What parameters are CFOs
focusing on to avoid GST scrutiny? What parameters are CFOs focusing on to avoid GST scrutiny?

How to prepare Form GSTR-9C

Updated on: Dec 11th, 2024

5 min read

GSTR-9C is a reconciliation statement to be self-certified and filed by certain taxpayers under GST. It needs due verification of the annual GST returns in GSTR-9 with the audited financial statements for a given financial year to report any gaps.

Latest Updates
53rd GST Council meeting
As on 22nd June 2024, the Council has recommended to provide relaxation to taxpayers from filing GSTR-9/9A for FY 2023-24 where their aggregate annual turnover for the said financial year is below Rs.2 crore. This was notified via CGST notification 14/2024 dated 10th July 2024.

Introduction to GSTR-9C

GSTR-9C is a reconciliation statement for reconciling values between the annual GSTR-9 of a financial year and the audited financial statements of the taxpayer. Every registered taxpayer whose turnover exceeds Rs.5 crore during a financial year is required to file this reconciliation statement. This ensures correct self-assessment of taxes for a financial year by the applicable taxpayer. The taxpayer shall prepare this statement and later file online or through a facilitation centre along with a copy of the audited financial statements and the GSTR-9 return for the financial year.

What are the Sections to be Filled in Form GSTR-9C?

GSTR-9C is divided into the following sections:

Part-A: Reconciliation Statement

The figures in the audited financial statements are at PAN level. Hence, the turnover, Tax paid and ITC earned on a particular GSTIN (or State/UT) must be pulled out from the audited accounts of the organisation as a whole.

The Reconciliation Statement is divided into five parts as follows:

Part-I: Basic details: Consists of FY, GSTIN, Legal Name and Trade Name. The taxpayer must also mention if he is subject to audit under any other law.

Part II: Reconciliation of turnover declared in audited financial statements and the one declared in Annual Return
This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that most often, the Audited Financial statements are at a PAN level.

This might require the break up of the audited financial statements at GSTIN level for reporting in GSTR-9C. Details of turnover adjustments to be made in tables 5B to 5N have been made optional, and adjustments, if any, which are required to be reported can be reported in Table 5O by the taxpayer. You can refer to the list of optional tables here.

This update is as per Notification No: 56/2019 issued on 14th November 2019. This part consists of four tables –

Table 5: Reconciliation of gross turnover

Table	Name	Details
A	Turnover (including exports) as per audited financial statements for the State / UT	The turnover (including exports) as per the audited financial statements should be reported here. The same should be derived and reported GSTIN-wise, and not at a PAN level.
B	Unbilled revenue at the beginning of Financial Year	Any unbilled revenue at the beginning of the FY on which GST was payable during the current year, will be added to the turnover reported under A.
C	Unadjusted advances at the end of the Financial Year	Any advances at the end of the FY, on which GST has been paid but the revenue has not been recognised, will be added to the turnover reported under A.
D	Deemed supply as per Schedule I	Any deemed supply under Schedule I of the CGST Act will be added to the turnover reported under A, provided the same has not already been included in the turnover reported in the audited financial statements.
E	Credit notes issued after the end of the financial year but reflected in the annual return	All credit notes that were issued after the end of the FY but reflected in the annual return will be reduced from the turnover reported under A.
F	Trade discounts accounted for in the audited Annual Financial Statement but are not permissible under GST	All trade discounts that have been accounted for in the audited annual financial statement, on which GST was leviable, will be added to the turnover reported under A
G	~~Turnover from April 2017 to June 2017~~	~~The pre-GST turnover for the period between April and June 2017 will be reduced from the turnover reported under A~~ (No longer required)
H	Unbilled revenue at the end of the financial year	Any unbilled revenue recorded during the FY, which has accrued but not liable to GST in the same FY, will be reduced from the turnover reported under A.
I	Unadjusted Advances at the beginning of the financial year	All advances at the beginning of the financial year, on which GST has not been paid but the same recognised as revenue in the audited financial statements, will be reduced from the turnover reported under A.
J	Credit notes accounted for in the audited annual financial statement but are not permissible under GST	All credit notes that have been accounted for in the audited annual financial statements, but are not allowable under the CGST Act, will be added to the turnover reported under A.
K	Adjustments on account of supply of goods by SEZ units to DTA Units	Any adjustments on account of supply of goods by SEZ units to DTA units (where the DTA units have filed bills of entry) will be reduced from the turnover reported under A.
L	Turnover for the period under composition scheme	The turnover for the period under the Composition Scheme (for those taxpayers who have opted out during the year), should be reduced from the turnover reported under A.
M	Adjustments in turnover under section 15 and rules thereunder	Any differences between the turnover declared in the annual return and the audited annual financial statements, due to the principles of valuation under section 15 of the CGST Act, should be added/reduced from the turnover reported under A.
N	Turnover adjustments due to foreign exchange fluctuations	Any adjustments in turnover due to foreign exchange fluctuations should be added/reduced from the turnover reported under A.
O	Turnover adjustments due to reasons not listed above	Any other adjustments in turnover for reasons not listed above should be added/reduced from the turnover reported under A
P	Annual turnover after adjustments as above	It will be auto-populated based on the above additions and reductions.
Q	Turnover as declared in Annual Return (GSTR-9)	Turnover declared in GSTR-9 is to be reported here.
R	Un-Reconciled turnover (Q – P)	It will be the difference between P and Q.

