GSTR 9C is a reconciliation statement that businesses registered under the Goods and Services Tax (GST) regime are required to file on an annual basis. It is essentially a GST audit form that businesses must use to reconcile the information provided in their annual return (GSTR 9 reconciliation) and their audited financial statements.
GSTR 9C is required to be filed by businesses with an annual turnover of more than ₹2 Crores in a financial year. It is important to note that filling GSTR 9C is separate from the regular monthly or quarterly GST returns that businesses are required to file.
GSTR 9C filing is a very significant process for businesses registered under the Goods and Services Tax (GST) regime. It serves the following purposes:
Ensures accuracy and transparency: GSTR 9C helps compare the information provided in the GST annual return (GSTR 9) and the audited financial statements. This ensures that the information provided is accurate and transparent.
Helps identify errors and discrepancies: The reconciliation process involved in GSTR 9C helps businesses identify any discrepancies or errors in their financial records or GST returns. This enables them to rectify the same before filing.
Minimises the risk of non-compliance: Filing GSTR 9C is mandatory for businesses with an annual turnover of more than ₹2 Crores. Failure to file GSTR 9C or filing incorrect information can result in penalties and fines, thereby encouraging businesses to comply with GST regulations.
Facilitates the audit process: GSTR 9C return filing serves as an important document during audits conducted by the GST authorities. Having accurate information and a certified reconciliation statement can help businesses avoid any penalties or issues during the audit process.
GSTR 9C reconciliation has to be filed by every taxpayer who gets their annual reports audited. Before the GSTR 9C is filed, it has to be certified by a chartered accountant or cost accountant. The form can be filed online through the GST portal or at a facilitation centre.
When filing the GSTR 9C, the taxpayer must include documents such as the annual returns and a copy of the audited accounts.
GSTR 9C is required to be filed by taxpayers whose annual turnover exceeds ₹2 Crore during the financial year. It is crucial to be aware of this requirement, as failing to do so will attract penalties.
The due date for filing GSTR 9C is the same as that of GSTR 9, which is 31st December of the subsequent financial year. This means that for the financial year 2022-23, the due date for filing GSTR 9C is 31st December 2023. It is important to note that GSTR 9C cannot be filed without first filing GSTR 9.
The Central Board of Indirect Taxes and Customs (CBIC) has introduced several measures to simplify the filing of GSTR 9C. Here are some of the ways to simplify the GSTR 9C filing process:
Prepare the accounts and reconcile them with the returns on a regular basis, to avoid any last-minute rush or errors.
Use automated accounting and reconciliation software to reconcile the data easily and accurately.
Keep proper documentation of all the financial transactions and supporting documents, as they may be required during the audit process.
Use the offline utility tool provided by the GST portal to simplify the process of preparing and filing GSTR 9C.
Seek the help of a professional, such as a chartered accountant, to ensure that all the details are correctly entered and the filing is done accurately.
You can file GSTR 9C online on the GST portal (www.gst.gov.in) under the "Services" tab. It is fairly easy to locate and the process is easy to complete. However, it may be wise to get help with this process, especially if it is your first time.
GSTR 9C comprises two main parts – A and B. Part A is known as the statement of reconciliation, and Part B refers to the certification of the reconciliation statement.
This part is populated with information on turnover, taxes paid, and input tax credit collected on a given GSTIN, as reflected in the audit books of a firm/company. The statement of reconciliation of GSTR 9C form is further divided into the following subsections:
This section requires the taxpayer to fill in basic information such as GSTIN, financial year, and legal and trade names. Also, the taxpayer needs to provide the details of any audit law that they might be subject to.
This involves an entry of the total turnover, both taxable and gross, as filed in the GSTR 9, along with the audited financial statements. This would require detailed segregation of the Audited Financial Statements (AFS) at the GSTIN level to be reported on GSTR 9C. As per the recent Central Board of Indirect Taxes & Customs notification, declaration of turnover adjustments in tables from 5B to 5N is now optional and all the necessary adjustments shall be mentioned in table 5O.
In this section, slab-wise GST liability is to be mentioned as per the audited accounts as well as the actual tax paid as per the GSTR-9 filed by the business. Any differences between the two values also need to be recorded in this section, and the taxpayers must declare any additional tax liability arising out of such unreconciled differences.
This part comprises the reconciliation of net ITC (Input Tax Credit) claimed and used by the taxpayers as declared in GSTR 9 and the AFS (Audited Financial Statements). However, the details of tables 12B, 12C, and 14 were made optional for FY 2020-21, and the taxpayer could choose to skip filling in the details for the same:
Table 14- Detailed break up of reconciliation of ITC as stated in GSTR 9 with ITC claimed on expenses as per AFS or account books.
12C- ITC recorded in the present financial year to be claimed in the succeeding financial years.
12B – ITC recorded in previous financial years as claimed in the present financial year.
In this section, the auditor needs to declare any outstanding tax highlighted in the process of reconciliation and GST audit. This tax liability could be gathered from the non-reconciliation of ITC or turnover based on:
Amount incurred towards supplies but missing from GSTR
Refund initiated erroneously and therefore must be returned
Any other outstanding liabilities pending settlement
Lastly, the GSTR 9C format provides the taxpayers with an option to settle the outstanding taxes as suggested by the auditor towards the closing of the reconciliation statement.
