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Ever since GSTR-9 & GSTR-9C forms have been released by CBIC, there has been persistent confusions surrounding who must file these forms and whether the details required for both are the same or not.
Latest Update as on 14th November 2019
1. The due date for GSTR-9 and GSTR-9C has been extended to 31st December 2019 and 31st March 2020 for FY 2017-18 and FY 2018-19 respectively.
2. Further CBIC issued Notification No. 56/ 2019 for simplification of GSTR-9/ 9C for FY 2017-18 and FY 2018-19 by making various fields optional.
Latest Update as on 20th September 2019
As per the decision taken at the 37th GST Council Meeting-
1. GSTR-9A filing for composition taxpayers waived off for FY 2017-18 and FY 2018-19.
2. GSTR-9 filing for businesses with turnover up to Rs 2 crore made optional for FY 2017-18 and FY 2018-19.
3. A committee is going to be constituted to examine the simplification of the Annual Return forms and reconciliation statement.
Check all News & Updates from the 37th GST Council meeting –Click Here
Important Announcement
On 26th August 2019
The due date for GSTR-9, GSTR-9A & GSTR-9C Annual Returns further extended from 31 August to 30 November 2019 for FY 2017-18.
Not any more…
Here is a quick comparison of GSTR-9 & GSTR-9C:
| Points of comparison | GSTR-9 Annual Return |
GSTR-9C Reconciliation Statement |
| 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 Composition Dealers 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-9C has been extended to 31st December and 31st March 2020 for FY 2017-18 and FY 2018-19 respectively.
**GSTR-9A filing for composition taxpayers waived off for FY 2017-18 and FY 2018-19.
Hence, GSTR-9 is the annual return to be filed by every GST registered taxpayer irrespective of their turnover^.
^GSTR-9 filing for businesses with turnover up to Rs 2 crore made optional for FY 2017-18 and FY 2018-19.
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.
FY 2017-18 is the first financial year for filing annual returns and GST audit, ClearTax GST helps you with the end-to-end compliance for GST ranging from invoicing solutions to filing of GSTR -9.