GSTR-9C is an annual GST reconciliation statement that must be filed by eligible taxpayers. Every registered person whose aggregate turnover in a financial year exceeds ₹5 crore is required to submit this form. Along with the form, taxpayers must also provide a copy of their audited annual financial statements.
Latest Updates
55th GST Council Meeting
As of 21st December 2024, the Council announced that a circular will be issued to clarify the late fee applicable under Section 47(2) of the CGST Act, 2017, for delays in filing the annual return (Form GSTR-9) and reconciliation statement (Form GSTR-9C).
The Council also recommended issuing a notification under Section 128 of the CGST Act, 2017, granting a waiver for late fees on delayed filing of Form GSTR-9C. This waiver applies to reconciliation statements for the financial years 2017-18 to 2022-23. The excess late fee will be waived if Form GSTR-9C is submitted on or before 31st March 2025.
53rd GST Council Meeting
As of 22nd June 2024, the Council recommended relaxation from filing GSTR-9/9A for FY 2023-24 for taxpayers with an annual turnover below ₹2 crore. This was officially notified through CGST Notification No. 14/2024 dated 10th July 2024.
These recommendations will take effect through the respective circulars and notifications.
What is GSTR-9C?
GSTR-9C is a reconciliation statement that compares:
- The annual returns filed in Form GSTR-9 for a financial year, and
- The figures reported in the taxpayer’s audited annual financial statements.
It contains details of the gross and taxable turnover as per the books of accounts, reconciled with the corresponding figures derived from all GST returns filed during the same financial year.
Any discrepancies identified during this reconciliation process are to be mentioned in the statement, along with the reasons for such differences. The statement is then certified by the taxpayer. A separate certified GSTR-9C statement must be prepared for each GSTIN. Therefore, a taxpayer with multiple GST registrations under the same PAN will need to file multiple GSTR-9C forms.
GSTR-9C must be prepared and self-certified by the taxpayer. It is required to be filed on the GST portal or through a facilitation centre, along with the audited financial statements and the annual return in Form GSTR-9. This requirement applies to taxpayers whose annual accounts are subject to audit under GST law.
GSTR-9C Applicability and Turnover Limit
As per CBIC Notification No. 30/2021 dated 30th July 2021, every registered person under GST whose aggregate turnover during a financial year exceeds ₹5 crore is required to file GSTR-9C. This threshold determines the applicability of the GSTR-9C reconciliation statement.
Additionally, CBIC Notification No. 09/2020 dated 16th March 2020 provides an exemption to foreign companies engaged in the airline business, provided they comply with the relevant provisions and rules under the Companies Act, 2013.
Further, CBIC Notification No. 30/2019 dated 28th June 2019 exempts non-resident taxpayers providing Online Information Database Access and Retrieval (OIDAR) services in India to unregistered persons from filing both GSTR-9 and GSTR-9C.
The turnover limit for GSTR-9C has been revised to ₹5 crore for the financial years 2018-19, 2019-20, 2020-21, 2021-22, and 2022-23 as per CBIC notifications.
What is the Due Date for GSTR-9C?
The due date for filing GSTR-9C is the same as the due date for filing the annual return in Form GSTR-9. Therefore, GSTR-9C must be submitted on or before 31st December of the year following the relevant financial year under audit.
The government may extend this deadline if necessary. For example, the due date for filing GSTR-9C for FY 2024-25 is 31st December 2025.
Importance of GSTR-9C
GSTR-9C is an essential GST reconciliation statement that taxpayers must prepare to report any discrepancies between the details of sales, taxes, or input tax credits mentioned in their GST returns and those reflected in their audited financial accounts. Any such differences must be clearly explained with valid reasons.
This statement serves as a key document for GST authorities to verify the accuracy of the returns filed by taxpayers, ensuring transparency and compliance after the taxpayer’s self-certification.
Contents and Format of GSTR-9C
GSTR-9C is divided into two main sections:
- Part-A: Reconciliation Statement
- Verification / Self-Certification
Part-A: Reconciliation Statement
Since the audited financial statements are prepared at the PAN level, the taxpayer must extract turnover, tax paid, and input tax credit (ITC) details corresponding to each GSTIN or State/UT from the consolidated accounts.
The Reconciliation Statement is structured into five parts:
Part-I: Basic Details
Includes the financial year, GSTIN, legal name, and trade name. The taxpayer must also specify whether they are subject to an audit under any other law.
Part-II: Reconciliation of Turnover
This section compares the gross and taxable turnover reported in the audited financial statements with the figures declared in the annual return (GSTR-9). Since audited accounts are generally at the PAN level, the taxpayer may need to provide a GSTIN-wise breakup. As per Notification No. 56/2019 dated 14th November 2019, the details in Tables 5B to 5N are optional, and any required adjustments can be entered in Table 5O.
Part-III: Reconciliation of Tax Paid
This part requires a GST rate-wise comparison of tax liabilities as per audited accounts and as reported in GSTR-9. It also calls for disclosure of any additional liability arising due to unreconciled differences identified during reconciliation.
