A registered taxpayer under the GST system must file GST returns, an indispensable compliance requirement that records sales, purchases, and taxes paid, along with input tax credit. An important compliance requirement that lends greater transparency and accountability to the taxation framework, it ensures the smooth functioning of indirect taxes. Varying types of returns are available to different types of taxpayers depending on their registration status and turnover levels. In order to stay away from penalties, interest payments, and interference with business activities, it is essential that GST returns like GSTR-1, GSTR-3B, GSTR-9, and GSTR-9C are submitted on time and with accuracy.
What is Form GSTR 9C?
Form GSTR-9C is an annual reconciliation statement to be furnished by registered taxpayers under the Goods and Services Tax (GST) regime if their total turnover is in excess of ₹5 crore during a financial year. It is a linkage between figures returned in the annual GST return (Form GSTR-9) and audited financial records of the taxpayer. The form must be certified by a Chartered Accountant (CA) or a Cost Accountant (CMA).
GSTR-9C has two parts:
1. Part A: Reconciliation Statement – Reconciles the
- turnover declared in GSTR-9 with the audited books of accounts.
- Tax payable vs. tax paid.
- ITC claimed against ITC, which is accounted for in the books
- Any excess liabilities identified as a result of the reconciliation
2. Part B: Certification – The reconciliation is certified by a CA or CMA through their own audit or statutory audit.
GSTR-9C is filed online through the GST portal (www.gst.gov.in) and is required to be filed by December 31st of the next financial year after the period to which such statement relates, unless extended.
Applicability of GSTR 9C
Those who are enrolled under GST with an annual turnover above ₹5 crore are required to submit GSTR-9C yearly. This obligation increases financial reporting transparency by matching the GST information with audited accounts. Companies have to keep correct accounts, perform reconciliations in advance, and seek advice from professionals in order to help comply with this requirement in a prompt and accurate manner.
Statutory Provision
As per Section 35(5) of the CGST Act, 2017, and Rule 80(3) of the CGST Rules, filing of GSTR-9C is compulsory for:
If the annual turnover of a registered person exceeds ₹5 crore, they are liable to get their accounts audited and certified by a Chartered Accountant or a Cost Accountant.
Further, they are required to file a reconciliation statement along with a copy of the audited annual accounts in FORM GSTR-9C.
Who Needs to File GSTR-9C?
Mandatory filing is required for:
- Registered GST taxpayers and those not opting for the composition scheme.
- Those who have an annual turnover of more than ₹5 crore, whether they supply goods or services or both.
- Aggregate turnover includes taxable and exempt supplies, zero-rated supplies (exports), non-GST goods, and reverse charge supplies.
Important: Turnover is calculated on PAN, not GSTIN. For taxpayers with more than one GSTIN under a common PAN, turnover in all states combined is taken to determine the ₹5 crore threshold.
Who is EXEMPT from filing GSTR-9C?
GSTR-9C is not applicable to the following types of registered persons, irrespective of their turnover:
1. Taxpayers having an aggregate turnover of ₹5 crore or less
If your PAN-based total turnover during the financial year is ₹5 crore or less, you do not need to file GSTR-9C.
2. Taxpayers under the Composition Scheme
Registered businesses under the composition scheme (filing GSTR-4 or CMP-08) are exempted from filing GSTR-9C, even if their turnover is more than ₹5 crore.
3. Input Service Distributors (ISD)
ISDs only pass on input tax credit to other units of the same organisation and do not make outward taxable supplies; hence, GSTR-9C does not apply.
4. Non-Resident Taxable Persons (NRTP)
NRTPs temporarily registered to make taxable supplies in India are exempted from GST audit and filing of GSTR-9C.
5. Casual Taxable Persons
Businesses or individuals registering for temporary events, exhibitions, or seasonal sales are exempted from filing GSTR-9C.
6. Section 51 TDS Deductors under CGST Act
Registered persons for deduction of tax at source (TDS) under GST law do not have to submit GSTR-9C.
7. Section 52 TCS Collectors under the CGST Act
E-commerce operators or other persons collecting tax at source (TCS) are not required to submit GSTR-9C, as they don’t make ordinary outward supplies.
Who is Eligible to File and Certify GSTR-9C?
- The reconciliation statement must be prepared by the taxpayer.
- A practising CMA or CA should certify it upon performing an audit.
- The auditor should ensure verification and comment on any variations and attest that the books of accounts are in conformity with the GST returns.
