section 10) to the regular scheme (Section 9). -
Details:
Required for claims exceeding Rs. 2 lakh, filed in Form GST ITC-01. The CA verifies stock, invoices, and capital goods’ remaining useful life per Rule 40.
- 4. Certificate under Section 18(1)(d) of the CGST Act
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Purpose:
Verifies ITC for inputs, semi-finished or finished goods, and capital goods when a registered person’s exempt supplies become taxable. -
Details:
Needed for claims over Rs. 2 lakh, declared in Form GST ITC-01. The CA ensures compliance with Rule 40, verifying stock and tax invoices.
- 5. Certificate under Section 18(3) of the CGST Act
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Purpose:
Certifies the transfer of ITC due to a change in business constitution (e.g., sale, merger, or transfer). -
Details:
Involves Form GST ITC-02. The CA verifies the ITC amount transferred, ensuring alignment with GST provisions and records.
- 6. Certificate under Section 54 of the CGST Act (GST Refund)
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Purpose:
Certifies the accuracy of refund claims exceeding Rs. 2 lakh, including ITC or tax paid details, to ensure compliance with refund provisions. -
Details:
As per Rule 89(2)(m) of the CGST Rules, 2017, a CA certificate is required for refund applications under Section 54, particularly for exports, inverted duty structure, or excess tax paid, where the claim exceeds Rs. 2 lakh. The CA verifies the refund application against books of accounts, invoices, and other records, ensuring the amount claimed is accurate and complies with conditions like non-availment of ITC for exempt supplies or adherence to export documentation.
- 7. Certificate under Section 29(5) of the CGST Act
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Purpose:
Certifies the amount payable equivalent to ITC on inputs, semi-finished or finished goods, and capital goods upon cancellation of registration. -
Details:
Filed in Form GSTR-10 per Rule 44(5). The CA verifies stock and estimates values if invoices are unavailable.
- 8. Certificate under Section 18(4) of the CGST Act – Regular to Composition Scheme
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Purpose:
Certifies the reversal of ITC on inputs, semi-finished or finished goods, and capital goods when a registered person opts for the composition scheme under Section 10. -
Details:
Required when tax invoices are unavailable, filed in Form GST ITC-03 per Rule 44(5). The CA verifies estimated values based on prevailing market prices.
- 9. Certificate under Section 18(4) of the CGST Act – Taxable Supplies Become Wholly Exempt
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Purpose:
Verifies the reversal of ITC on inputs, semi-finished or finished goods, and capital goods when taxable supplies become wholly exempt. -
Details:
Filed in Form GST ITC-03 per Rule 44(5) if invoices are unavailable. The CA confirms estimated values and compliance with exemption notifications.
- 10. Certificate for Credit Mismatch
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Purpose:
Certifies that the supplier has paid tax on supplies covered by mismatched invoices, as per CBIC Circulars No. 183/15/2022-GST and No. 193/05/2023-GST, when ITC claimed in Form GSTR-3B exceeds Form GSTR-2A by over Rs. 5 lakh (or Rs. 2.5 lakh each for CGST/SGST). -
Details:
The CA verifies tax payment via Form GSTR-3B, ensuring compliance with Section 16(2)(c), focusing on supplier records, not recipient ITC admissibility.
- 11. Certificate for GST Refund Issues (Additional Context)
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Purpose:
Specifically addresses refund-related certifications beyond Section 54, where CAs may be required to certify additional aspects, such as the incidence of tax not passed on to another person (Rule 89(2)(f)) or compliance with specific refund conditions (e.g., for SEZ units or deemed exports). -
Details:
For refunds under Section 54, particularly for zero-rated supplies (exports or SEZ supplies) or inverted duty structure, a CA certificate may be required to confirm that the tax burden has not been passed on, as per Rule 89(2)(f), or to validate specific documentation (e.g., shipping bills, bank realization certificates). The CA verifies financial records, export documents, and compliance with refund conditions, ensuring the claim’s legitimacy.
How We Help Your Busines..?
Our CA team ensures your certifications are accurate and compliant by:
- Reviewing your books, invoices, and GST filings thoroughly.
- Following ICAI’s strict guidelines for certifications.
- Providing clear, authority-specific certificates to avoid misuse.
- Guiding you on required documents, like management representations or export proofs.
- Some certifications, like those for ITC reversals, may require estimating stock values if invoices are missing. We’ll guide you to ensure these estimates comply with GST rules. Timely submission of forms (e.g., GST ITC-01, RFD-01) is critical, and we’ll guide you meet deadlines.
