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

What is GSTR-9C return?

GSTR 9C is an annual audit form or reconciliation statement As the name suggests, it is a report showing year-end reconciliation arising out of the difference in the of the taxpayer and the GSTR 9 (i.e., annual return) for the relevant year. It consists of the gross and taxable turnover as per the books reconciled with the respective figures as per the consolidation of of all GST returns. Any difference arising in the reconciliation is reported in GSTR-9C aligns with the reasons for the same. This certified statement has to be generated for every GSTIN. GSTR-9C should be prepared and self-certified by the taxpayer. It should be filed through the GST portal or through a facilitation center.

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GSTR-9C Applicability

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.5Cr. In other words, a registered taxpayer having a turnover of less than or equal to Rs.5Cr. is not required to file GSTR 9C.

All foreign companies that are in the airline business and compliant with the relevant provisions and rules of the Companies Act 2013 are exempt from filing GSTR-9C.
Non-residents providing OIDAR service in India to unregistered persons have been exempted from filing GSTR-9 and GSTR-9C.

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

GTSR 9C, i.e., the annual audit report, needs to be submitted along with the annual return, GSTR 9. This means that the due date to file GSTR-9C is the same as the due date for submitting the annual returns in GSTR-9C is the same as GSTR-9 due date, i.e., 31st December of the year subsequent to the relevant F.Y.

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What is the Importance of GSTR-9C?

The taxpayer is responsible for preparing the GST Reconciliation statement. Any differences between the sales, tax, or input tax credit reported in the GST returns and the Audited Accounts should be noted in this statement, along with the reasons for these differences.

This statement serves as a reference for GST authorities to verify the accuracy of the GST returns filed by taxpayers after self-certification.

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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

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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.

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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
• Copy of Audited Accounts
• Copy of Annual Reports
• Annual audit report should be the one where the audit is conducted by another person under a statute.
• Others prescribed

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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-

Steps to Generate Form GSTR-9C JSON File

1. Log in to the GST portal and download the GSTR-9 and GSTR-9C tables.
2. Download the GSTR-9C Offline Tool from the "Downloads" section.
3. Enter data into the Offline Tool, preview the draft, and generate the JSON file.

How to Upload the GSTR-9C JSON File

1. Log in to the GST portal, select "Annual Return," and click "Prepare Offline."
2. Upload the JSON file. If needed, make changes, re-generate the file, and upload again.
3. Fix errors by downloading the Error Report, making corrections, and re-uploading.

Steps to File Form GSTR-9C

1. Upload financial documents like the balance sheet and profit and loss statement (PDF format).
2. Save each upload and click "Proceed to File."
3. Preview and verify the details, then click "File GSTR-9C."
4. Track the filing status under "View Filed Returns."

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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: Reconciliation Statement

• Part I - Basic Details 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: Reconciliation of Turnover 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: Reconciliation of Tax Paid 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: Reconciliation of Input Tax Credit (ITC) 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: Verification or Self Certification

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.

Filing GSTR-9C is crucial for ensuring accurate GST reconciliation for businesses with a turnover exceeding Rs. 5 crore. If you are a small business owner and need help with GST filing, you can contact our experts, who can help you file your GSTR accurately. Hire an expert now!

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