GSTR 9C -FY 2021-22 Detailed Analysis

WHAT IS GSTR 9C?

GSTR 9 C is reconciliation statement of GSTR 9 and Financial Statements: –

-Output Turnover

-Outward Taxable value Turnover

-Outward Taxable value Turnover rate wise

-Input Credit Reconciliation

Auto Populated Tables in GSTR 9C from GSTR 9

• Table 5Q -Turnover as declared in Annual return

Derived by Form GSTR-9 under Table 5N+Table 10-Table 11

• Table 7F -Taxable turnover as per liability declared in Annual Return

Derived by Form GSTR-9 under Table 4N-Table 4G+Table 10-Table 11

• Table 9Q-Total amount of tax paid as declared in Annual Return

Derived by Form GSTR-9 under Table 9+Table 10-Table 11

• Table 12E- ITC claimed in Annual Return

Derived by Form GSTR-9 under Table 7J

Categories of Form GSTR 9 C

• Part A-Consists of General Information

GSTIN-Enter the GST Registration Number

FY-The Financial Year for which the return is filed

Legal Name-Name under which GST is registered

Trade Name- Name under which Business is being conducted

Name of Act, if you are liable to audit under any Act

Part B

• Output Turnover Value Reconciliation – Point II

Table 5- Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (GSTR9)

Table 6- Reasons for Un-Reconciled Difference in Annual Gross Turnover

Table 7- Reconciliation of Taxable Turnover

Table 8- Reasons for Un-Reconciled Difference in Taxable Turnover

• Outward Tax Liability Reconciliation – Point III

Table 9- Reconciliation of rate wise liability and amount payable thereon

Table 10- Reasons for Un-Reconciled Payment of Tax

Table 11-Additional amount payable but not paid (due to reasons specified under Table 6,8 and 10 above)

• Input Tax Credit Reconciliation- Point IV

Table 12-Reconciliation of Net Input Tax Credit

Table 13- Reasons for Un-reconciled difference in ITC

Table 14- Reversal of ITC declared in ITC availed on expenses as per audited Annual Financial Statements or books of account-Optional

Table 15- Reasons for Un-reconciled difference in ITC

Table 16-Tax Payable on un reconciled difference in ITC (due to reasons specified in 13 & 15 above)

• Tax Liability Computation- Point V

Additional Liability arising on GSTR9C Reconciliation

POINT II-Output Turnover Value Reconciliation

Table 5- Reconciliation of Total Turnover

Table 5 reconciles with the Turnover in the Financial statement with the turnover declared in GSTR 9 Annual return

5A- Turnover (including exports) as per audited financial statements for the State / UT (For multi-GSTIN units under same PAN the turnover shall be derived from the audited

In Table 5A enter turnover as declared in the financial statements while filing your income tax return

As GST Returns are state -wise and Income tax return is based on PAN basis so there might be cases where your financial statement shows consolidated turnover.

The turnover to be entered in Table 5A is the turnover derived from the particular state where the GSTIN is registered for and not the consolidated turnover

From Sub headings 5B TO 5O are reconciliation GST adjustments categories to derive Audited turnover to GST Act based Turnover

(+) 5B- Unbilled revenue at the beginning of Financial Year

Incase of ongoing projects accounting standards requires to recognise income on the basis of percentage of work completion method on contract value or on accrual basis

In GST, Revenue is recognised on time of supply basis

E.g.: – Accrual Income booked in March 21 and Invoices are raised in FY 21-22

The income is already booked in FY 20-21 thus will not appear in Financial statement of FY 21-22

But in GST, the invoices raised in April 22 related to such Accrual Income of March 21 are shown in GSTR 1 and Output Tax is paid in GSTR 3B which is reflected in the Output turnover of GSTR 9 FY 21-22. Such invoice Output value has to be disclosed under Table 5B

Thus FY 21-22 Turnover in Financial statement is less to the extent of such revenue since it was disclosed in the previous year so this revenue is now added in Table 5B to reconcile with GSTR 9 Turnover shown in Table 5Q

(+) 5C- Unadjusted advances at the end of the Financial Year

In GST, Advances received for services are to be shown as Outward taxable supply and GST is to be paid on it. Whereas as per Income tax Act and accounting standards only receipt of advances does not qualify for Revenue recognition.

