GSTR-9C - Frequently Asked Questions (FAQs)

GSTR-9C is a reconciliation statement between the annual GST return in Form GSTR-9 and the audited financial statements of a taxpayer. It is to be furnished on a self-certification basis by taxpayers with a turnover exceeding Rs.5 crore, with a few exemptions. 

Here are some of the frequently asked questions taxpayers have concerning Form GSTR-9C
 

1. What are the system prerequisites for filing GSTR-9C? 
 

The offline utility works best on Windows 7 and above and MS EXCEL 2010 and above.
 

2. What is the time limit to file GSTR-9C and should Form GSTR-9 and Form GSTR-9C be filed separately? 
 

As per Section 44(2), GSTR-9C should be filed along with the Annual Return GSTR-9. Also, as per Section 44(1), the due date to file Annual Return is on or before 31st December following the end of the financial year for which the return is prepared. Thus, it can be inferred that the due date of filing GSTR-9C is on or before 31st December following the end of the financial year for which the return is prepared. For instance, for FY 2022-23, the deadline to file GSTR-9C is 31st December 2023.

3. What are the documents to be enclosed with Form GSTR-9C? 
 

The enterprise's Balance Sheet, Profit and Loss Account/ Income and Expenditure Statement, etc. is to be uploaded during filing of Form GSTR 9C in PDF format.
 

4. What are the steps for creating a JSON file of Form GSTR-9C? 
 

Here is a detailed guide on how to file GSTR 9C offline or online. 
 

5. Can GSTR-9C be revised? 
 

Currently, there is no provision to revise Form GSTR-9C. Hence, taxpayers are requested to take the utmost care when reporting details in Form GSTR-9C and filing the same. 
 

6. Can an internal auditor of an entity certify Form GSTR-9C? 
 

No, an internal auditor cannot certify Form GSTR-9C. Besides, the CBIC has now notified that the Form GSTR-9C be self-certified only.
 

7. Should Form GSTR-9C be filed for state-wise for every registration under the same PAN? 
 

Yes, Form GSTR-9C should be filed for every registration in each state. Once the PAN-based aggregate turnover exceeds Rs.5 crore, every registered GSTIN under the same PAN is required to file Form GSTR-9C. 
 

8. Should a CA be registered as a GST practitioner for certifying Form GSTR-9C? 
 

The CBIC has notified that the Form GSTR-9C is to be self-certified. Hence, a CA is no longer required for certifying Form GSTR-9C.
 

9. Who is required to file GSTR 9C? 
 

Every registered person under GST whose turnover during a financial year exceeds the prescribed limit of Rs.5 crore must file a self-certified reconciliation statement in Form GSTR-9C. This statement is required to be filed by every GST-registered taxpayer, i.e. every GSTIN, and must be submitted along with documents such as a copy of the audited accounts and annual return in Form GSTR-9.

It is to be noted that persons who are non-residents and providing OIDAR service in India to unregistered persons have been exempted from submitting GSTR-9 and GSTR-9C as per CBIC Notification No.30/2019 dated 30th June 2019. Further, as per CBIC Notification No.09/2020 dated 16th March 2020, foreign companies that are in the airline business and compliant with the relevant provisions and rules of the Companies Act 2013 are exempted from the GSTR-9C requirement.  

10. Can GSTR-9C be filed without filing Annual GST Return (GSTR-9)? 
 

No, GSTR-9C can be filed only after filing GSTR-9. 

11. Which fields are auto-populated from GSTR-9 in Form GSTR-9C? 

The following fields will be auto-populated in Form GSTR-9C: 

• The turnover details as per GSTR-9
• Liability as per GSTR-9
• Total tax paid as mentioned GSTR-9
• Input Tax Credit availed in GSTR-9

12. Does aggregate turnover include stock transfers/cross charges between branches located at different states? 

As per Section 2(6) of the CGST/SGST Act, the term aggregate turnover includes inter-state supplies of persons under the same PAN. Thus, a stock transfer from a branch located in one state to the one located in another state will be included in the turnover of the branch supplying goods/services. 

13. Does aggregate turnover include stock transfers/cross charges between branches located in the same state to determine the threshold limits? 

Branches having the same GSTIN: If both the branches have the same GSTIN, then such stock transfers will not be included in aggregate turnover for determining the threshold limit. 
Branches having different GSTIN: If both the branches have different GSTIN’s, then such stock transfers will be included in aggregate turnover for determining the threshold limit. 

