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, and shall furnish a copy of the audited annual accounts and a reconciliation statement, duly certified, in FORM 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:
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.
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.
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.
For example, for the FY 2017-18, the due date for filing GSTR-9C is 30th June 2019*.
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.
The GSTR-9C consists of two main parts:
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 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 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 :
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.
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 report will vary depending on who the certifier is.
Part-A: Reconciliation Statement
Following are the changes made to the format and filing procedure as on 31st Dec 2018: