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

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

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.

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 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. 

GSTR-9C applicability & GSTR-9C turnover limit

Every registered person under GST whose turnover during a financial year exceeds the prescribed GSTR-9C turnover limit of Rs.5 crore^ satisfies GSTR-9C applicability condition to file this statement. 

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, FY 2020-21, FY 2021-22 and FY 2022-23 as per the CBIC notifications.

What is the due date for GSTR-9C?

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 2023-24 is 31st December 2024.

What’s the importance of GSTR-9C?

The taxpayer must prepare this GST Reconciliation statement. Any differences between the sales, tax, or input tax credit 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 after a self-certification.

Contents and format of GSTR-9C

The GSTR-9C consists of two main parts: 

• Part-A: Reconciliation Statement 
• Verification/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.

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. 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. This update is as per Notification No: 56/2019 issued on 14th November 2019.

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. 

A Taxpayer has the option to not fill details of ITC reconciliation in tables 12B, 12C and 14. This update is as per Notification No: 56/2019 issued on 14th November 2019.

Verification/Self-certification by taxpayer

For further details about the GSTR-9C format and reporting steps, read our article on Guide to Form GSTR-9C

What has changed in GSTR-9C format & filing?

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

• Verification by Registered Taxpayers has been added & CA/CMA certification is removed.
• Taxpayers need to file the GST returns for all the months of the financial year 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.

For detailed analysis of tables that were revised in the GSTR-9C format, visit our page “Revised GSTR-9C from FY 20-21 onwards”.

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.