GSTR 9C : Reconciliation Statement & Certification- Filing, Format & Rules

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What is GSTR-9C return?

GSTR 9C is an annual audit form a.k.a. reconciliation statement released by the government on 13 Sep,2018. As the name suggests, it is a report showing year-end reconciliation, arising out of the difference in Books of Accounts of the taxpayer and the GSTR 9 (i.e. annual return) for the relevant year. But, to our joy, not all registered taxpayers are required to file GTSR 9C. Instead, only those having the aggregate turnover exceeding Rs 2 crore during the relevant previous year are bound to follow this provision under Section 35 (5) of CGST ACT, 2017. Further, to the ease of tax filers, no hard copies are required to be furnished. Rather, a simple click and online submission to the GSTN portal will be construed as complete compliance of the law.

Who should file GSTR-9C? Is it mandatory to be filed by all taxpayers?

For understanding applicability of GSTR 9C lets us bifurcate taxpayers into two categories

  • Registered
  • Unregistered

The liability to file GSTR 9C has been imposed only on registered taxpayers having aggregate turnover during the relevant year in excess of Rs 2 Cr. In other words, a registered taxpayer having a turnover of less than or equal to Rs.2 Cr. is not required to file GSTR 9C. But since GSTR 9C is an Audit Report the shall be duly certified by a practicing Chartered Accountant or Cost Accountant.

What are the new changes brought in GTSR-9C reconciliation Statement?

Apart from making the following table details optional

  • Table 5B to 5N
  • Table 12B and 12C
  • Table 14

Amendments in structure of GSTR 9C has been changed as under

  • Words “True and Fair” certifying the audit report u/s GSTR 9C has been changed to “True and Correct”
  • Cash Flow Statement is required to be furnished only in case of availability of the same.

What is the due date for filing of GSTR-9C?

The due date for filing GSTR 9C has not been explicitly mentioned under the provisions of law. But, the same needs to be derived from the interpretation of section 44 (2) of the CGST Act, 2017. Which states that GTSR 9C i.e. annual audit report needs to be submitted along with the annual return, GSTR 9. As per Section 44(1) of the CGST ACT, 2017 read with Rule 80 of the CGST Rules, 2017 the due date of filing GSTR 9 for the FY 2017-18 is 31st Dec 2018. Hence, we can say that the due date for filing GSTR 9C is also 31st Dec 2018.

What is the penalty for the late filing of GSTR-9C?

As per section 125 of CGST and SGST Act 2017, there is a general penalty of Rs 25,000/-. Since no specific penalty has been introduced for late filing of GSTR 9C, we may say that the general penalty as mentioned above shall levy upon a defaulter in this situation

Is it possible to revise my GSTR 9C form?

In the absence of any clear provision to revise GSTR 9C under Section 44 or Rule 80 of the CSGT Act 2017. A clear understanding can be drawn that GSTR 9C once filed cannot be amended.

What are the documents required to be submitted along with GSTR 9C?

Documents required to be submitted along with the Reconciliation statement in GSTR 9C are Audited Financial Statements such as

  • Balance Sheet
  • Profit & Loss account or Income & expenditure account
  • Cash flow statement
  • Others prescribed

What is the step by step process to file GSTR 9C?

Here is the list of quick steps that need to be followed for filing the reconciliation statement-

1. Each registered person is required to maintain Books of accounts (records/documents) under GST law and other laws.
2. Prepare these Annual Financial Statements based on Books of accounts
  • Balance Sheet
  • Profit & Loss Account
  • Income & expenditure account
  • Cash flow statement (if applicable)
*Annual financial statements are prepared at PAN level
3. Get Annual Financial Statements audited under the applicable laws eg Income Tax Law, Companies Act etc. A view can be given that if audited in any other law, the audit might not be separately required to be conducted under GST.
4. If not audited under any other law, then get it audited under GST law. As per GSTR 9C instructions in Part 5 Audit at PAN level should be sufficient. There shall not be in general need to get an audit done on GSTIN level.
5. GSTIN wise details of assessee are collected in respect of
  • Turnover
  • ITC
  • Tax paid etc
Reconcile the details with GSTR-9 in part A of GSTR-9C and differences are to be reported therein.
6. Thereafter Certification has to be done in part B either by CA or CMA.
7. Part B of GSTR-9C in itself is an audit as well as certification. As there is no separate audit report format provided under the law.
8. GSTR-9, GSTR-9C and audited annual financial statement (audited whether under GST or any other law) and such other details as may be prescribed (nothing prescribed till date) are required to be uploaded on the common portal on or before the end of December of subsequent FY. (Now 31st March 2019 date extended)

Can you explain the Structure of the Reconciliation Statement GSTR-9C?

The reconciliation statement is required to be prepared in two parts:-

  • Part A is the reconciliation statement
  • Part B is the certification by the chartered accountant or the cost accountant who has drawn the Part A.

