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

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 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 March 2023
CGST Notification 07/2023 has notified the GST Council recommendation.
Any delay in the filing of annual returns in form GSTR-9 FY 2022-23 onwards attracts concessional late fee for the following categories of registered taxpayers-
- Turnover up to Rs.5 crore filing GSTR-9 after due date attracts a late fee of Rs. 25 per day subject to max cap 0.02% of turnover.
- Turnover over Rs.5 crore to 20 crore filing GSTR-9 after due date attracts late fee of Rs 50 per day subject to max cap 0.02% of turnover.

18th February 2023
49th GST Council meeting updates-
1. Council recommended the late fee rationalisation for delayed GSTR-9 filing from FY 2022-23 onwards as follows: 
   (a) Registered persons with Annual Aggregate Turnover (AATO) up to Rs.5 cr is reduced to Rs. 25 per day subject to a maximum of 0.02% of turnover.
   (b) Registered persons with AATO of more than Rs.5 cr to 20 cr is reduced to Rs 50 per day subject to a maximum of 0.02% of turnover.
2. The Council recommended an amnesty scheme for pending GSTR-9 returns. This scheme comes with a conditional waiver/ reduction of late fees.

5th July 2022 

The CBIC has exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 21-22 from filing Form GSTR-9. 
 

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

 

What is GSTR-9C?

Every registered person under GST whose turnover during a financial year exceeds the prescribed limit of Rs.5 crore^ must prepare the reconciliation statement in Form GSTR-9C and self-certify it before filing it on the GST portal. 

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 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 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.

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

Who must prepare & submit GSTR-9C?

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. 

As per CBIC’s CGST notification number 30/2021 dated 30th July 2021, 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.

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, FY 2019-20 and FY 2020-21 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?

The taxpayer must prepare this GST Reconciliation statement. Any differences between the details reported in all the GST returns and the Audited 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. The GSTR-9C needs to be self-certified by the taxpayer.

What are the contents of form GSTR-9C?

The GSTR-9C consists of two main parts: 

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

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. 

Self-certification by taxpayer

Detailed Format of GSTR-9C

Part-A: Reconciliation Statement
 

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 & removal of CA/CMA certification:

• 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.

The older format of Part-B: Certification (No longer applicable)

Earlier, the GSTR-9C had to 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. This has been done away with from FY 2020-21 onwards.
 

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