GSTR-9C – Annual Reconciliation Statement

Other than the hottest ongoing political drama, the topic which is much talked about, within the trade and industry, is the annual return filing under GST. With its soon emerging final extended due date, at present being 30^th June, 2019, for filing of the first annual return under GST, most of the registered taxpayer is still trying to understand the provisions of the same.

GST Annual return, as the name itself says, is required to be filed one time every financial year. Every registered taxpayer under GST is required to file an annual return except for certain specified categories of the taxpayer.

Different formats of the annual returns are made available for the different categories of persons as listed herein below –

1. A normal taxpayer is required to file an annual return in FORM GSTR-9.

2. Composition scheme dealer is required to file an annual return in FORM GSTR-9A.

3. E-commerce operator requiring to collect TDS is required to file an annual return in FORM GSTR-9B.

4. Reconciliation statement in FORM GSTR-9C is required to be filed by a normal taxpayer who is having an aggregate turnover of more than INR 2 Crores.

The present article would help the taxpayer to understand the provisions attached with the filing of FORM GSTR-9C – Reconciliation Statement and also would help to clear up various doubts present in their mind with respect to the same.

GSTR-9C – Reconciliation Statement is basically a reconciliation between an annual return filed in FORM GSTR-9 and the audited annual financial statements.

1. Who is required to file GSTR-9C – Reconciliation Statement?

The simple answer to the above question is that the registered taxable person who is required to get his accounts audited under GST is required to file a GSTR-9C – Reconciliation Statement.

Now, the next obvious question that would arise is which are the categories of a registered person who are required to get their accounts audited under GST? The answer to the said question lies within the provisions of section 35 (5) of the Central Goods and Service Tax Act, 2017 read with rule 80 (3) of the Central Goods and Service Tax Rules, 2017.

Reading together both the above provisions, it can be concluded that, every registered taxpayer whose aggregate turnover during the financial year exceeds INR 2 Crore shall get his accounts audited by a chartered accountant or a cost accountant and such person is required to furnish a copy of audited annual accounts and a reconciliation statement in FORM GSTR-9C.

It is important to understand the term ‘aggregate turnover’ which has been defined under section 2 (6) of the Central Goods and Service Tax Act, 2017. It means the aggregate value of all the taxable supplies, exempt supplies, exports of goods or services or both and inter-state supplies of persons having the same PAN. However, it excludes the value of inward supplies on which tax is payable on reverse charge and central tax, state tax, union territory tax, integrated tax and cess.

2. Due date of filing of first GSTR-9C – Reconciliation Statement

GSTR-9C – Reconciliation Statement is required to be filed on or before 31^st December following the financial year which is under audit. However, the due date for filling of the first annual return i.e. for the financial year 2017-2018 has been extended till 30^th June, 2019.

3. Requirements to file GSTR-9C – Reconciliation Statement –

Following are the list of requirements which the taxpayer needs to fulfill prior to the filing of GSTR-9C – Reconciliation Statement –

• System requirement for the filing of GSTR-9C – Reconciliation Statement is –
  • Operating System : MS Windows 7 or above;
  • Microsoft Excel 2007 and above.
• All the pending returns i.e. GSTR-1 and GSTR-3B need to be filed before filing of GSTR-9C – Reconciliation Statement.
• An annual return in FORM GSTR-9 also needs to be filed before filing of GSTR-9C – Reconciliation Statement.
• Reconcile the outward supply as per books of accounts and as per returns filed.
• Reconcile the input tax credit (ITC) as per books of accounts, returns filed and auto-populated in return GSTR-2A.
• Reconcile the tax paid / payable (CGST, SGST and IGST including reverse charge) as per books of accounts and as per returns filed.

4. Steps to file GSTR-9C – Reconciliation Statement –

GSTR-9C – Reconciliation Statement can be filed in both online or offline mode.

• Visit site https://www.gst.gov.in/.
• Click on Login icon and provide appropriate Username and Password.
• Navigate path Services > Returns > Annual Returns.
• Select the appropriate Financial Year from the drop-down list and click SEARCH.
• Under ‘Reconciliation Statement GSTR 9C’ click on ‘INITIATE FILING’ for online filing of GSTR-9C – Reconciliation Statement or click on ‘PREPARE OFFLINE’ for offline filing of GSTR-9C – Reconciliation Statement.

5. Prepare offline by Certified Auditor –

In order to prepare offline GSTR-9C – Reconciliation Statement by certified auditor following steps needs to be followed –

• Visit site https://www.gst.gov.in/.
• Navigate the path Downloads > Offline Tools > GSTR-9C Offline tools.
• Click on Excel sheet name ‘GSTR 9C_offline_Utility’.
• Under the home page provide the mandatory fields / details like GSTIN, Financial Year and Name of the Act, if you are liable to audit under any Act.
• After providing the above mandatory fields / details, one can proceed to prepare Part A and Part B of GSTR-9C – Reconciliation Statement.
• Provide appropriate details as per the various worksheets and click on ‘Validate Sheet’ in order to check the status of validation.
• After validating all the worksheets, click on ‘Generate JSON file to upload GSTR-9C details on GST portal’ to generate JSON file and sign using Digital Signature Certificate (DSC).
• The signed GSTR-9C JSON file would be provided to the taxpayer by the auditor for upload.

6. Online upload of GSTR 9C by the taxpayer –

For online upload the taxpayer needs to follow the below mentioned steps –

• Visit site https://www.gst.gov.in/.
• Click on Login icon and provide appropriate Username and Password.
• Navigate the path Services > Returns > Annual Return.
• Select appropriate Financial Year from the drop-down list and click on SEARCH.
• Under ‘Reconciliation Statement GSTR 9C’ click on Prepare Offline.
• Upload the JSON using an offline tool by clicking the upload option.
• Uploaded JSON file would be further validated and processed.
• On successful upload of data, the taxpayer can Preview the form and file the same.