Not any more…
Here is a quick comparison of GSTR-9 & GSTR-9C :
|Points of comparison||GSTR-9
|Nature||Informational/ a consolidation of all GST returns||Analytical statement on GST returns certified by GST Auditor/ CA/CMA for GST authorities to take necessary action|
|Who must file||GST Registered taxpayer||GST registered taxpayer to whom GST audit is applicable|
|Not applicable to||Casual Taxable Person
Non-Resident Taxable Person
Input Service Distributor
Unique Identification Number Holders
Online Information and Database Access Retrieval Service providers
Persons subject to TCS or TDS provisions
|Those mentioned under GSTR-9 but also a registered person whose aggregate turnover in an FY is less than Rs. 2 Crores|
|Due date for filing||31 December of next FY*||31 December of next FY*, either with or after filing GSTR-9|
|Late fees & penalty||Late fees of Rs 200 per day of delay subject to a maximum cap of an amount at 0.25% of total turnover in respective State/UT||No specific provision, Hence, subject to a general penalty of Rs 25,000|
|Filing of the return||On GST portal or through facilitation centre||On GST portal or through facilitation centre at the time of or after filing GSTR-9|
|Format of the return||Consolidated summary details of the turnover, ITC and tax paid, late fees as per the GST returns filed between July 2017 and March 2018 along with its amendments made between April 2018 and September 2018.
Further, declaration of demands/ refunds, supplies from composition dealers, Job works, goods sent on an approval basis, HSN wise summary of outward and inward supplies, late fees payable is required.
|Part-A -Reporting of reconciliation needed between turnover, tax paid and ITC. Report on Auditor’s recommendation of any additional tax liability.
Part -B -Certificate by GST Auditor/ CA/ CMA
|Who must certify/ attest||No certification required by CA/CMA but must be attested by the taxpayer using a digital signature||Certification of GST Auditor is required who is either a CA/CMA through digital signature and must be attested by the taxpayer using a digital signature|
|Annexures||No annexures to be attached||Annexure of Audited financial statement is required|
*The due date for filing GSTR-9, GSTR-9A and GSTR-9C was thrice extended from 31 December 2018 to 30 November 2019 by CBIC for FY 2017-18.
Hence, GSTR-9 is the annual return to be filed by every GST registered taxpayer irrespective of their turnover.
Whereas GSTR-9C is the reconciliation statement to be submitted by those GST registered taxpayers to whom GST audit applies. GST Audit applies to those taxpayers whose turnover exceeds Rs. 2 crores. Audited financial statements must be filed by the taxpayers along with this after obtaining certification from the auditor or a Chartered Accountant or a CMA.