Thus, in Table no 5C all the Advances against services recognised in GST for which invoices has not been raised till the end of the financial year has to be disclosed here.

This Advance revenue disclosed under Table 5C is not in Financial statement therefore is to be added to the Turnover disclosed in Table 5A to reconcile with Turnover of GSTR 9C shown in Table 5Q.

(+) 5D- Deemed Supply under Schedule I

Under GST there are certain supplies recognised as Deemed Supply under Schedule I for which no consideration is received.

E.g., Supply of goods or services or both between branches within the same state when made in the course or furtherance of business is recognised as GST Supply. Such supplies are not considered as Revenue under Income Tax Act.

So, supplies which are not accounted as revenue in the Financial statements but recognised as Deemed supply in GSTR 9 under Table 4E to be shown here under Table 5D

These Deemed supply in Table 5D is not in the Financial statement thus is added to the Turnover disclosed in Table 5A to reconcile with Turnover of GSTR 9C shown in Table 5Q

(-)5E- Credit Notes issued after the end of the financial year but reflected in the annual return

If there are certain credit notes raised in April 2022 related to March 2022 but instead of reflecting in GSTR 1 of  April 22 shown in March 22 and so now  shown in GSTR 9 FY 2021-22.

In the Financial statements of FY 2021-22 the revenue will be higher to the extent of such credit notes as these credit notes will be reflected in FY 22-23 Financial Statement.

Hence such credit notes reflected in GSTR 9 will be disclosed under Table 5E which will be deducted from Table 5A to reconciled with the Turnover disclosed in GSTR 9 shown in Table 5Q

(+)5F- Trade Discounts accounted for in the audited Annual Financial Statement but are not permissible under GST

Under GST Act for discount to be permissible as deduction conditions have to be met according to Sec 15(3)

As per Sec 15(3) of CGST Act, the value of the supply shall not include any discount which is given—

(a) before or at the time of the supply if such discount has been duly recorded in the invoice issued in respect of such supply; and

(b) after the supply has been effected, if—

(i) such discount is established in terms of an agreement entered into at or before the time of such supply and specifically linked to relevant invoices; and

(ii) input tax credit as is attributable to the discount not on the basis of document issued by the supplier has been reversed by the recipient of the supply.

In Income tax there is no such conditions required for a Discount to be reduced from Supply

Since these non-permissible discounts under GST are already deducted in Turnover value as per Financial Statement mentioned in Table 5A, these non-permissible discounts under GST accounted in Financial Statements are to be disclosed under Table 5F which is added to Table 5A turnover to reconcile with Table 5Q GSTR 9 Turnover.

(-)5G- Turnover from April 2017 to June 2017

This was relevant for FY 2017-18 since GST became applicable from July 2017.

So, this Table is as such disabled for FY 2021-22.

(-) 5H- Unbilled revenue at the end of Financial Year

Similar to Table 5B only this is related to the March 2022 income adjustment entry accounted in Financial Statements.

For revenue recognition as per Accounting Standards, Revenue is recognised in March 22 for which invoices will be raised in FY 22-23. Hence currently as per GST Provisions in GST Returns of FY 21-22 this revenue is not admitted in the returns. It will be disclosed in the GSTR 9 of FY 22-23

This Accrual income recognised in the Financial statement has to be reflected under Table 5 H reducing the Table 5A Financial statement turnover to reconcile with Table 5Q GSTR 9 Turnover

There is no need to enter negative value, the GSTR 9C auto subtracts the value entered in Table 5H.

(-) 5I Unadjusted Advances at the beginning of the Financial Year

Similar to Table 5C, the invoices must have been raised in FY 21-22 for advances received for services in March 21

In Financial Statements revenue is recognised in FY 21-22 but in GST Returns revenue was already recognised in FY 20-21 when advance for services was received in March 21

Thus, in Table no 5 I all the Advances against services recognised in GST Returns for FY 20-21 for which revenue has been accounted in the Financial statement for FY 21-22 such Output value has to be disclosed here.

