GSTR 9C : Reconciliation Statement & Certification- Filing, Format & Rules

Every registered person whose aggregate turnover during a financial year exceeds two crore rupees shall get his accounts audited as specified under sub-section (5) of section 35 of the CGST Act.

They shall furnish a copy of the audited annual accounts and a reconciliation statement, duly certified, in form GSTR-9C.

Latest updates to GSTR-9C

31st July 2021
The CBIC has exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 20-21 from filing Form GSTR-9.

30th July 2021
The CBIC has notified changes to Sections 35(5) and 44 of the CGST Act. The requirement to get a GST audit and certification done by a CA/CMA now stands removed. Taxpayers with a turnover exceeding Rs.5 crore in the previous financial year are required to file Form GSTR-9C on a self-certification basis. This change is applicable from FY 20-21 onwards. Further, Form GSTR-9C will be modified to support self-certification by the taxpayer.

28th May 2021
As per 43rd GST Council meeting outcome, GSTR-9 shall continue to be optional for taxpayers with turnover up to Rs.2 crore, whereas GSTR-9C can be self-certified by taxpayers with turnover less than or equal to Rs.5 crore from FY 2020-21 onwards.

9th March 2021
The Form GSTR-9A has been disabled from FY 2019-20 onwards for composition taxpayers due to the introduction of GSTR-4 (Annual return). However, the GSTR-9A is optional and can be filed for FY 2017-18 and FY 2018-19.

28th February 2021
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been further extended up to 31st March 2021.

30th December 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been extended up to 28th February 2021.

28th October 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2018-19 has been extended up to 31st December 2020.

Watch the video to get a complete overview of GSTR-9C

What is GSTR-9C?

Every registered person whose turnover during a financial year exceeds the prescribed limit of rupees two crores shall get his accounts audited by a chartered accountant or a cost accountant.

GSTR-9C is a statement of reconciliation between:

• the Annual Returns in GSTR-9 filed for a FY,  and
• the figures as per the audited annual Financial Statements of the taxpayer.

It can be considered to be similar to that of a tax audit report furnished under the Income-tax act. It will consist of gross and taxable turnover as per the Books reconciled with the respective figures as per the consolidation of all the GST returns for an FY. 

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

^The limit is enhanced to Rs 5 crore for the GSTR-9C of FY 2018-19 and FY 2019-20 as per the CBIC notifications.

Who must prepare & submit GSTR-9C?

GSTR-9C must be prepared and certified by a Chartered Accountant or Cost Accountant. It must be filed on the GST portal or through a facilitation centre by the taxpayer, along with other documents such as the 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. 

Audit under GST applies to those registered persons whose Annual aggregate turnover exceeds rupees two crores^ in that FY. Further, as per CBIC’s CGST notification number 09/2020 dated 16th March 2020, all the foreign companies which are into airlines business and compliant with the relevant provisions and rules of the Companies Act, 2013 are exempted from the GSTR-9C requirement. 

Moreover, 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.

^The limit is enhanced to Rs 5 crore for the GSTR-9C of FY 2018-19 and FY 2019-20 as per the CBIC notifications.

What is the due date for GSTR-9C?

The due date for submitting the Annual returns in GSTR-9 is the same deadline for submission of GSTR-9C. 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.

What’s the importance of GSTR-9C?

A Chartered Accountant or Cost Accountant must prepare this GST Reconciliation statement. Any differences between the details reported in all the GST returns and the Audited Accounts must be reported by the CA 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. This is because the CA has to certify any additional liability arising out of the reconciliation exercise and GST audit in GSTR-9C.

What are the contents of form GSTR-9C?

The GSTR-9C consists of two main parts: 

• Part-A: Reconciliation Statement 
• Part-B: 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.

As per Notification No: 56/2019 issued on 14th November 2019 For FY 2017-18 & 2018-19, following changes were made:

• 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. 
• A Taxpayer has the option to not fill details of ITC reconciliation in tables 12B, 12C and 14.

The Reconciliation Statement is divided into five parts as follows: 

Part-I: Basic details: Consists of FY, 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 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. 

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 unreconciled 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. 

Part-V: Auditor’s recommendation on additional Liability due to non-reconciliation: Here, the Auditor must report any tax liability identified through the reconciliation exercise and GST audit, pending for payment by the taxpayer. This can be non-reconciliation of turnover or ITC on account of :

• Amount paid for supplies not included in the Annual Returns(GSTR-9)
• Erroneous Refund to be paid back
• Other Outstanding demands to be settled

Lastly, the instructions to the format of GSTR-9C specifies that an option will be given to taxpayers to settle taxes as recommended by the auditor at the end of the reconciliation statement.

Part-B: Certification

As per Notification No: 56/2019 issued on 14th November 2019 For FY 2017-18 & 2018-19, following changes were made:

• The declaration part includes minor changes, including the declaration by the auditor, which now reads “true and fair” instead of “true and correct”, before his/her signature and stamp/seal.

The GSTR-9C can be certified by the same CA who conducted the GST audit or it can be also certified by any other CA who did not conduct the GST Audit for that particular GSTIN. 

The difference between the both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format of Part-B for certification reports will vary depending on who the certifier is.  

Detailed Format of GSTR-9C

Part-A: Reconciliation Statement

Part-B: Certification

What has changed in GSTR-9C format & filing

Following are the changes made to the format and filing procedure as on 31st Dec 2018:

• Verification by Registered Taxpayers:

• Taxpayers need to file the GST returns for all the months of FY 2017-18 in GSTR-1, GSTR-3B and GSTR – 9.
• At the end of this return, taxpayers shall be given an option to pay any additional 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.