CA Certificate Formats u/s 18(4) of CGST Act/SGST Act
ICAI indirect tax Committee has issued the issued a set of various draft ‘ Certificates under GST Law (SGST/ CGST Acts)
Certificate under the State Goods and Services Tax Act, 2017 (in short “SGST Act”) and the Central
Goods and Services Tax Act, 2017 (in short “CGST Act”) in terms of Section 18(4) of the said Acts
(Registered person who opts to pay tax under section 10)
1. M/s. __________________ (hereinafter referred to as the “Applicant’) is a registered person
vide GSTIN…………… and is having its principal place of business at
____________________________________________________ in the State of _______. The
Applicant has the following additional places of business duly registered in the State of _____:
The principal place of business and the additional places of business in the State of State have
been duly registered with effect from ____________.
2. The Applicant has been paying taxes u/s 9 of the CGST / SGST Acts, 2017 w.e.f. _______ up
to__________. On and from__________, the Applicant ceases to pay tax u/s 9 and has opted to pay tax under Section 10 of the CGST / SGST Acts, 2017.
3. In terms of Section 18(4) of the CGST and SGST Acts, the Applicant who has availed input tax
credit opts to pay tax under Section 10 of the CGST and SGST Acts, shall be liable pay an amount,
by way of debit in the electronic credit ledger or electronic cash ledger, equivalent to the credit of
input tax in respect of inputs held in stock and inputs contained in semi-finished or finished goods
held in stock on the day immediately preceding the date of exercising the option to pay tax u/s 9 of
the CGST / SGST Acts, 2017, as on___________.
4. We have examined the books of accounts and other relevant documents / records of the
Applicant and on the basis of such examination & the information and explanation furnished
to us, we hereby certify that, subject to our remarks / comments in para 6 infra, the Applicant
is required to pay an amount of Rs …………., by way of debit in the electronic credit ledger
or electronic cash ledger, equivalent to the credit of input tax in respect of inputs held in stock
and capital goods where tax invoices are not available with it on the day immediately
preceding the date from which it opts to pay tax under Section 10 of the CGST and SGST
5. The relevant details of inputs held in stock and capital goods as on _______________ (that is the day preceding the date from which he becomes liable to pay tax u/s 9 of the CGST / SGST Acts,
2017) where whose tax invoices are not available with the Applicant Assessee and the
corresponding input tax credit is provided as Appendix A.
6. Remarks / comments (Refer Para 4 supra):
a. The description, value along with rate of GST of the inputs held in stock on the day
immediately preceding the date on which the Applicant opts to pay tax u/s 10 of the CGST /
SGST Acts, 2017 i.e. ______________, whose invoices are not available with the Applicant,
is based on the management certificate furnished to us on_____________. According to the
management certificate, the value of inputs as such and capital goods is an estimated price of
such goods which is based on their prevailing market price as on_______________.
b. These estimates have been worked on as per the requirement of Section 18(4) of
SGST/CGST Acts, 2017 read with Rule 44(5) of CGST/SGST Rules, 2017 by the Applicant
and we have reviewed their assumptions and workings. Based on our examination of the
evidence supporting the assumptions, nothing has come to our attention, which causes us to
believe that assumptions do not provide a reasonable basis for the estimate. Actual results are
likely to be different from the estimate since anticipated events might not occur as expected
and the variation might be material.
c. The stocks have not been physically verified. Reliance has been placed on the declaration
given by the Applicant in respect of quantity of stocks held by it as on
________________whose invoices are not available with it.
7. This certificate has been issued in terms of Section 18(4) of the SGST / CGST Acts, 2017 read
with Rule 44 (5) of the CGST / SGST Rules, 2017.
Firm Registration Number: _______
Membership Number: ______
Check points for the Chartered Accountant –
i. This certificate is required to be issued only if the tax invoices related to the inputs held in stock,
inputs contained in semi-finished or finished goods held in stock and on capital goods are not
available (Rule 44 (3) and Rule 44(5) of the CGST / SGST Rules, 2017). It may be noted that the
above said Rule 44 (3) stipulates issuance of a Certificate only in cases of non-possession of
invoices. The said Rule does not speak of issuance of Certificate if the registered person is in
possession of the relevant tax invoices
ii. Verify registration particulars with the Registration Certificate.
iii. Check whether declaration in Form GST ITC-03 is filed by the tax payer on GST portal declaring
the above amounts in the respective columns.
iv. Ensure the turnover is within the limits as specified u/s 10 (1) and 10 (3) of the CGST / SGST
Act, 2017. Aggregate turnover has to be computed in terms of Section 2(6) of the CGST / SGST
v. Check computation of input tax credit to be reversed by multiplying the effective rate of tax
specified under Notification 1/2017-CT (Rate) dated 28.06.2017, as amended from time to time,
with the estimated value of inputs or input contained in semi-finished or finished goods.
vi. Ensure that the amount is determined separately for input tax credit of Central Tax, State Tax,
Union Territory Tax and Integrated Tax and verified / reconciled with the ledger balances.
vii. The date on which the applicant has opted to pay tax u/s 10 of the CGST / SGST Act, 2017 should
be thoroughly verified. The applicability of conditions meted out under the GST laws for a tax
payer opting to pay tax u/s 10 of the CGST / SGST Act, 2017 should be checked to confirm the
above said date.
viii. In case there are stock-in-transits as on the specified date of eligibility of credits, appropriate
treatment to be considered. (Note: Practical difficulty may arise to determine the credit amount
and invoice-wise details of items consumed at WIP / semi-finished and finished goods stage. This
may be computed by way of a fixed % and relevant assumptions / note may be included in the
ix. Verify and cross check the details which have been filed in Form GST CMP-02 which is an
intimation to opt to pay tax under Section 10 of CGST/SGST Act, 2017.
x. Check reversal of credit in Electronic Credit Ledger and payment in Electronic Cash Ledger of the
amount as specified in GST ITC -03
xi. This certificate is to be suitably modified wherever applicable. The names of the registered
persons, dates, addresses etc. are only illustrative and needs to be modified in each case. Any
resemblance to any person / place is purely unintentional.
xii. This certificate is to be issued in respect of a person who ceases to pay tax u/s 9 of the CGST /
SGST Acts, 2017 and opts to pay tax u/s 10 of the CGST / SGST Acts, 2017.
xiii. Ensure that the certificate issued is in accordance with the Guidance note on Reports and
Certificates for special purpose issued by the ICAI.
xiv. Ensure that a letter of representation is taken from the management for the details and information provided by them.
xv. Ensure that a declaration is taken from the Applicant with regard to non-availability of tax
invoices and reasons for the same.
Appendix A to Certificate issued under the State Goods and Services Tax Act, 2017 (in short “SGST Act”) and the Central Goods and Services Tax Act, 2017 (in short “CGST Act”) in terms of section 18(4) of the said Acts
Summary of stock of inputs held in stock and capital goods on which input tax credit is required to be paid under section 18(4)-whose invoices are not available
Firm Registration No.:
This is as per ICAI indirect tax Committee draft ‘ Certificates under GST Law (SGST/ CGST Acts)‘, with a list of checkpoints to be reviewed by Chartered Accountants before issuing the respective certificates, as listed here-under:CA Certificates under GST Law : ICAI issued Draft Formats