Process of Filing GSTR-9C Online
GSTR-9C is electronically filed through the GST portal (www.gst.gov.in) and needs to be certified and signed digitally by a Chartered Accountant (CA) or Cost Accountant (CMA). It needs to be filed together with or after the GSTR-9 (Annual Return).
What are the contents of GSTR-9C?
GSTR-9C includes:
- critical information regarding the taxpayer.
- Reconciles GSTR-9 turnover with audited accounts.
- Reconciles tax paid with GSTR-9 and audited accounts.
- Inclusion of certification by CA/CMA, and any observations.
Filing Process
1. Check Eligibility
Check if your total turnover during the financial year exceeds 5 crore (on PAN and all GSTINs). If so, filling up GSTR-9C is mandatory.
2. Gather the Necessary Documents
Make sure you have the following:
- Filed GSTR-9 (Annual Return)
- Audited accounts (Balance Sheet, Profit & Loss Account, Cash Flow Statement, etc.)
- Reconcile payment, tax dues, ITC, and settlements.
- Determine any difference or deviation.
- Obtain a digital signature (DSC) for companies or an EVC for individuals.
- Appoint a practising CA or CMA to audit and certify.
3. Access the GST Portal
Visit www.gst.gov.in. Fill in your username and password to log in. Move to Services > Returns > Annual Return.
4. Select GSTR-9C
Select the financial year. Click on “Initiate Filing of GSTR-9C” (after filing GSTR-9). You will be taken to a dashboard split into two parts:
- Part A: Reconciliation Statement
- Part B: Auditor Certification
5. Complete Part A – Reconciliation Statement
Among components are:
- Agreement of gross turnover declared in GSTR9 with verified records
- Reconciliations of tax paid
- Reconciliation of Input Tax Credit (ITC)
- Other obligations
Using offline tools or filling it in by hand, you can import JSON files ready by the auditor.
6. Part B – CA/CMA Certification
The authorised CA or CMA shall:
- Go through Part A
- Conduct audit procedures
- Certification upon completion of the audit by the CA
- Certification upon use of another person’s audit by the CA
7. Preview and Submit
Click “Preview Draft GSTR-9C” in order to verify for errors or missing information. After verification, submit the form. File using DSC (compulsory for companies) or EVC (for others, such as proprietorships or partnerships).
8. Acknowledgement
Upon successful submission, an ARN (Acknowledgement Reference Number) is produced. Fetch the filed GSTR-9C and the receipt of acknowledgement for records.
Due Date of GSTR 9C
Unless the government gives an extension by notification, GSTR 9C should be filed on December 31st of the following fiscal year.
To maintain compliance and avoid fines or investigations, on-time filing is absolutely vital. To prevent any mistakes or delays while adhering to the deadline, businesses should prepare their account books ahead of time and work closely with their auditors. The GST site will alert to any extensions.
Consequences of Non-Compliance
Non-filing of GSTR-9C, the reconciliation statement required under GST law, can attract both legal and financial penalties to taxpayers having an aggregate turnover of more than ₹5 crore during a financial year.
Even though the GST Act doesn’t specify a particular penalty for failing to file GSTR-9C, the general provisions and restrictions mentioned under Section 125 of the CGST Act are to be brought into force. Therefore, it is mentioned that failure to comply with the laid-down regulations of the Act may attract a penalty of ₹25,000 under CGST and an equivalent amount under SGST, which sums up to a total of ₹50,000. No specific penalty is found as laid against this offence.
Non-compliance can lead to
- Scrutiny notices or audits by the GST authorities.
- Late claims of refunds (if any).
- Negative impact on the compliance rating of the taxpayer, which could have implications for future business transactions, tenders, or the approval of loans.
- Discrepancies detected during departmental audits could lead to interest charges and demand notices.
In addition, organisations that continuously fail to meet compliance criteria have the potential to be labeled as non-compliant, something that can harm their brand image and credibility. To avoid penalties and legal issues, it is recommended that GSTR-9C be filed correctly and on time by a Chartered Accountant or a Cost Accountant.
Conclusion
Every year, taxpayers registered under GST with a total turnover of more than ₹5 crore must submit GSTR 9C. The return helps to reconcile the data submitted in GSTR9 with audited financial statements, therefore ensuring accuracy, openness, and tax law compliance. Certification by a Chartered Accountant (CA) or Cost and Management Accountant (CMA) enhances credibility as well as allows for early detection of discrepancies. The timely and accurate filing of GSTR-9C not only reduces legal threats but also improves the compliance record of the taxpayer. To complete their GSTR-9C requirements successfully and promptly, firms should avail themselves of professionals in advance, keep the necessary documentation ready, and follow deadlines.
Related Services