14. Is the supply of alcohol for human consumption included in determining the threshold limit of Rs. 5 crores by a registered person? 

The term aggregate turnover includes exempt turnover. As per CGST Act, exempt turnover means supply of any goods or services or both which attracts nil rate of tax or which may be wholly exempt from tax under section 11, or under section 6 of the Integrated Goods and Services Tax Act and includes non-taxable supply. 

Non-taxable supply is a supply of goods or services which is not chargeable to tax under either the CGST Act or the IGST Act. Section 9(1) of CGST/ SGST Act and Section 7(1) and 5(1) of UTGST and IGST Act specifically excludes alcoholic liquor for human consumption from the levy/charge of GST. Thus, on a combined reading of all the sections it can be inferred that alcoholic liquor for human consumption falls under exempt turnover and as exempt turnover is part of the aggregate turnover, the same should be included in computing the threshold limit of Rs.5 crores. 
 

15. Does a registered person exclusively deal in exempted supplies exceeding Rs.5 crores, required to file GSTR-9C? 

Yes, because the definition of aggregate turnover includes exempted supplies. 
 

16. What are the contents of Form GSTR-9C? 

Here are the contents of Form GSTR-9C. 
 

17. What are the late fees for failure in submitting Annual Return and not getting the accounts audited? 
 

If a taxpayer fails to file both Annual Return and Form GSTR-9C, then he is liable to a fee of Rs.200/- per day during which the default continues (Rs. 100 under CGST law + Rs. 100/- under State / Union Territory GST law) *Capped to a maximum amount of .50% (0.25% under the CGST Law + 0.25% under the SGST / UTGST Law) of turnover in the State/UT. These provisions apply to the filing of GSTR-9; however, no specific provisions apply to GSTR-9C, and hence the filing of GSTR-9 and non-filing of GSTR-9C could be subject to a general penalty of Rs 25,000. 
 

18. Can the late fee be waived off in genuine cases? 
 

The Government may do so by way of issue of notification specifying the circumstances but, no such notification has been issued yet. 
 

19. Can mistakes in the monthly return be rectified during GSTR 9C?

No, mistakes in the monthly return cannot be rectified at the time of filing GSTR 9C. GSTR 9C is a self-certified reconciliation statement between the annual GSTR-9 return and the audited financial statements. 

20. Which details are to be provided in Table 5B of Form GSTR-9C? 

Table 5B requires reporting of addition to unbilled revenue at the beginning of the Financial Year. Thus, in simple words, this clause requires reporting of any unbilled revenue, which was recorded in the books of the previous financial year, but the invoice was issued in the current year under the GST law. 

21. Should a taxable person disclose details of notice pay recovery from employees in GSTR-9C? If yes, where should it be reported? 

If the notice pay recovered from employees is considered a taxable supply, but the same is not disclosed as an income in the Profit and Loss account, then it should be reported under Sl.No.5O of GSTR-9C. 

22. Where should the ineligible ITC identified by an auditor which are claimed as eligible by the dealer in GSTR 3B and in Form GSTR 9 be reported in Form GSTR 9C? 

Total ITC availed by the dealer- This is reported in column 3 Part IV of Sl.14 of Form GSTR 9C. Eligible ITC as determined by the auditor- This is reported in column 4 Part IV of Sl.14 of Form GSTR 9C. Thus, the difference between the two is ineligible ITC. The auditor should disclose such ineligible ITC in the Certificate issued by him. 

23. How to download an error report in GSTR 9C?

Once a user uploads the JSON file on the GST Portal, they may receive an error message in case the entries contained in the JSON file failed the GST system’s validation. To download the zipped error report, the user will need to perform the following steps-
Step 1: In the ‘Upload History’ table, click on the ‘Generate error report’ hyperlink.

Step 2: Once the error report has been generated, click on the ‘Download error report’ link displayed in the column ‘Error Report’. 

Step 3: Click on the ‘Download error report’ link to download the zipped error report.

Step 4: The error JSON file will be downloaded on your system. Import the file into the GSTR-9C offline tool to make the necessary corrections.

24. How to initiate signing in GSTR 9C? 

You can refer to our detailed guide on how to file GSTR 9C offline or online. Here are the steps to initiate signing in GSTR 9C.

25. How to attach DSC to GSTR 9C? 

You can refer to our detailed guide on how to file GSTR 9C offline or online.