Since this revenue appearing in 5I is not in Turnover of GSTR 9 Table 5Q it will be reduced from Table 5A Financial statement turnover to reconcile with Table 5Q GSTR 9 Turnover

No need to enter negative value, the GSTR 9C auto subtracts the value entered in Table 5I.

(+) 5J- Credit notes accounted for in the audited Annual Financial Statement but are not permissible under GST

Under GST Credit notes for a particular FY has to be issued within 180 days from the end of the financial year after which it is not eligible but there is no such rule under Income Tax

So, such credit notes accounted in Financial statements of FY 2021-22 not reflected in GST Returns of FY 21-22 due to ineligibility will be reflected under Table 5J.

The value disclosed in Table 5J will be added to Table 5A Financial statement turnover to reconcile with Table 5Q GSTR 9 Turnover as such ineligible GST credit notes has not been reduced from GSTR 9

(-) 5K Adjustments on account of supply of goods by SEZ units to DTA Units

As per Sec 30 of SEZ Act

Any goods removed from a Special Economic Zone to the Domestic Tariff Area shall be chargeable to duties of customs including anti-dumping, countervailing and safeguard duties under the Customs Tariff Act, 1975

As per GST Instructions instruction no. 9 of Form GSTR-1 – Any supply made by SEZ to DTA, without the cover of a bill of entry is required to be reported by SEZ unit in GSTR-1. The supplies made by SEZ on cover of a bill of entry shall be reported by DTA unit in its GSTR-2 as imports in GSTR-2. The liability for payment of IGST in respect of supply of services would, be created from this Table.

Thus, those supply of goods by SEZ unit to DTA which are received under the cover of the bill of entry are not disclosed in GSTR 1 and GSTR 3B and accordingly does not reflect in GSTR 9 are to be reported under this Table 5K

Hence the above-mentioned supplies are accounted in the financial statement as revenue but not reflected in the GSTR 9

The value disclosed in Table 5K will be reduced to Table 5A Financial statement turnover to reconcile with Table 5Q GSTR 9 Turnover as such SEZ Supplies are not reported in GSTR 9.

There is no need to enter negative value to the Output value the GSTR 9C auto subtracts the value entered in Table 5K.

(-) 5L- Turnover for the period under composition scheme

If during the FY 21-22 the registered person was under Composition scheme and then shifted to Regular scheme.  GSTR 9 does not include turnover under composition scheme whereas the Financial statement will reflect turnover for the whole year including the turnover under composition scheme

In Table 5L turnover under composition scheme is to be reflected. This turnover in Table 5L is reduced from Table 5A Financial statement turnover to reconcile with Table 5Q GSTR 9 Turnover

There is no need to enter negative value to the Output value the GSTR 9C auto subtracts the value entered in Table 5L.

5M -Adjustments in turnover under section 15 and rules thereunder

Value of supply under GST has to be in accordance with Sec 15. In our GST Returns the supply will be recorded as per Sec 15 whereas in the Financial Statements the revenue is booked as per the applicable Accounting Standards

Variation in valuation of Turnover due to Sec15 and Accounting Standards are to be reflected in Table 5M.

If the value of Turnover in Financial statement is higher than the value of Supply in GST due to valuations then the amount shown in Table 5M has to be reflected as negative amount and if value of Turnover in Financial statement is less than the value of Supply in GST due to valuations then the amount shown in Table 5M has to be reflected as positive amount.

5 N- Adjustments in turnover due to foreign exchange fluctuations

In the Financial Statements foreign exchange gain/loss is accounted for and adjusted in the Turnover. There are no such adjustments done in GST Returns

Variation in Turnover of Financial Statement and GSTR 9 due to foreign exchange fluctuations has to be reflected in Table 5N

If the value of Turnover in Financial statement is higher than the value of Supply in GST due to foreign exchange fluctuations then the amount shown in Table 5N has to be reflected as negative amount and if value of Turnover in Financial statement is less than the value of Supply in GST due to foreign exchange fluctuations then the amount shown in Table 5N has to be reflected as positive amount.

