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…
Update as on 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.
Budget 2021: Update as on 1st February 2021
GST audit requirement by specific professionals such as CAs and CMAs has been removed from the GST law. Section 35 and 44 were amended for this. As per the amendment, only GSTR-9-annual returns on a self-certification basis needs to be filed on the GST portal by taxpayers, completely removing the requirement for GSTR-9C -reconciliation statement. However, the financial year and date of applicability of this removal are yet to be clarified by the government.
Update as on 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.
Update as on 28th Oct 2020
The due date to file GSTR-9 & GSTR-9C for the FY 2018-19 is further extended up to 31st December 2020.
Here is a quick comparison of GSTR-9 & GSTR-9C:
*The due date for filing GSTR-9, GSTR-9C has been extended to 5th & 7th February 2020 for FY 2017-18 and to 30th September 2020 for FY 2018-19.
**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^.
|Points of comparison
||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
||No annexures to be attached
||Annexure of Audited financial statement is required
^GSTR-9 filing for businesses with turnover up to Rs 2 crore made optional for FY 2017-18 and for businesses with an annual turnover of less than Rs 5 crore, filing of GSTR-9C for FY 2018-19 is waived off.
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.