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.
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 for FY 2017-18 | 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 | 31st December 2018* for FY 2017-18 | 31st December 2018* with or after filing GSTR-9 for FY 2017-18 |
| 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 |
| Annexures | No annexures to be attached | Annexure of Audited financial statement is required |
Due date for filing GSTR-9, GSTR-9A and GSTR-9C is extended till 31st March 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. Moreover, whether or not there were business operations during the year, this must be filed by 31st December of the year following the financial year under consideration.
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.