5O -Adjustments in turnover due to reasons not listed above

If adjustments in Turnover of Financial Statement and GSTR 9 is due to reasons other than stated above Table 5B to 5N then the adjustment amount should be reflected in Table 5 O

If such adjustment causes the value of Turnover in Financial statement is higher than the value of Supply in GST the amount shown in Table 5 O has to be reflected as negative amount and if value of Turnover in Financial statement is less than the value of Supply in GST after such adjustment the amount shown in Table 5 O has to be reflected as positive amount.

5P- Annual turnover after adjustments as above

This is auto populated by doing the adjustments against Table 5A from Table 5B to Table 5 O

Table 5 P reflects GST adjustments to Turnover of Financial Statement

5Q- Turnover as declared in Annual Return (GSTR9)

This is auto populated from GSTR 9. This is derived by adding Table 5N, Table 10 and reducing Table 11 of GSTR 9

5R- Un-Reconciled turnover (Q – P)

This is auto populated by taking difference of Table 5Q and Table 5P

Ideally there should be no difference. If variation is in negative amount, it means that Output turnover value was under reported in the GSTR 9 return and if variation is in positive amount, it means that Output turnover value was under reported in the Income tax return.

Table 6- Reasons for Un – Reconciled difference in Annual Gross Turnover

Detailed explanation has to be given for the un reconciled turnover in Table 5R.

Table 7- Reconciliation of Taxable Turnover

Table 7 is reconciliation of Outward taxable Turnover reflected in GSTR 9 as compared to Taxable Turnover appearing in Financial Statement.

To arrive at Taxable Turnover appearing in Financial Statement, the Turnover appearing after GST reconciliation adjustments in Table 5P is taken as the base. This GST adjusted Financial Turnover includes non -taxable turnover. So, to arrive at Taxable turnover as per Financial statement the below Table 7B to 7D are reduced from Turnover reflected in Table 7A.

The values entered in Table 7B to 7D should be net of credit/debit notes or adjustments if any.

If net of credit/debit notes or adjustments if any results in positive amount in Table 7B to 7D then it is auto subtracted in Table 7E.

If net of credit/debit notes or adjustments if any results in negative amount in Table 7B to 7D then it is added in Table 7E.

7A- Annual turnover after adjustments (from 5P above)

Auto populated from Table 5P

(-)7B- Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover

If the below listed supplies are included in your Turnover in the financial statement, then such supplies are to be reflected under Table 7B

• Exempt Supply-If any supply of goods /services that attracts nil rate of supply or are wholly exempt from GST or non-taxable supply. This category includes mostly like essential commodities e.g., Milk, bread, fruits, etc.
• Nil Rated Supplies-Supplies that are currently taxed at 0% rate E.g.-Salt
• Non-GST Supplies-Supplies that do not attract taxes under GST Act but are taxable under other Acts. E.g. – Alcoholic liquor for human consumption, specified petroleum products like (a) petroleum crude, (b) high speed diesel, (c) motor spirit (commonly known as petrol), (d) natural gases and (e) aviation turbine fuel
• No Supply- Activities or transaction which are neither supply of goods nor supply of service as mentioned in Section 7(2) of CGST Act i.e., Activities or transactions specified in Sch III or such activities or transactions undertaken by the Government or any local authority in which they are engaged as public authorities, as may be notified by the Government.

While calculating the amounts with net of credit/debit notes or adjustments if any the Gross amounts accounted for should match GSTR 9- Table 5D,5E,5F.

7C- Zero rated supplies without payment of tax

Supplies made during FY 21-22 as –

• Exports of goods or services or both,
• Supply of goods or services or both to a Special Economic Zone developer or a Special Economic Zone unit

On which no GST Tax are paid are to be reported under Table 7C.

