1. 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 get his books audited by a Chartered Accountant/Cost Accountant. This ensures correct self-assessment of taxes by a taxpayer.
The reconciliation statement should be prepared by a Chartered Accountant/Cost Accountant 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.
2. 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|
|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.|
|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|
|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 part consists of three tables-
|Table 9 Reconciliation of taxes paid|
|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 five tables-
|Table 12 – Reconciliation of net input tax credit|
|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: Auditor’s recommendation on additional liability due to non-reconciliation
This part consists of auditor’s recommendations. Recommendations can be regarding:
- 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.
Part B is for certification.
Form GSTR-9C should be certified by a Chartered Accountant or a Cost Accountant. He should authenticate the return either through a DSC or by using Aadhaar based signature mechanism.