After the reconciliation process, the GSTR 9C for a given GSTIN may be certified by the CA who performed the GST audit or any other CA who was not part of the GST audit.
In case of a certification by a CA who did not perform the audit, they must have reached an opinion based on the account books audited by the CA in the reconciliation statement.
The GSTR 9C format consists of two parts, Part A and Part B, which are as follows:
This part includes the basic details of the taxpayer, such as name, GSTIN, financial year for which GSTR 9C is being filed, etc.
Reconciliation of turnover declared in audited financial statements with turnover declared in Annual Return (GSTR-9):
This part requires reconciliation of the turnover declared in the audited financial statements with the turnover declared in GSTR-9.
In this part, reconciliation of the tax paid as per the audited financial statements with the tax paid as per the GSTR-9 is required.
This part requires reconciliation of the ITC claimed as per the audited financial statements with the ITC claimed as per the GSTR-9.
Any other reconciliation required between the audited financial statements and the GSTR-9 should be mentioned in this part.
The auditor should provide a certificate in this part stating that the reconciliation statement in Part A has been verified and found to be true and correct.
The taxpayer should provide a certificate in this part stating that they have provided all the required information for the reconciliation statement in Part A, and that it is true and correct to the best of their knowledge.
The due date for filing GSTR 9C is on or before December 31st of the subsequent financial year. If the taxpayer fails to file GSTR 9C by the due date, a late fee of ₹200 per day of delay (₹100 per day for CGST and SGST, respectively) up to a maximum of 0.5% of the taxpayer's total turnover in the respective financial year, will be levied.
Additionally, if the taxpayer fails to file GSTR 9C within one year from the due date, a penalty of ₹50 per day (₹25 per day for CGST and SGST, respectively) will be levied until the GSTR 9C is filed or the amount of penalty reaches the maximum of 0.5% of the taxpayer's total turnover in the respective financial year, whichever is lower.
It is important to note that the late fees and penalties for non-filing or late filing of GSTR 9C cannot be waived or reduced under any circumstances. Therefore, it is essential for taxpayers to ensure timely filing of GSTR 9C to avoid any financial burden.
To file GSTR 9C, the following credentials and documents are needed:
GSTIN (Goods and Services Tax Identification Number) of the registered taxpayer.
Username and password to access the GST portal.
Digital signature certificate (DSC) for authentication purposes.
Auditor's report in Form GSTR 9C, duly signed by a chartered accountant.
Audited annual financial statements including the balance sheet, profit and loss account, and cash flow statement.
Details of all invoices, debit notes, credit notes, and other relevant documents for the financial year being audited.
Details of all outward and inward supplies made during the financial year.
Details of Input Tax Credit (ITC) availed and utilised during the financial year.
A reconciliation statement between the audited financial statements and the annual return in Form GSTR 9.
Any other relevant documents as required by the auditor or the GST authorities.
It is important to ensure that all the information provided in the GSTR 9C is accurate and complete to avoid penalties and late fees.
GSTR 9 and GSTR 9C are both important GST returns that need to be filed by taxpayers registered under GST. However, they have different purposes and requirements.
GSTR-9 is an annual return that provides a summary of all the outward and inward supplies made during the financial year, as well as details of GST paid and Input Tax Credit (ITC) claimed.
It needs to be filed by all regular taxpayers registered under GST, except for Input Service Distributors (ISDs), Casual Taxable Persons, and Non-Resident Taxable Persons.
While GSTR-9 provides a summary of all the transactions made during the financial year, GSTR 9C is a detailed reconciliation statement that ensures that the GST paid and ITC claimed is in line with the audited financial statements.
As per the 43rd GST council recommendations, taxpayers with a turnover of up to ₹5 Crores may self-certify the GSTR 9C for FY 2020-21 onwards. However, taxpayers with an aggregate turnover of more than ₹5 Crores are compulsorily required to file the GSTR 9C without fail for FY 2020-21.
Taxpayer’s Aggregate Turnover
GSTR 9C Filing Requirement (FY 2020-21 onwards)
Less than ₹2 Crores
Between ₹2 Crores and ₹5 Crores
Optional, with a self-certification benefit if filed
More than ₹5 Crores
Filing GSTR 9C is mandatory for businesses with an annual turnover of more than ₹5 Crores.
Form GSTR-9C must be filed along with the Form GSTR-9 as per Section 44(2) of the GST Act, 2017
No, a CA need not be registered as a GST practitioner for certifying Form GSTR-9C.
No, once filed, GSTR-9C cannot be revised.
To check the status of your GSTR 9C filing, you need to log in to the GST portal and navigate to the Services tab. Then, select the ‘Returns’ option and click on the ‘Track Return Status’ option. Enter the relevant details such as financial year and return filing period to check the status of your GSTR 9C filing.
If you fail to file GSTR 9C on time, you will be liable to pay a late fee of ₹200 per day for each day of delay, subject to a maximum of 0.5% of your turnover.
Yes, a registered taxpayer who has exclusively made exempt supplies of goods or services in excess of ₹2 crores during a financial year is required to file GSTR 9C.
Yes, if a person has obtained multiple registrations in different states, they are required to file Form GSTR 9C for each registration obtained.
The due date for filing GSTR 9C is on or before 31st December of the subsequent financial year. For instance, if you need to file GSTR 9C for FY 2022-23, the due date will be 31st December 2023.