While calculating the amounts with net of credit/debit notes or adjustments if any the Gross amounts accounted for should match with GSTR 9- Table 5A,5B

7D- Supplies on which tax is to be paid by the recipient on reverse charge basis

Outward Supplies made during FY 2021-22 for which GST Tax was to be paid by recipient

Such supplies are to be reported under Table 7D.

While calculating the amounts with net of credit/debit notes or adjustments if any the Gross amounts accounted for should match with GSTR 9- Table 5C

7E- Taxable turnover as per adjustments above (A-B-C-D)

Here the Turnover is auto populated. This is derived by the difference between the annual turnover after adjustments declared in Table 7A above and the sum of all supplies under Table 7B to Table 7D reflects the Taxable GST Turnover as per the Financial statement.

7F- Taxable turnover as per liability declared in Annual Return (GSTR9)

Taxable turnover as declared in Table (4N – 4G) + (10-11) of the Annual Return (GSTR9) is auto populated here.

7G- Unreconciled taxable turnover (F-E)

This auto populates difference arising between Taxable Turnover in GSTR 9 derived under Table F with Taxable Turnover in Financial statement derived under Table E.

Ideally there should be no difference. If variation is in negative amount, it means that Output Taxable turnover value was under reported in the GSTR 9 return and if variation is in positive amount, it means that Output Taxable turnover value was under reported in the Income tax return.

Table 8- Reasons for Un – Reconciled difference in taxable turnover

Detailed explanation has to be given for the un reconciled turnover in Table 7G.

Outward Tax Liability Reconciliation-Point III

Table 9- Reconciliation of rate wise liability and amount payable thereon

The Outward GST Tax payable and Taxable GST Turnover accounted in the Financial statements should be reflected in Table 9 rate wise

Rate wise Outward supply turnover Tax liability accounted in Financial Statement has to be declared-

Table 9A – Outward supply turnover attracting tax liability @ 5%

Table 9C – Outward supply turnover attracting tax liability @ 12%

Table 9E – Outward supply turnover attracting tax liability @ 18%

Table 9G- Outward supply turnover attracting tax liability @ 28%

Table 9I- Outward supply turnover attracting tax liability @ 3%

Table 9J- Outward supply turnover attracting tax liability @ 0.25%

Table 9K- Outward supply turnover attracting tax liability @ 0.10%

Table 9K1- Outward supply turnover attracting tax liability other than tax rates mentioned above

Rate wise Inward supply turnover attracting tax to the recipient and the Tax liability accounted and paid in the Financial Statement has to be declared under

Table 9B – Inward supply turnover attracting reverse charge tax liability @ 5%

Table 9D – Inward supply turnover attracting reverse charge tax liability @ 12%

Table 9F- Inward supply turnover attracting reverse charge tax liability @ 18%

Table 9H- Inward supply turnover attracting reverse charge tax liability @ 28%

Apart from Output tax liability there might be other GST Liabilities accounted for such as: –

Table 9L- Interest

GST Interest accounted for in the financial statement has to be shown under this table

Table 9M- Late fee

GST Late fees accounted for in the financial statement has to be shown under this table

Table 9N-Penalty

GST Penalty accounted for in the financial statement has to be shown under this table

Table 9O-Others

GST liabilities other than above Table 9A to Table 9N that is accounted for in the financial statement has to be shown under this table

Table 9P- Total amount to be paid as per tables above

The total amount accounted in the Financial Statement to be paid as GST liability is declared here. This is auto-populated by summation of Table 9A to 9O

Table 9Q- Total amount paid as declared in Annual Return (GSTR 9)

Tax Liability admitted and paid in Table 9+ Table 10- Table 11 of the Annual Return (GSTR9) is auto populated here.

Table 9R- Unreconciled payment (Q-P)

This auto populates difference arising between Tax Liability in GSTR 9 derived under Table 9Q with Tax Liability in Financial statement derived under Table 9P.

Ideally there should be no difference. If variation is in negative amount, it means that Output Tax Liability was under reported in the GSTR 9 return and if variation is in positive amount, it means that GST Tax Liability was under reported in the Income tax return.

