GSTR-9C is an audit form that serves as a statement of reconciliation submitted by a registered GST taxpayer whose aggregate turnover in a given financial year does not exceed ₹2 Crores (w.e.f. FY 2020-21, filing GSTR 9C is optional for businesses with turnover less than ₹5 Crores). This statement of reconciliation is submitted by the registered taxpayer after a GST audit has been conducted by a Chartered Accountant (CA). Post thorough verification of the annual GST returns in GSTR-9, this reconciliation statement is subsequently certified by either a GST Auditor or a Chartered Accountant.
The GSTR 9C 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.
As per the regulations listed by the GST authorities, GSTR 9C must be filed on or before the 31st of December of the following year. For example, the GSTR 9C for financial year 2020-21 must be filed by December 31, 2022.
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 deadline for GSTR 9C filing is usually December 31 of every year succeeding the fiscal year under audit and may be extended by the government based on the necessity.
However, any delay in filing the GSTR 9C within the prescribed deadline attracts the penalty clause of the GSTR 9C audit return form, and the taxpayer is liable to pay a late fee of ₹200 per day (₹100 each under CGST and SGST) as penalty.
The maximum penalty cannot exceed 0.5% of the entire turnover on which it is being imposed.
In certain cases, the Government reserves the right to waive off a part of the penalty amount for a section of taxpayers on special grounds through a notification issued on the recommendation of the GST council.
No such waiver notification has been issued by any state/central Government to date.
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 can not be revised.
The following fields as auto-populated in Form GSTR-9C from Form GSTR-9:
Liability as per GSTR-9
Turnover details as per GSTR-9
Total tax paid as mentioned GSTR-9
Input Tax Credit availed in GSTR-9