GSTR-9C: Due Date, Applicability, Turnover Limit & Filing Process

GSTR 9c is a crucial annual compliance requirement under the Goods and Services Tax (GST) regime in India. As a registered taxpayer, it’s essential to understand the intricacies of this reconciliation statement, including its applicability, GSTR 9c due date, format, and the step-by-step filing process. In this comprehensive guide, we’ll walk you through everything you need to know about GSTR-9c to ensure timely and accurate compliance.

What is GSTR-9C?

GSTR 9c is a reconciliation statement that registered taxpayers must file annually along with their GST annual return (GSTR-9). The primary purpose of this statement is to reconcile the figures reported in the annual return with those in the audited financial statements.

Here are the key points to understand about GSTR-9c:

• It is a statement that compares the gross and taxable turnover as per the books of accounts with the respective figures mentioned in the consolidation of all GST returns filed for the financial year.

• Any discrepancies identified during this reconciliation must be reported in GSTR 9c along with explanations and then certified by the taxpayer.

• The certified statement must be submitted for each GSTIN, meaning multiple GSTR-9c forms may be required for a single PAN.

• GSTR 9c must be prepared and self-certified by the taxpayer, then filed on the GST portal or through a facilitation centre.

• Supporting documents, such as a copy of the audited accounts and the GSTR-9 annual return, must also be submitted.

GSTR-9C Applicability & Turnover Limit

Not all registered taxpayers are required to file GSTR-9c. The applicability of this reconciliation statement depends on the annual turnover of the business. Here’s what you need to know about the 9c applicability and GSTR 9c turnover limit:

• Every registered person under GST with an annual turnover exceeding ₹5 crore is required to file GSTR-9c.

• According to CBIC’s CGST Notification No. 30/2021 dated 30th July 2021, foreign companies in the airline business, compliant with the Companies Act 2013, are exempt from filing GSTR-9c.

• Non-residents providing OIDAR services to unregistered persons in India are exempt from filing both GSTR-9 and GSTR-9c.

GSTR-9C Due Date

To ensure timely compliance, it’s crucial to be aware of the GSTR9c due date. The due date for filing GSTR-9c aligns with the due date for submitting the annual return in GSTR-9, which is on or before 31st December of the year following the relevant financial year under audit. The government may extend this deadline if needed. For example, the GSTR 9c due date for FY 2023-24 is 31st December 2024.

GSTR-9C Format & Structure

The GSTR 9c format is divided into two parts: Part A, which is the reconciliation statement, and Part B, which is the certification by a Chartered Accountant or Cost Accountant. Let’s take a closer look at the structure of GSTR-9c:

Part A: Reconciliation statement

• Part I: Basic details about the registered person, such as FY, GSTIN, legal name, trade name, and whether the registered person is liable to be audited under any other Act.

• Part II: Requires reconciliation of turnover declared in the audited financial statement with turnover declared in the Annual Return. There may be reasons for differences.

• Part III: Deals with the reconciliation of taxes paid.

• Part IV: Reconciliation of Input Tax Credits as per books of account and ITC as declared in the Annual Return.

• Part V: Auditor to recommend additional liability arising due to non-reconciliation. Additional liability is mentioned separately under categories of tax rates, ITC, interest, late fees, penalty, any other amount not in GSTR-9, erroneous refund to be paid back, outstanding demands to be settled.

Part B: GSTR 9c certification by a Chartered Accountant or Cost Accountant

Step-by-Step Filing Process for GSTR-9C

Now that you understand the GSTR 9c format and structure, let’s walk through the step-by-step process of how to file GSTR 9c:

1. Visit the official GSTN portal and login with your credentials.

2. Click on the Annual Return tab on the Dashboard.

3. Click on “Initiate e-filing” to be redirected to the GSTR-9 form.

4. Proceed to file the GST Reconciliation statement.

To simplify the GSTR 9c filing process, you can use the GSTR 9c offline tool provided by the GST portal. This tool allows you to prepare and validate your reconciliation statement offline before uploading it to the portal.

Here are the documents required for GSTR-9c filing:

• Audited financial statements (to be enclosed along with the audit report in Form GSTR-9c)

• Balance Sheet Copy

• Profit and Loss Account Statement

• Cash Flow Statement

• Annual Report Copy

GSTR-9C Penalty for Non-Filing

Failing to file GSTR-9c by the due date can result in penalties. Taxpayers who miss the GSTR9c due date are liable to pay a penalty of ₹200 per day of delay (₹100 SGST + ₹100 CGST). The total penalty amount shall not exceed 0.50% of the taxpayer’s turnover in the relevant state/UT.

Conclusion

GSTR-9c is a critical annual compliance requirement under GST for taxpayers crossing the ₹5 crore turnover threshold. It involves GSTR 9c reconciliation of the figures reported in GSTR-9 annual return with those in the audited financial statements. The reconciliation statement aims to identify and explain any discrepancies between the two sets of data.

Taxpayers must prepare and self-certify GSTR-9c, getting it signed by a CA or Cost Accountant. It has to be filed by 31st December of the next financial year. Delay in filing attracts a penalty of ₹200 per day, subject to a maximum of 0.5% of turnover.

GSTR-9c plays a vital role in establishing the veracity of a taxpayer’s annual GST filings. Authorities rely on this reconciliation to verify the accuracy of returns post self-certification. Therefore, businesses must accord high priority to this compliance and ensure timely and error-free GSTR-9c filing each year.

Frequently Asked Questions (FAQs)

Q1. Is it mandatory to file GSTR-9C using the offline utility?

No, it is not mandatory to use the GSTR 9c offline tool for filing. You can choose to file GSTR-9c directly on the GST portal. However, using the offline utility can help you prepare and validate your reconciliation statement before uploading it to the portal, reducing the chances of errors.

Q2. Can I file GSTR-9C using EVC instead of DSC?

Yes, you can file GSTR-9c using Electronic Verification Code (EVC) instead of Digital Signature Certificate (DSC). This option is available for taxpayers who are not required to get their accounts audited under any other law.

Q3. Can GSTR-9C be revised after submission?

No, once you have filed GSTR-9c, it cannot be revised. Therefore, it’s essential to ensure that all the information provided in the reconciliation statement is accurate and complete before submitting it.

Q4. What if there are mismatches in GSTR-9C vs audited financials?

If there are mismatches between the figures reported in GSTR-9c and the audited financial statements, you must provide explanations for these discrepancies in the reconciliation statement. The auditor will also mention these mismatches in their certification report.

Q5. Who can certify Part B of GSTR-9C?

Part B of GSTR-9c, which is the certification, must be signed by a Chartered Accountant or a Cost Accountant. This certification is mandatory for taxpayers with an annual turnover exceeding ₹5 crore.