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GST compliance gets confusing sometimes, especially when it comes to differentiating between GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement). Perplexity about their distinct purposes, who needs to file, and what they entail often results in costly errors, penalties, or audits. For businesses with higher turnover, these challenges can feel especially overwhelming.
We will simplify the complexities of GSTR-9 and GSTR-9C, offering clear explanations of their differences and requirements.
Every year, businesses registered under the Goods and Services Tax (GST) regime must file the GSTR-9 annual return. This comprehensive document consolidates details of outward and inward supplies made during the financial year, categorized under different tax heads like CGST, SGST, IGST, and HSN codes. It essentially serves as an amalgamation of all the quarterly and monthly returns (GSTR-1, GSTR-2A, and GSTR-3B) filed throughout the year. While the process can be complex, the GSTR-9 plays a crucial role in ensuring complete data reconciliation and promoting full transparency in disclosures.
The filing of GSTR-9 is mandatory for all regular taxpayers, including developers and SEZ unit holders, who have submitted their monthly or quarterly returns. The return captures critical information such as details of supplies (both inward and outward), input tax credits availed, taxes paid, and other relevant declarations. The deadline for submitting the GSTR-9 is December 31st of the year following the financial year under review.
GSTR-9C was introduced on September 13, 2018. The form is designed particularly for taxpayers with an annual turnover exceeding two crores. This form needs certification from qualified chartered accountants. This form acts as a reconciliation statement and bridges the gap between taxpayer’s audited annual financial records and the annual return filed under GSTR-9.
The form consolidates all GST returns filed during the financial year and compares the gross and taxable turnover as per the taxpayer’s books of accounts with the figures reported in GSTR-9. Any discrepancies identified during this reconciliation process must be clearly outlined, along with an explanation for the differences. It is important to note that a separate GSTR-9C must be filed for each GSTIN registered under the taxpayer.
We have simplified the comparison between the GSTR-9 and the GSTR-9C through below table:
| Particulars | GSTR-9 | GSTR-9C |
|---|---|---|
| Type | Annual Return | Reconciliation Statement |
| GST Act | Section 44(1) of the CGST Act | Section 35(5) of the CGST Act |
| Applicability |
All Registered Taxpayers
|
To be filed if the turnover in a financial year (FY) exceeds ₹2 Cr:
|
| Exceptions |
|
|
| Signature | Digitally signed by the registered taxpayer | Digitally signed by the GST Auditor (CA/CMA) (Note: This requirement may not always apply) |
| Threshold | No specific threshold | Subject to a turnover threshold |
| Financial Annexures | Not required | Required |
| Filing Timeline | Must be filed before GSTR-9C | GSTR-9C must be filed after GSTR-9 |
| Due Date | 31st December of the following Financial Year | 31st December of the following Financial Year (with or after filing GSTR-9) |
| Filing Method | On the GST Portal or through facilitation centers | On the GST Portal or through facilitation centers |
| Return Format |
A comprehensive summary covering:
|
|
| Late Fees |
Minimum Penalty:
Up to 0.25% of the taxpayer’s turnover |
As per Section 125 of the CGST Act, 2017, A penalty of up to Rs. 25,000 may be applicable for not getting the accounts audited. |
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Composition scheme taxpayers, casual taxable persons, non-resident taxable persons, and persons paying TDS or TCS are exempted from filing GSTR-9.
No, it is optional to report the HSN code in GSTR-9.
You must report the ITC reversal in Table 7 of GSTR-9.
You must use DRC-03 to pay the additional liability found in GSTR-9.
Currently, there is no provision to revise GSTR-9C.
Yes, GSTR-9C should be filed for every registration in each state.