Part-IV: Reconciliation of Input Tax Credit (ITC)
This section involves reconciling the ITC availed and utilized as per the audited financial statements with the figures declared in GSTR-9. It also includes reporting expenses from the audited accounts, categorizing them into eligible and ineligible ITC, and reconciling eligible credits with those claimed in GSTR-9 after accounting for any reversals.
As per Notification No. 56/2019 dated 14th November 2019, taxpayers have the option to skip filling ITC details in Tables 12B, 12C, and 14.
Verification / Self-Certification by Taxpayer
For more information on the GSTR-9C format and detailed reporting process, refer to our comprehensive article on the Guide to Form GSTR-9C.
What Has Changed in the GSTR-9C Format and Filing Process?
The following updates have been made to the GSTR-9C format and filing procedure:
- Verification by registered taxpayers has been introduced, and CA/CMA certification has been removed.
- Taxpayers are now required to file all monthly and annual GST returns — GSTR-1, GSTR-3B, and GSTR-9 — for the relevant financial year before filing GSTR-9C.
- At the end of the return, taxpayers are provided with an option to pay any additional liability declared in the form using FORM DRC-03. While doing so, they must select ‘Reconciliation Statement’ from the drop-down menu in FORM DRC-03.
- It is important to note that any such liability can only be paid through the electronic cash ledger.
For a detailed breakdown of the revised tables and structural updates in the GSTR-9C format, refer to our page “Revised GSTR-9C from FY 2020-21 onwards.”
Older Format – Part-B: Certification (No Longer Applicable)
Previously, Part-B of GSTR-9C required certification by a Chartered Accountant (CA) who conducted the GST audit or by another CA not associated with that specific GSTIN’s audit. This requirement has been discontinued from FY 2020-21 onwards, and taxpayers must now self-certify the form instead.
FAQs on GSTR-9C
1. Is GSTR-9C discontinued?
No, GSTR-9C has not been discontinued. However, the filing rules and format were revised in 2021. Earlier, the form required certification by a Chartered Accountant or Cost Accountant. Under the revised process, it now requires self-certification by the authorized person of the taxpayer.
2. What is the penalty for not filing GSTR-9C?
There is no specific penalty prescribed under GST law for failure to file GSTR-9C by the due date (31st December following the relevant financial year). However, such taxpayers are liable to pay a general penalty of ₹25,000 under the CGST Act for non-compliance.
3. What is the GSTR-9C reconciliation statement?
GSTR-9C is a reconciliation statement filed by certain registered taxpayers. It reconciles the figures reported in the annual return (Form GSTR-9) with those in the audited financial statements. The purpose is to identify and report any differences for review by GST authorities.
4. Which tables are mandatory in GSTR-9C?
Tables 5, 7, 9, and 12 are mandatory in Form GSTR-9C.
Tables 6, 8, 10, and 13 should be filled only if there are any unreconciled amounts or variances identified in the mandatory tables. If there are no such differences, these tables may remain blank.
5. How can I download the GSTR-9C error report?
To download the zipped error report for GSTR-9C from the GST portal:
- Log in to the GST portal and go to the GSTR-9C tile.
- Navigate to the Upload History table.
- Click on ‘Generate Error Report’.
- Under the Error Report column, click on ‘Download Error Report’.
- A JSON file containing the error details will be downloaded.
- You can import this file into the offline utility tool to identify and correct the issues.
6. What turnover is considered for GSTR-9C applicability?
Every registered taxpayer with an annual aggregate turnover exceeding ₹5 crore during a financial year is required to file GSTR-9C, as per CBIC Notification No. 30/2021 dated 30th July 2021.
7. Who is exempt from filing GSTR-9C?
The following are exempt from filing GSTR-9C:
- Foreign airline companies compliant with the Companies Act, 2013 (as per Notification No. 09/2020).
- Non-resident taxpayers providing OIDAR (Online Information Database Access and Retrieval) services to unregistered persons in India (as per Notification No. 30/2019).
8. What is the due date for filing GSTR-9C?
The due date for filing GSTR-9C is the same as the due date for GSTR-9, i.e., 31st December of the year following the relevant financial year. The government may extend this due date through official notifications if required.
9. Can GSTR-9C be revised after submission?
Once GSTR-9C is submitted, it cannot be revised or edited on the GST portal. Therefore, taxpayers must thoroughly review all details and reconciliations before filing the statement.
10. How is GSTR-9C filed?
GSTR-9C must be prepared and self-certified by the taxpayer. It can be filed online on the GST portal or through a facilitation centre, along with supporting documents such as:
- Audited annual financial statements
- Annual return (Form GSTR-9)
11. Is digital signature required for GSTR-9C filing?
Yes, GSTR-9C must be filed using a Digital Signature Certificate (DSC) by companies and LLPs. Other taxpayers can authenticate it using an Electronic Verification Code (EVC).