Table 6: A taxpayer can provide reasons for non-reconciliation between the turnover declared in the annual return and the audited annual financial statements here.

Table 7: Reconciliation of taxable turnover

Table	Name	Details
A	Annual turnover after adjustments (from 5P above)	It will be auto-populated from Table 5P above.
B	Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover	The value of exempted, nil rated, non-GST supplies, and no-supply turnover should be reported here (net of credit/debit notes and amendments, if any).
C	Zero-rated supplies without payment of tax	The value of supplies which are zero-rated (including supplies to SEZs) and for which no tax was paid should be reported here (net of credit/debit notes and amendments, if any).
D	Supplies on which tax is to be paid by the recipient on reverse charge basis	Value of supplies for which tax is to be paid by the recipient under reverse charge should be reported here (net of credit/debit notes and amendments, if any).
E	Taxable turnover as per adjustments above (A-B-C-D)	It is (A-B-C-D).
F	Taxable turnover as per liability declared in Annual Return (GSTR9)	The taxable turnover with regard to the liability listed in the annual return GSTR-9 (Tables 4N to 4G and Tables 10-11).
G	Unreconciled taxable turnover (F-E)	It will be the difference between F and E.

Table 8: A taxpayer can provide reasons for un-reconciled taxable turnover in Table 7G over here.

Part III: Reconciliation of taxes paid
This section requires GST rate-wise reporting of the tax liability that arose as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to unreconciled differences noticed upon reconciliation. This part consists of three tables –

Table 9: Reconciliation of taxes paid

Table	Name	Details
A-O	Rates of taxes	Under Tables A-O, one needs to report taxable values, central, state tax, integrated tax and cess value for each tax rate (5%, 12%, 18%, 28%, 3%, .25% and .10%). If tax is paid under reverse charge, the same needs to be reported as a separate line item under rows marked RC. Interest, late fees and penalties should also be reported.
P	Total amount to be paid as per tables above	It is a sum total of A to O.
Q	Total amount paid as declared in Annual Return (GSTR 9)	Amount of tax paid as reported in GSTR-9 should be reported here.
R	Unreconciled payment of amount	It is a difference between P and Q

Table 10: A taxpayer can provide reasons for any un-reconciled amount of tax in Table 9R here.

Table 11: Any amount which is payable due to reasons specified under Table 6, 8 and 10 above shall be reported here.

Part IV: Reconciliation of ITC
This part consists of the reconciliation of input tax credit availed and utilised by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement.

Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any.

A Taxpayer has the option to not fill details of ITC reconciliation in tables 12B, 12C and 14. This update is as per Notification No: 56/2019 issued on 14th November 2019. This part consists of five tables –

Table 12: Reconciliation of net input tax credit

Table	Name	Details
A	ITC availed as per audited Annual Financial Statement for the State/ UT	ITC availed as per audited financial statements for the should be reported here. In case of multiple GSTIN’s under the same PAN, an entity should internally derive at ITC for individual GSTIN’s for reporting.
B	ITC booked in earlier Financial Years claimed in current Financial Year	Any ITC booked in the earlier FY but availed in the current FY should be reported here. For e.g., any transitional credit of earlier years reported in the current year should be reported here.
C	ITC booked in current Financial Year to be claimed in subsequent Financial Years	Any ITC booked in the current FY but not credited to the ITC ledger should be reported here.
D	ITC availed as per audited financial statements or books of account	It is a sum total of A, B, and C above.
E	ITC claimed in Annual Return (GSTR9)	Net ITC as declared in Table 7J of GSTR-9 should be reported here.
F	Unreconciled ITC	It is a difference of 12D and 12E above.