Table 10- Reasons for un-reconciled payment of amount

Detailed explanation has to be given for the un reconciled turnover in Table 9R.

Table 11- Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10 above)

The Additional Liability arising due to under reporting of Tax Liability and Output Turnover appearing in Table 6,8 and 10 have to reported here and taxes to be paid by filing DRC-03 

Reconciliation of Input Tax Credit (ITC)-Point IV

Table 12 Reconciliation of Net Input Tax Credit (ITC)

Under Table 12 Eligible Input tax credit accounted for and availed in Financial Statements are reconciled with the Input credit availed in GSTR 9

12A- 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)

Enter the Input credit accounted in the Financial statements related to the GSTIN of the state for FY 21-22 that reflected in GSTR 2B and are eligible to claim credit under GST Act.

12B-ITC booked in earlier Financial Years claimed in current Financial Year

Eligible input tax credit accounted in FY 20-21 but claimed in GST Returns during the period April 21 to Nov 21. Such Input tax credit has to be reflected in this Table 12 B

12 C- ITC booked in current Financial Year to be claimed in subsequent Financial Years

Eligible input tax credit accounted in FY 21-22 but claimed in GST Returns during the period April 22 to Nov 22. Such Input tax credit has to be reflected in this Table 12 C

12 D-ITC availed as per audited financial statements or books of account (A+B-C)

ITC availed in GST for FY 2021-22 which are accounted in Financial Statement. This is auto populated by adding Table 12B and reducing Table 12 C to Table 12A.

12E-ITC claimed in Annual Return (GSTR9)

This is auto populated from GSTR 9 Table 7 J.

12F-Un-reconciled ITC (E-D)

This auto populates difference arising between Input tax Credit availed in GSTR 9 derived under Table 12E with Input tax Credit availed in Financial statement derived under Table 12D.

Ideally there should be no difference. If variation is in positive, it means that excess Input tax credit was availed in the GSTR 9 return and if variation is negative, it means less of Input tax credit was availed in GSTR 9

Table 13-Reasons for un-reconciled difference in ITC

Detailed explanation has to be given for the un reconciled turnover in Table 12F.

Table 14-Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account-Optional

Under this Table all the expenses accounted in the Financial Statement related to the GSTIN of the state whether revenue or capital expenditure has to reported here under the relevant expense heading in Table 14 A to Table 14 Q. The Input tax credit availed corresponding to these expenses that are reflected in GSTR 2B and are eligible to claim credit under GST are also required to be reported in Table 14

Table 14 R -Total amount of eligible ITC availed

Auto summary of Table 14 A to Table 14Q

Table 14 S- ITC claimed in Annual Return (GSTR9)

This is auto populated from GSTR 9 Table 7 J.

Table 15-Reasons for un -reconciled difference in ITC

Detailed explanation has to be given for the un reconciled turnover in Table 14 S.

Table 16-Tax payable on un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)

The Additional Liability arising due to excess credit claimed in Table 13 and 15 have to be reported here and taxes to be paid by filing DRC-03

Point V-Additional Liability due to non-reconciliation

Under this category the additional liabilities declared in Table 11 and Table 16 has to be admitted here and liabilities that was paid but not included in Annual Return. Payment to be done by filing DRC-03

Point V A to Point VG1 -Rate wise additional Outward tax liability to be admitted here

Point VH-Additional Liability due Input tax credit excess availed

Point V I- Interest on Additional Output tax Liability and Input Tax credit

Point V J-Late Fees arising on GST Returns not paid yet

Point V K-Penalty charged on not yet paid

Point V L- Any other amount paid for supplies not included in Annual Return GSTR 9

Any taxes paid by filing DRC-03 but not shown in GSTR 9

Point V M- Erroneous refund to be paid back

Any GST ineligible refund received to be admitted here

Point V N- Outstanding demands to be settled

Outstanding demands not paid yet to be disclosed here

Point V O- Other (Pl. Specify)

Any other liability not disclosed in the above categories to be mentioned here

Thank you for reading

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