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 (FY) exceeds Rs.5 crore rupees must file this form. They shall also furnish a copy of the audited annual accounts.

Key Takeaways

• GSTR-9C reconciles audited financials with GSTR-9 for turnover >₹5 crore taxpayers, filed per GSTIN by 31 Dec post-FY
• GSTR-9C reconciles audited financials (PAN-level) with GSTR-9 turnover, tax, and ITC per GSTIN for taxpayers >₹5 crore.​
• Self-certify discrepancies in Parts II-IV with reasons; pay additional liability via DRC-03.​
• Part V captures unreconciled tax/ITC shortfalls; due 31 Dec post-FY with audited accounts.​
• Exemptions apply to foreign airlines and OIDAR providers to unregistered persons.

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 FY. 

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. 

What's the Importance of GSTR-9C?

This statement verifies GST return accuracy against books, flagging discrepancies for authorities. It supports audit trails, reduces notices through proactive disclosures, and enables ITC/tax payments via DRC-03 for unreconciled differences. Proper filing minimizes scrutiny and improves liquidity management.​

GSTR-9C Applicability and 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.

GSTR 9C Due Date

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.

GSTR-9C Format and Contents  

The GSTR-9C consists of two main parts: 

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

Part-A: Reconciliation Statement

The Reconciliation Statement is divided into five parts as follows: 

Part-I: Basic details

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

Part-III: Reconciliation of tax paid

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

Part-V: Additional Liability due to non-reconciliation

Verification/Self-certification by taxpayer

For a more detailed GSTR-9C format, read our article on GSTR Annual Return Formats

What has Changed in GSTR-9C Format & Filing?

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

1. Table 7D1 (New) for E-Commerce Operator Supplies
   This new table mandates reporting of supplies where tax is paid by the e-commerce operator (ECO) as per Section 9(5) of the CGST Act. It ensures clear segregation and accurate disclosure of ECO-supplied transactions, facilitating better alignment between supplier and ECO’s tax payments.
2. Late Fee Table 17 (New)
   GSTR-9C now includes an auto-calculated Table 17 that records the daily late fee amount applicable on delayed filings at ₹100 per day for each return (GSTR-9 and GSTR-9C). Taxpayers must remit this fee via Form DRC-03. Automation eliminates manual errors and emphasizes the financial consequences of late compliance.

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