Table 13: Reasons for unreconciled ITC in Table 12F should be provided here.

Table 14: Reconciliation of ITC declared in GSTR-9 with the ITC availed on expenses as per audited financial statement or Books.

A-Q	Expenses	Various sub-heads of general expenses are mentioned in these Tables. A taxpayer needs to declare respective ITC against each head. He can also add/delete any expense head as per applicability.
R	Total amount of eligible ITC availed	It is a sum total of A-Q above.
S	ITC claimed in Annual Return (GSTR9)	Net ITC as declared in Table 7J of GSTR-9 should be reported here.
T	Un-reconciled ITC	It is a difference of 14R and 14S above.

Table 15: Reasons for non-reconciliation between ITC availed on the various expenses declared in Table 14R and ITC declared in Table 14S shall be specified here.

Table 16: Any amount which is payable due to reasons specified in Table 13 and Table 15 above shall be reported here.

Part V: Additional Liability due to non-reconciliation

This part consists of:

Additional liability arising on the part of a taxpayer due to non-reconciliation of turnover or ITC
Any other amount to be paid for supplies not included in the annual return.
Erroneous claiming of refund which should be paid back to the government.
Any other outstanding demands to be paid off.

Note: Towards the end of the GSTR-9C return form, taxpayers have the option of making payment for any additional liability declared in the form, through FORM DRC-03. A taxpayer has to select ‘Reconciliation Statement’ from the dropdown menu provided in FORM DRC-03. Such liability can be paid through the electronic cash ledger only.

Verification by the taxpayer

Form GSTR-9C should be self-certified by the taxpayer. He should authenticate the return either through a DSC or by using Aadhaar based signature mechanism.

Format of GSTR-9C is given below-

How to file GSTR-9C?

GSTR-9C is prepared using the offline utility tool available on the GST portal. Prerequisites are as follows-

Taxpayer must be registered and should have a valid GSTIN.
User should have valid GSTN login credentials i.e., User ID and password
User has filed GSTR-9 for the relevant financial year.
The aggregate annual turnover of such registered person for the specific financial year exceeds Rs.5 crore.

On the GST Portal, GSTR-9C tile gets enabled only after filing the form GSTR-9 of that financial year.

Taxpayer must follow the below steps to file GSTR-9C-
A. On the GST Portal:

Login to the GST Portal to take following actions-
a. Download Filed Form GSTR-9
b. Download Form GSTR-9C Tables Derived from Form GSTR-9
c. Download latest version of GSTR-9C Offline Tool from the GST portal

B. On the offline tool:

Prepare GSTR-9C statement offline using GSTR-9C Offline Tool by
taking following actions-
a. Open the GSTR-9C Offline Utility Excel Worksheet
b. Add table-wise details in the Worksheet
c. Generate Preview PDF file to view Draft Form GSTR-9C
d. Generate JSON File

For the detailed steps on how to prepare GSTR-9C using the offline tool, refer to our article “How to file GSTR-9C using the Offline Utility”.

C. On the GST Portal

Upload the generated JSON File on GST Portal.
Note:

In case of Error during upload: Download the error report. Make corrections and
upload the updated JSON.
Before filing, in case taxpayer wants to add or edit data in the file that has
been successfully processed without error: Download the processed GSTR-9C
JSON File from GST Portal. Import the same to Offline Tool, make
corrections and upload the updated JSON.

D. File Form GSTR-9C and view/download the filed form for reference.

About the Author

AJ

Functional Specialist

DVSR Anjaneyulu, known by the name AJ, I've got a vast experience in accounting, finance, taxes and audit. I'm always keen to simplify laws for the readers and learn about the Indian finance ecosystem. I also love listening to music, travelling, and, most importantly, conversing with people to better understand the world.. Read more

Browse by topics

Income Tax e-Filing

Income Tax Calculator

Income Tax Slabs FY 2024-25

Old vs New Tax Regime

How To File ITR

New Tax Regime

Which ITR Should I File

Last Date To File ITR For 2024-25

Income Tax Sections & Deductions

Income Tax Refund

Capital Gains Income