Let us understand both the parts in detail:

Part A: This part if further subdivided into 5 parts as discussed below:
  • Part I seeks the basic details about the registered person i.e. FY, GSTIN, legal name, trade name. In addition, it also requires to mention as to whether the registered person is liable to be audited under any other Act and if yes, the reference to that Act has to be specified.
  • Part II: This part requires the reconciliation of turnover declared in an audited financial statement with the turnover declared in Annual return (GSTR 9). It has the following Tables:
    1. Table 5: requires making addition and subtraction of various specified categories of items from the gross turnover of the audited annual financial statement to arrive at the gross turnover as per the GSTR-9. The difference between two is reported as un-reconciled turnover.
    2. Table 6: The auditor is required to explain the reasons of the unreconciled differences in the annual gross turnover.
    3. Table 7: This table requires reconciliation of taxable turnover as declared in the audited annual financial statement with the GSTR-9 taxable turnover. The difference between Table 5 and Table 7 is that in case of Table 5, the reconciliation is between gross turnover (which includes taxable as well as non-taxable turnover) whereas Table 7 provides for reconciliation between taxable turnover.
    4. Table 8: Explanation of reason of the difference between taxable turnover is required to be given in this Table.
  • Part III: This part deals with the reconciliation of taxes paid. It has the following tables:
    1. Table 9: This table requires reconciliation of rate wise liability and the amount payable thereon. The turnover in the audited annual financial statement may be liable to tax at different rates. There is need to provide details of taxable value and tax payable for goods or services supplied at various rates. This amount is required to be compared with the total turnover and tax liability declared in the Annual Return.
    2. Table 10: This table requires the auditor to explain the reasons for un-reconciled payment of amount.
    3. Table 11: This table is summary of the additional amount payable by virtue of differences which have arisen in the Table 6, 8 and 10 above. The tax declared under this table has to be paid in cash.
  • Part IV: This part deals with reconciliation of Input Tax Credits as per books of account and ITC as declared in the Annual Return. Following are tables required to be reported/reconciled with respect to the ITC:
    1. Table 12: Reconciliation of net input tax credits as per audited annual financial statements for the GSTIN viz a viz Input Tax Credit availed in the GSTR-9 suitably adjusted for the credits pertaining to the one financial year availed in different financial year. The difference between the two is un-reconciled ITC.
    2. Table 13: Reasons for un-reconciled ITC has to be declared in the Table 13.
    3. Table 14: This table requires submission of details as to the credits availed on various categories of expenses as per audited annual financial statement or books of account. This detail has to be reconciled with the credits availed in the GSTR-9
    4. Table 15: The reason of the difference in credits as per books of account and GSTR-9 as arrived under Table 14 has to be reported under this table.
    5. Table 16: This part requires the auditor to comment upon the tax payable on unreconciled differences in ITC which has arisen in table 13 and Table 15.
  • Part V: This part requires the auditor to recommend additional liability arising due to non-reconciliation. The additional liability has be mentioned separately under various categories of rates of tax, input tax credits, interest, late fees, penalty, any other amount not included in the GSSTR-9, erroneous refund to be paid back and outstanding demands to be settled.
Part B:

This part provides the format of certification by the auditor. The format I is applicable when the certification is done either by the chartered accountant/cost accountant who had conducted the audit whereas Format II is applicable where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the person who had conducted the audit of the accounts.

FAQ’s on GSTR 9C Requirement for Filing

Q - A registered person having business in multiple states, shall get GST audit done separately for each state?

Based on the understanding that, if the audit has been completed under any other law, there may not be the requirement of getting books of account and records audited under the GST Act again. Accordingly, such person may not get the state level accounts audited separately. However, the certification as required under GSTR-9C is to be given separately for each of the GSTIN.

Q - For the purposes of furnishing audit report under GSTR 9C, whether state-level financial statements are required to be prepared?

As per GSTR-9C, Part B auditor is required to examine the balance sheet, profit and loss account and cash flow at GSTIN level. This could lead to a view that there is need to prepare the trial balance, profit and loss account and balance sheet at the GSTIN level.
However, if one considers the instruction 5A, it provides that in case of the multi-locational unit, the turnover may be derived from the internal records of the registered person from the audited financial statement. This further states that reference to audited annual financial statement includes reference to books of account in case of persons having multi presence. Based on this, it appears that even if the state level transactions could be identified from the internal record, it could be said to be the fulfillment of the requirement of law. Hence, based on this, the author is of the view that there is no need to prepare a state level balance sheet and profit and loss account. However, it is suggested to have state-level trial balance so that all transaction pertaining to that State could be separately identified and reported in the GSTR-9 and GSTR-9C.

Q -What shall be the audit requirement under GST in case of a partnership firm having income above Rs. 2 crores but not required to be audited under any other law.

Considering the fact that the turnover exceeds Rs. 2 crores and audit has not been under any other law, there is a compulsory requirement to get the accounts audited under the GST Act. The audit report would be given in Part B of GSTR-9C along with comment/qualification of additional liability on unreconciled differences as per Part A of the GSTR-9C.

CA Abhishek Soni
CA Abhishek Soni

Abhishek Soni is a Chartered Accountant by profession & entrepreneur by passion. He is the co-founder & CEO of Tax2win is amongst the top 25 emerging startups of Asia and authorized ERI by the Income Tax Department. In the past, he worked in EY and comes with wide industry experience from telecom, retail to manufacturing to entertainment where he has handled various national and international assignments.