A Comprehensive Guide to File GSTR-9C for FY 2022-23

Introduction:

In the dynamic landscape of Goods and Services Tax (GST) implementation in India, businesses are confronted with a myriad of compliance requirements. Among these, the filing of GSTR-9 Annual return or GSTR-9C reconciliation statement is very crucial. GSTR-9 provides a consolidated view of a taxpayer’s financial activities throughout the fiscal year as per GSTR-1 and GSTR-3B returns. However, to ensure accuracy and transparency in GST reporting, the government has introduced GSTR-9C, a reconciliation statement that acts as a crucial tool for the reconciliation of financial data submitted in GSTR-9 with the audited financial statements. This comprehensive guide aims to demystify the complexities of GSTR-9C filing in India for the FY 2022-23. I have covered GSTR-9 filing in a separate article, to read GSTR-9 article Click here.

1. Understanding GSTR-9C, its Due date and applicability for FY 2022-23

• Relevant Provision: Sec 44 of the CGST Act read with Sub-Rule (3) of Rule 80
• GSTR-9C is a reconciliation statement between the annual return GSTR-9 and the audited financial statements of the taxpayer for the relevant financial year.
• Self-Certification: GSTR-9C is to be self- certified by taxpayer from FY 2020-21 onwards. No requirement of CA or CMA certification after amendment in Sec 35 and 44 through Notification No 29/2021-CT dated 30 July 2021.
• GSTR-9C is mandatory to be filed for FY 22-23 by taxpayers having aggregate annual turnover of FY 22-23 exceeding Rs. 5 Crore and optional for others.
• Due date for filing GSTR-9C for FY 2022-23 is 31^st Dec 2023 or the extended due date.
• Late fee : No specific provision for delayed filing of GSTR-9C. Practically, no payment of Late fee at the time of filing GSTR-9C. But department may levy general penalty under Sec 125 i.e., INR 50,000 (CGST+SGST).
• Belated GSTR-9C can be filed within three years from the due date unless extended. You cannot revise Form GSTR-9C return after filing

2. GSTR-9C – All aspects, Mandatory & Optional Tables for FY 2022-23

(Note: Before preparing GSTR-9C, download GSTR-9C Extract pdf from GST portal to refer relevant details of GSTR-9. To download this pdf, navigate to Services > Returns > Annual Return > Form GSTR-9C> “Download GSTR-9C tables derived from GSTR-9C(PDF)”)

FORM GSTR-9C, Reconciliation Statement is divided into V parts and 16 Tables and relaxations are explained below:

*Part I Basic Details (Home Page):

• TABLE NO. 1 to 4

FY, GSTIN, Legal name, Trade name and Liable to audit under any act

• • Fill Details as per GST profile

*Part II : Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9)

• TABLE NO. 5A to 5R: Reconciliation of Gross Turnover
  • Fill Turnover as per financials statements for the State/UT in Table 5A (For multi-GSTIN units under same PAN, the turnover shall as be derived from the Audited Annual Financial Statements. For example, if there are 2 branches in different states, then mention turnover of single state here because for another state separate GSTR-9C to be filed. It is applicable for all figures derived from financial statements)
  • Mention adjustments in Table 5B to 5O
  • Fill in Table 5Q: Turnover declared in Annual Return (GSTR9 Table 5N)

Note : Table 5B – Turnover reconciliation – Unbilled Revenue at the start of the year can be integrated and disclosed in Table 5O. Other Turnover reconciliations from Table 5C to 5N – are to be shown separately and cannot be clubbed under Table 5O. (Earlier relaxation till FY 21-22)

• TABLE NO. 6: Reasons for un-reconciled Gross Turnover
  • Give reasons in Table 6 for Unreconciled amount calculated in Table 5R
  • You can add more rows for multiple reasons

• TABLE NO. 7A to 7G: Reconciliation of Taxable Turnover
  • Table 7A auto-fetched from table 5P
  • Fill Exempted, Nil rated and Zero rated turnover as per financial statements in Table 7B and 7C
  • In Table 7D, show Outward supplies made by you on which RCM is applicable
  • Fill in Table 7F: Taxable Turnover declared in Annual Return (GSTR9 Table 4N-4G)

• TABLE NO. 8: Reasons for un-reconciled Taxable Turnover
  • Give reasons in Table 8 for Unreconciled amount calculated in Table 7G

*Part III : Reconciliation of Tax Paid

• TABLE NO. 9A to 9R: Reconciliation of rate wise liability and amount payable thereon
  • Fill Rate Wise Taxable Turnover (Including Inward Supplies on which RCM is applicable) and corresponding tax payable in Table 9A to 9K1.
  • Fill in Table 9Q: Total amount paid as declared in Annual Return (GSTR 9 Table 9A, B & C)

(Note in this table, separate row given 9L to 9O of GSTR-9C for Interest, late fee and others but practically we do not have to fill this table to avoid unnecessary difference because in table 9Q it auto-fetched only tax payable amount from GSTR-9 even if we have already paid Interest or Late fee)

• TABLE NO. 10: Reasons for un-reconciled payment of amount
  • Give reasons in Table 10 for Unreconciled amount calculated in Table 9R

• TABLE NO. 11A to 11K: Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10)
  • Fill unreconciled Taxable Value and tax payable and Interest payable due to unreconciled amount

