GST Audit is required even though taxable turnover is less than 2 crore, and last date for GST audit is 30.06.2019
Legal Text is given below for referance:
Section 35(5) of CGST Act 2017
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 and shall submit a copy of the audited annual accounts, the reconciliation statement under sub-section (2) of section 44 and such other documents in such form and manner as may be prescribed.
Section 2(6) of CGST Act 2017
“Aggregate turnover” means the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess;
Rule 80(3) of CGST Rules 2017
Every registered person whose aggregate turnover during a financial year exceeds two crore 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.
As per the Legal Text GST Audit will apply every year for those GST registered business (GSTIN) whose turnover by supply of goods or service is more than Rs 2 crores.
Also the turnover will be taken for whole year, therefore the turnover value of first quarter of pre GST period will be added to calculate Aggregate Turnover.
Definition of turnover for GST audit : Now Aggregate turnover is defined as turnover inclusive of taxable, exempt and nil rated supply.
For Example :
Alcoholic liquor for human consumption is exempt from GST however it will still be part of aggregate turnover for GST Audit.
Similarly, Stock transfer or self supplies done on would also be considered for the aggregate turnover for GST Audit.
Even if someone has taken registration by virtue of reverse charge mechanism of section 9(3) of CGST act and are primarily in business of dealing in exempt goods or services, they would still need to be audited under GST if turnover exceed the threshold limit of 2 crore. For example generally schools or hospitals are not required to take GST registration unless they take services liable to be paid under reverse charge or providing taxable services like sale of relevant materials. Once a dealer is registered his aggregate turnover would be considered for the limit of GST audit.
Also an important thing to note here is that Aggregate turnover is calculated on PAN basis but GST Audit is done registration basis. It means if someone is having multiple registration on single PAN they need to have multiple GST audit once PAN based turnover exceeds the limit of Rs. 2 crore.
So overall we can infer that there can be situations when GST Audit is required even though taxable turnover is less than 2 crore, and last date for GST audit is 30.06.2019.