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Ever since GSTR-9 & GSTR-9C forms have been released by CBIC, there has been persistent confusion surrounding who must file these forms and whether the details required for both are the same or not. But not any more!
31st July 2021
The CBIC has exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 20-21 from filing Form GSTR-9.
30th July 2021
The CBIC has notified changes to Sections 35(5) and 44 of the CGST Act. The requirement to get a GST audit and certification done by a CA/CMA now stands removed. Taxpayers with a turnover exceeding Rs.5 crore in the previous financial year are required to file Form GSTR-9C on a self-certification basis. This change is applicable from FY 20-21 onwards. Further, Form GSTR-9C will be modified to support self-certification by the taxpayer.
28th May 2021
As per the 43rd GST Council meeting outcome, GSTR-9 shall continue to be optional for taxpayers with turnover up to Rs.2 crore, whereas GSTR-9C can be self-certified by taxpayers with turnover less than or equal to Rs.5 crore from FY 2020-21 onwards.
9th March 2021
The Form GSTR-9A has been disabled from FY 2019-20 onwards for composition taxpayers due to the introduction of GSTR-4 (Annual return). However, the GSTR-9A is optional and can be filed for FY 2017-18 and FY 2018-19.
28th February 2021
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been further extended up to 31st March 2021.
30th December 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been extended up to 28th February 2021.
28th October 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2018-19 has been extended up to 31st December 2020.
31st July 2021
The CBIC has exempted GST-registered taxpayers with annual aggregate turnover up to Rs.2 crore in FY 20-21 from filing Form GSTR-9.
30th July 2021
The CBIC has notified changes to Sections 35(5) and 44 of the CGST Act. The requirement to get a GST audit and certification done by a CA/CMA now stands removed. Taxpayers with a turnover exceeding Rs.5 crore in the previous financial year are required to file Form GSTR-9C on a self-certification basis. This change is applicable from FY 20-21 onwards. Further, Form GSTR-9C will be modified to support self-certification by the taxpayer.
28th May 2021
As per 43rd GST Council meeting outcome, GSTR-9 shall continue to be optional for taxpayers with turnover up to Rs.2 crore, whereas GSTR-9C can be self-certified by taxpayers with turnover less than or equal to Rs.5 crore from FY 2020-21 onwards.
9th March 2021
The Form GSTR-9A has been disabled from FY 2019-20 onwards for composition taxpayers due to the introduction of GSTR-4 (Annual return). However, the GSTR-9A is optional and can be filed for FY 2017-18 and FY 2018-19.
28th February 2021
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been further extended up to 31st March 2021.
30th December 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2019-20 has been extended up to 28th February 2021.
28th October 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2018-19 has been extended up to 31st December 2020.
| 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 DistributorUnique Identification Number Holders Online Information and Database Access Retrieval (OIDAR) Service providers Composition Dealers Persons subject to TCS or TDS provisions | Those persons mentioned under the column for GSTR-9 including a registered person whose aggregate turnover in an FY is less than Rs.2 crore upto 2017-18 and Rs.5 crore for FY 2018-19 and 2019-20 |
| Due date for filing | 31st December of next FY* | 31st 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 April of FY beginning and March of FY end along with its amendments made between April of next FY beginning and September of next FY. 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 to be reported wherever applicable. | 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 |
* Subject to CBIC notifications for any due date extension.
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 crore.
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.
ClearTax GST helps you with the end-to-end compliance for GST ranging from invoicing solutions to filing of GSTR -9 and GSTR-9C.