*Part IV : Reconciliation of Input Tax Credit (ITC)

• TABLE NO. 12A to 12F: Reconciliation of Net Input Tax Credit (ITC)

(Note: Including RCM ITC)

• • In Table 12A, Fill ITC availed as per audited Annual Financial Statement for the State/ UT (For multi-GSTIN units under same PAN this should be derived from books of accounts)
  • In Table 12B Fill ITC booked in earlier Financial Years (FY 21-22) claimed in current Financial Year (FY 22-23 till 30.11.22)

• • In Table 12C Fill ITC booked in current Financial Year (FY 22-23) to be claimed in subsequent Financial Year (FY 23-24 till 30.11.23)
  • In Table 12E Fill ITC Claimed in annual return (GSTR-9 Table 7J)

Note : Table 12B and 12C are now mandatory.

(Recent update: Vide notification no. 18/2022- CT dated 28.09.2022, w.e.f. 01.10.2022, amended Sec 16(4) of CGST Act and extended the time period for availment of ITC pertaining to a Financial year upto 30th day of November of the following financial year or furnishing of GSTR-9 whichever is earlier. (Applicable from FY 21-22 onwards)

• TABLE NO. 13: Reasons for un-reconciled difference in ITC
  • Give reasons in Table 13 for Unreconciled difference calculated in Table 12F

• TABLE NO. 14A to 14T: Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account
  • This table is OPTIONAL to fill the expense-wise Input tax credit claim information

• TABLE NO. 15: Reasons for un-reconciled difference in ITC
  • Give reasons in Table 15 for Unreconciled difference calculated in Table 14T

• TABLE NO. 16: Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)
  • Fill tax payable and Interest Details and Pay amount through DRC-03 challan

*Part V : Additional liability due to non-reconciliation

• Table S. NO. A to O
  • Fill additional liability amount due to unreconciled Turnover, unreconciled Taxes paid, Erroneous refund and outstanding Demand etc.

3. Prerequisites to prepare GSTR-9C

i. GSTR-9 and all GSTR-1 and GSTR-3B returns should have been filed of FY 22-23 before preparing GSTR-9C.

ii. After filing GSTR-9, Navigate to Services > Returns > Annual Return > Form GSTR-9C> > Download GSTR-9C tables derived from GSTR-9C (PDF). This is only for reference for preparing the reconciliation statements (GSTR-9C)

iii. To fill GSTR-9C, first Prepare reconciliation charts in excel or any software of GSTR9 vs Financial statements for Turnover, Output tax paid and ITC available and claimed during the year.

4. Steps to prepare and file GSTR-9C return (Offline Tool)

Note : GSTR-9C shall be filed online but to be prepared through Offline Tool.

1. Navigate to GST Portal> Downloads> Offline Tools> GSTR-9C Offline Tool> Click on Blue Colour Download Button> Proceed> Zip file will be downloaded

2. Now go to Download section of your systems and Extract The ZIP folder

3. Open the excel file inside the folder

4. Click on Enable editing and carefully read the instructions

5. Now fill all the tables one by one as discussed above in S. No. 2 of this article

6. Don’t forget to validate each Sheet after filling details, if it shows any “Sheet validation error” then resolve it as per error instructions

7. After filling all GSTR-9C tables, Go to Home page and click on button “Generate JSON file to upload GSTR-9C details on GST portal” and save the JSON file

8. To upload JSON file, Login taxpayer GST portal and Navigate to Services > Returns > Annual Return > Form GSTR-9C: Click on “Prepare Offline” Tab and click on ‘Upload’ tab and select JSON file to upload it.

9. It will take 2 minutes to process the JSON file. If it shows “Processed with error” then you need to Download Error report and import in the GSTR-9C Offline tool to check and resolve the error and follow same steps again to generate valid JSON file.

10. If it gets processed without any error, then move forward to next step.

11. Click on “Initiate filing” button and upload Audited Balance Sheet and Profit and Loss account and Click on save button.

12. Then click ‘Preview Draft GSTR-9C PDF’ button to review the details entered.

13. Now Click on declaration box and “Proceed to File” and select authorized signatory details from the drop-down list.

14. You can file Form GSTR-9C using DSC or EVC of Authorized Signatory.

15. ARN is generated on successful filing of Form GSTR-9C.

16. Filed form GSTR-9C will be available for view/download in PDF and Excel format.

Conclusion: In conclusion, the accurate compliance of GSTR-9C emerges as a linchpin in the landscape of Goods and Services Tax (GST) obligations in India. This reconciliation statement serves as a critical bridge between the annual return (GSTR-9) and audited financial statements, ensuring that the financial data submitted aligns seamlessly and transparently. When comparing the data shown in GSTR 9/9C Vs GSTR 3B, the council has initiated issuing the notices and has urged for the data. So, it is very important to submit accurate figures in this return. I hope this article has provided a comprehensive understanding of GSTR-9C and will facilitate you to file your return with ease.

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DISCLAIMER: This publication is merely a general guide meant for knowledge purposes only. All the references or content are for educational purposes only and do not constitute a legal advice. We do not accept any liabilities whatsoever for any losses caused directly or indirectly by the use/reliance of any information or conclusion contained in this publication. Prior to acting upon this publication, you’re suggested to seek the advice.