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Guide to Preparing Form GSTR-9C

By AJ

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Updated on: Feb 23rd, 2023

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12 min read

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GSTR-9C is a reconciliation statement to be submitted by a taxpayer under GST. It is to be self-certified by the taxpayer after a due verification of the annual GST returns in GSTR-9 with the financial statements.

Latest Updates

18th February 2023
49th GST Council meeting updates-
1. Council recommended the late fee rationalisation for delayed GSTR-9 filing from FY 2022-23 onwards as follows: 
   (a) Registered persons with Annual Aggregate Turnover (AATO) up to Rs.5 cr is reduced to Rs. 25 per day subject to a maximum of 0.02% of turnover.
   (b) Registered persons with AATO of more than Rs.5 cr to 20 cr is reduced to Rs 50 per day subject to a maximum of 0.02% of turnover.
2. The Council recommended an amnesty scheme for pending GSTR-9 returns. This scheme comes with a conditional waiver/ reduction of late fees.

16th November 2022
Changes are made in the format of GSTR-9 (annual returns), to mention the period after the FY 2021-22 as ‘April 2022 to October 2022 filed up to 30th November 2022’ instead of ‘April 2022 to September 2022’ in various tables.

05th July 2022
The department has exempted taxpayers with a yearly turnover of more than Rs.2 crore during the FY 2021-22 from filing GSTR-9 or annual returns.
 

What is form GSTR-9C?

GSTR-9C is a reconciliation statement between the annual GSTR-9 of a financial year and the audited financial statements of the taxpayer. Every registered taxpayer whose turnover exceeds Rs.2 crore during a financial year is required to file this reconciliation statement. This ensures correct self-assessment of taxes by a taxpayer.  The taxpayer shall prepare this statement and later filed by a taxpayer online or through a facilitation centre along with a copy of the audited financial statements and the GSTR-9 return.

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

GSTR-9C is divided into two parts:

Part A is the reconciliation statement which is further subdivided into five sub-parts: 

Part I: Basic Details 
Basic details such as the GSTIN, FY, legal name and trade name are to be reported here. A taxpayer is also supposed to report 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 part consists of four tables –

Table 5: Reconciliation of gross turnover

Table
 
Name
 
Details
ATurnover (including exports) as per audited financial statements for the State / UTThe 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.
BUnbilled revenue at the beginning of Financial YearAny 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.
CUnadjusted advances at the end of the Financial YearAny 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.
DDeemed supply as per Schedule IAny 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.
ECredit notes issued after the end of the financial year but reflected in the annual returnAll 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.
FTrade discounts accounted for in the audited Annual Financial Statement but are not permissible under GSTAll 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
GTurnover from April 2017 to June 2017The pre-GST turnover for the period between April and June 2017 will be reduced from the turnover reported under A.
HUnbilled revenue at the end of the financial yearAny 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.
IUnadjusted Advances at the beginning of the financial yearAll 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.
JCredit notes accounted for in the audited annual financial statement but are not permissible under GSTAll 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.
KAdjustments on account of supply of goods by SEZ units to DTA UnitsAny 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.
LTurnover for the period under composition schemeThe 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.
MAdjustments in turnover under section 15 and rules thereunderAny 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.
NTurnover adjustments due to foreign exchange fluctuationsAny adjustments in turnover due to foreign exchange fluctuations should be added/reduced from the turnover reported under A.
OTurnover adjustments due to reasons not listed aboveAny other adjustments in turnover for reasons not listed above should be added/reduced from the turnover reported under A
PAnnual turnover after adjustments as aboveIt will be auto-populated based on the above additions and reductions.
QTurnover as declared in Annual Return (GSTR-9)Turnover declared in GSTR-9 is to be reported here.
RUn-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

TableNameDetails
AAnnual turnover after adjustments (from 5P above)It will be auto-populated from Table 5P above.
BValue of Exempted, Nil Rated, Non-GST supplies, No-Supply turnoverThe 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).
CZero-rated supplies without payment of taxThe 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).
DSupplies on which tax is to be paid by the recipient on reverse charge basisValue 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).
ETaxable turnover as per adjustments above (A-B-C-D)It is (A-B-C-D).
FTaxable 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).
GUnreconciled 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 part consists of three tables –

Table 9: Reconciliation of taxes paid

TableNameDetails
A-ORates of taxesUnder 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.
PTotal amount to be paid as per tables aboveIt is a sum total of A to O.
QTotal amount paid as declared in Annual Return (GSTR 9)Amount of tax paid as reported in GSTR-9 should be reported here.
RUnreconciled payment of amountIt 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 five tables –

Table 12: Reconciliation of net input tax credit

TableNameDetails
AITC availed as per audited Annual Financial Statement for the State/ UTITC 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.
BITC booked in earlier Financial Years claimed in current Financial YearAny 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.
CITC booked in current Financial Year to be claimed in subsequent Financial YearsAny ITC booked in the current FY but not credited to the ITC ledger should be reported here.
DITC availed as per audited financial statements or books of accountIt is a sum total of A, B, and C above.
EITC claimed in Annual Return (GSTR9)Net ITC as declared in Table 7J of GSTR-9 should be reported here.
FUnreconciled ITCIt 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-QExpenses
 
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.
 
RTotal amount of eligible ITC availed
 
It is a sum total of A-Q above.
 
SITC claimed in Annual Return (GSTR9)
 
Net ITC as declared in Table 7J of GSTR-9 should be reported here.
 
TUn-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:

  1. Additional liability arising on the part of a taxpayer due to non-reconciliation of turnover or ITC
  2. Any other amount to be paid for supplies not included in the annual return. 
  3. Erroneous claiming of refund which should be paid back to the government.
  4. 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.   

Part B is for certification. 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.

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About the Author

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

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