GSTR 9C: Reconciliation Statement & Certification – Due Date, Applicability, Limit, Format

GSTR-9C is a form for annual GST reconciliation statement filed by applicable taxpayers. Every registered person whose aggregate turnover during a financial year exceeds Rs.5 crore must file this form. They shall also furnish a copy of the audited annual accounts.

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What is GSTR-9C?

GSTR-9C is a statement of reconciliation between:

• The annual returns in form GSTR-9 filed for a FY, and
• The figures as per the audited annual financial statements of the taxpayer.

GSTR-9C consists of gross and taxable turnover as per the books reconciled with the respective figures as per the consolidation of all the GST returns for a Financial Year.

Hence, any differences arising from this reconciliation exercise will be reported in this statement, along with the reasons for the same and then certified by the taxpayer themselves. The certified statement shall be issued for every GSTIN. Hence, for a PAN, there can be several GSTR-9C forms to be filed.

GSTR-9C must be prepared and self-certified by the taxpayer. It must be filed on the GST portal or through a facilitation centre by the taxpayer, along with other documents such as a copy of the Audited Accounts and Annual Return in form GSTR-9. This statement is applicable to all those taxpayers who must get their Annual Accounts audited under the GST laws.

GSTR-9C applicability and GSTR-9C turnover limit

As per CBIC notification no. 30/2021 dated 30th July 2021, every registered person under GST whose turnover during a financial year exceeds the prescribed GSTR-9C turnover limit of Rs.5 crore satisfies the GSTR-9C applicability condition to file this statement.

Further, as per CBIC’s CGST notification no. 09/2020 dated 16th March 2020, all foreign companies which are in the airline business and compliant with the relevant provisions and rules of the Companies Act 2013 are exempted from the GSTR-9C requirement.

In addition to the above, persons who are non-residents and are providing OIDAR service in India to unregistered persons have been exempted from submitting GSTR-9 and GSTR-9C as per CBIC notification no. 30/2019 dated 28th June 2019.

^The limit is enhanced to Rs 5 crore for the GSTR-9C of FY 2018-19, FY 2019-20, FY 2020-21, FY 2021-22 and FY 2022-23 as per the CBIC notifications.

What is the due date for GSTR-9C?

The due date to file GSTR-9C is the same as due date for submitting the Annual returns in GSTR-9. Hence, the GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant FY under audit. The due date can be extended by the Government if deemed necessary. For instance, the GSTR-9C due date for FY 2024-25 is 31st December 2025.

What’s the importance of GSTR-9C?

The taxpayer must prepare this GST reconciliation statement. Any differences between sales, taxes, or input tax credit details reported in all the GST returns and the Audited Books of Accounts must be reported therein with the reasons for the differences.

This statement acts as a base for the GST authorities to verify the correctness of the GST returns filed by the taxpayers after a self-certification.

Contents and format of GSTR-9C

The GSTR-9C consists of two main parts:

• Part-A: Reconciliation Statement
• Verification/Self-certification

Part-A: Reconciliation Statement

The figures in the audited financial statements are at PAN level. Hence, the turnover, Tax paid and ITC earned on a particular GSTIN (or State/UT) must be pulled out from the audited accounts of the organisation as a whole.

The Reconciliation Statement is divided into five parts as follows:

Part-I: Basic details:

Consists of Financial Year, GSTIN, Legal Name and Trade Name. The taxpayer must also mention if he is subject to audit under any other law.

Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9):

 This involves reporting of the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that most often, the Audited Financial statements are at a PAN level.

This might require the break up of the audited financial statements at GSTIN level for reporting in GSTR-9C. Details of turnover adjustments to be made in tables 5B to 5N have been made optional, and adjustments, if any, which are required to be reported can be reported in Table 5O by the taxpayer. This update is as per Notification No: 56/2019 issued on 14th November 2019.

Part-III: Reconciliation of tax paid:

 This section requires GST rate-wise reporting of the tax liability that arose as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to not reconciled differences noticed upon reconciliation.

Part-IV: Reconciliation of Input Tax Credit (ITC):

 This part consists of the reconciliation of input tax credit availed and utilised by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement.

Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any.

A Taxpayer has the option to not fill details of ITC reconciliation in tables 12B, 12C and 14. This update is as per Notification No: 56/2019 issued on 14th November 2019.

Verification/Self-certification by taxpayer

For further details about the GSTR-9C format and reporting steps, read our article on Guide to Form GSTR-9C

What has changed in GSTR-9C format & filing?

Following are the changes made to the format and filing procedure-

• Verification by Registered Taxpayers has been added & CA/CMA certification is removed.
• Taxpayers need to file the GST returns for all the months of the financial year in GSTR-1, GSTR-3B and GSTR-9.
• At the end of this return, taxpayers shall be given an option to pay any additional tax liability declared in this form, through FORM DRC-03. Taxpayers shall select ―’Reconciliation Statement’ in the drop-down provided in FORM DRC-03. It may be noted that such liability shall be paid through electronic cash ledger only.

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Frequently Asked Questions

What is the GSTR 9C reconciliation statement?

GSTR-9C is a reconciliation statement filed by certain taxpayers that reconciles values in annual returns of GSTR-9 with the audited financial statements to identify gaps and report the same for authorities to assess.

Is GSTR-9C removed?

No, the department did not removed the GSTR-9C, but revised the filing rules and format in 2021. Earlier, it required auditor’s certification, whereas now it needs self-certification by an authorised person of the taxpayer.

What turnover is considered for GSTR 9C?

All taxpayers with an annual aggregate turnover of more than Rs.5 crore must file GSTR-9C for the financial year.

What is the penalty for GSTR 9C?

If one misses filing GSTR-9C by the due date, i.e., 31st December of the year following the financial year, no specific provision governs this. However, the taxpayer who defaults will be subjected to a general penalty of Rs 25,000.

How do you download the error report in GSTR 9C?

You can download the zipped error report of the GSTR-9C filing can be downloaded by navigating as follows:

1. Go to GSTR-9C tile after logging into GST portal
2. Go to Upload History table
3. Click on ‘Generate error report’ link
4. Click on ‘Download error report’ under ‘Error Report’ column.
5. The JSON format of the error report is downloaded on your system.
6. You can import it into your offline tool to make further corrections.

Which tables are mandatory in GSTR-9C?

Tables 5, 7, 9 & 12 are mandatory for GSTR-9C. Tables 6, 8, 10 & 13 must only be filled if there are any un-reconciled amounts as per mandatory tables mentioned above. Else, the same will be blank