GSTR 9C: Applicability, Format, Due Date & Rules

GSTR-9C is a reconciliation statement between GSTR-9 and the audited books of accounts. It must be submitted by those GST registered taxpayers to whom GST audit applies as specified under sub-section (5) of section 35 of the CGST Act. GST Audit applies to those taxpayers whose aggregate turnover during the financial year exceeds Rs. 2 crores.

As per Section 2(6) of CGST Act, 2017, ‘Aggregate Turnover’ means the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess.

The turnover calculation must be PAN based. Once the PAN-based aggregate turnover exceeds Rs.2 crore, every registered GSTIN having the same PAN is required to get its accounts audited and file Form GSTR-9C. GSTR-9C should be filed for every registration in each state.

Note: GSTR-9C can only be filed after filing GSTR-9.

GSTR-9C must be prepared and certified by a Chartered Accountant or Cost Accountant. Any differences arising between the details reported in GST returns and the Audited Accounts must be reported by the auditor therein with the reasons for the same. GSTR-9C must be filed on the GST portal or through a facilitation centre by the taxpayer.

Note: The certified statement shall be issued for every GSTIN. Hence, for a PAN there can be several GSTR-9C forms to be filed.

Q1. What is the due date for GSTR-9C?

Below are the due dates for filing GSTR 9C (Reconciliation Statement) form for both financial years:

• Financial Year 2017-18 – 31st January 2020
• Financial Year 2018-19 – 31st March 2020

It may be noted that earlier the last date for filing of GSTR-9 and GSTR-9C for Financial Year 2017-18 was 30th November 2019 while that for Financial Year 2018-19 was 31st December 2019.

Q2. Can GSTR-9C be revised?

Currently, there is no provision to revise Form GSTR-9C. Hence, taxpayers are requested to take the utmost care when reporting details in Form GSTR-9C and filing the same.

Q3. Format of the GSTR-9C return?

GSTR-9C consists of two main parts:

• Part-A: Reconciliation Statement
• Part-B: Certification

Part-A: Reconciliation Statement

This is further divided into five sub-parts as follows:

Part-I: This part requires basic details such as Financial Year, GSTIN, Legal Name and Trade Name.

Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9).

Part-III: This section requires GST rate-wise reporting of the tax liability that arose as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. The taxpayer is also required to state the additional liability due to unreconciled differences noticed upon reconciliation.

Part-IV: This part consists of Reconciliation of Input Tax Credit (ITC).

Part-V: This part consists of auditor’s recommendation on the additional liability to be discharged by the taxpayer.

Part-B: Certification

There are two forms of certificate given in Part-B:

• Form-I is applicable when reconciliation statement has been drawn up by the same person who has conducted the audit.
• Form-II is applicable where reconciliation statement is not drawn up by the same person who had conducted the audit.

Example: XYZ company is required to get its accounts audited from practising Chartered Accountant under Companies Act 1956. If the reconciliation statement in Form GSTR-9C is drawn-up by the same Chartered Accountant who has audited the accounts of XYZ company under the companies act, 1956, then the auditor is required to issue the certificate in Form I.

In other cases, Form II is applicable.

Q4. Documents to be enclosed with Form GSTR-9C?

The following documents are required to be enclosed with Form GSTR-9C:

• A copy of the audited financial statements as per Section 35(5),
• A copy of the audit report where the audit of the entity is carried out by another person under a statute other than the GST Act.