Introduction to GSTR-9C

GST compliance in India requires annual returns and reconciliations to ensure the accuracy of the data reported throughout the year. GSTR-9C is a crucial component of this compliance framework for businesses with an annual turnover exceeding ₹5 crore, providing a structured comparison between audited financial statements and the filed GST returns.

What is GSTR-9C and Why It Matters

GSTR-9C is a self-certified annual reconciliation statement filed along with GSTR-9. It reconciles the data in your audited financial statements with the figures reported in your GST returns (GSTR-1, GSTR-3B). Its key objectives include:

• Ensuring accuracy of declared turnover and taxes paid.
• Validating Input Tax Credit (ITC) claimed.
• Highlighting and explaining discrepancies between financial records and GST returns.
• Ensuring refund integrity and overall GST compliance.

It is a critical compliance tool for businesses, reducing audit risk and improving credibility with tax authorities.

Who Must File GSTR-9C

GSTR-9C is mandatory for GST-registered taxpayers whose aggregate PAN-level turnover exceeds ₹5 crore in a financial year. It is filed separately for each GSTIN under the PAN if the turnover threshold is crossed.

Due Date for Filing GSTR-9C

The due date for filing GSTR-9C is December 31 following the end of the relevant financial year, alongside GSTR-9. For example, for FY 2024-25, the GSTR-9C due date will be December 31, 2025.

Structure of GSTR-9C

Part A: Reconciliation Statement

GSTR-9C’s Part A consists of five key sections:

Basic Details

Includes:

• Financial Year
• GSTIN
• Legal/trade name
• Whether audit is applicable

Turnover Reconciliation

Compares turnover reported in:

• Audited financial statements
• GSTR-9 and other GST returns
  Any discrepancies are adjusted with explanations.

Tax Liability Reconciliation

Compares:

• Tax liability as per books
• Tax paid as per GST returns
  Differences, if any, are to be explained and reconciled.

ITC Reconciliation

Aligns ITC claimed in returns with ITC reflected in books, with explanations for differences.

Additional Liability Summary

Details any additional tax liability or interest payable due to mismatches identified during reconciliation.

Part B: Certification by CA (Now Removed)

Until FY 2019-20, a CA/Cost Accountant certification was required. Post FY 2020-21, self-certification by the taxpayer is sufficient, simplifying compliance.

Filing Process of GSTR-9C

Pre-Filing Checklist

✅ Complete the statutory financial audit (mandatory for turnover > ₹2 crore).
✅ Ensure GSTR-9 is filed, as GSTR-9C can only be initiated after that.
✅ Reconcile turnover, taxes paid, and ITC claimed with books.
✅ Gather audited Balance Sheet, Profit & Loss Account, and relevant invoices.

Step-by-Step Filing on GST Portal

1️⃣ Log in to the GST portal.
2️⃣ Navigate to Returns > Annual Return > GSTR-9C.
3️⃣ Upload reconciliation details and audited financial statements.
4️⃣ Preview the JSON file to verify accuracy.
5️⃣ Self-certify and submit the form.
6️⃣ Download the filed form for record-keeping.

⚠️ Note: GSTR-9C cannot be revised once filed, so accuracy is critical.

Practical Example: Filing GSTR-9C

For FY 2024-25:

• Turnover in audited financials: ₹6 crore.
• Turnover in GSTR-9: ₹5.9 crore.
• Discrepancy of ₹10 lakh explained as year-end invoice adjustments.
• Tax liability reconciled with minor differences, and interest on delayed payments computed and added.
• ITC reconciliation performed with matching figures.
• Filed GSTR-9 first, followed by GSTR-9C before December 31, 2025.

Common Mistakes to Avoid While Filing GSTR-9C

❌ Filing GSTR-9C before GSTR-9.
❌ Not reconciling turnover across books and returns.
❌ Ignoring small discrepancies, leading to potential audit flags.
❌ Missing the December 31 deadline, resulting in late fees.
❌ Filing without backup documents for reconciliations.

Key Compliance Tips for GSTR-9C

✅ Maintain periodic reconciliations throughout the year to reduce last-minute discrepancies.
✅ Use automated reconciliation tools to align GSTR-1, GSTR-3B, and books.
✅ Document explanations for differences between returns and books.
✅ Retain a copy of the filed GSTR-9C and supporting workpapers for audits.
✅ File well before the due date to avoid server issues on the last day.

Why Accurate GSTR-9C Filing Matters

Filing GSTR-9C accurately:

• Demonstrates the business’s commitment to compliance.
• Reduces GST audit risks by providing transparent reconciliations.
• Ensures prompt processing of GST refunds.
• Prevents unnecessary penalties and interest due to unreported discrepancies.
• Maintains credibility with GST authorities.

FAQs on GSTR-9C

Is GSTR-9C mandatory for all taxpayers?

No, it is mandatory only for GST-registered taxpayers with an aggregate PAN-level turnover exceeding ₹5 crore in a financial year.

Can I revise GSTR-9C after submission?

No, GSTR-9C cannot be revised once submitted. Ensure accuracy before filing.

What documents are needed for GSTR-9C?

You need audited financial statements (Balance Sheet, P&L), reconciliation workpapers, and invoices supporting reconciliations.

What if there are discrepancies in GSTR-9C?

You must explain discrepancies and pay any additional taxes or interest, if applicable, in the reconciliation.

Is CA certification required now?

No, for FY 2020-21 onwards, GSTR-9C is self-certified, and CA certification is not required.

Is GSTR-9C filed GSTIN-wise or PAN-wise?

It is filed GSTIN-wise if the aggregate PAN-level turnover exceeds ₹5 crore.

Conclusion: Streamlining Annual GST Compliance with GSTR-9C

GSTR-9C is a critical tool for businesses to ensure GST compliance and maintain transparency in reporting. By understanding its structure, deadlines, and filing process, businesses can avoid penalties and build a robust compliance culture while preparing for potential audits.

Stay ahead by preparing periodic reconciliations and using compliance tools to simplify GSTR-9C filing for your business.