GSTR 9C Reconciliation Statement- A Detailed Analysis

GSTR 9C-Reconciliation Statement under Goods and Services Tax- A Detailed Analysis

GSTR 9C is the reconciliation statement prescribed for registered tax payer to whom the GST Audit is applicable. It is not required to be filed by such registered person whose aggregate turnover during a financial year is less than two crore rupees including all mentioned in the table for GSTR 9. Whether forcibly or voluntarily, businesses across nation now have become familiar with the provisions of the Goods and Services Tax including various amendments done on almost daily basis. Within a few months of the GST implementation there was a flood of amendment notifications and one of them concerns GST Audit and GST Returns. In this article, an attempt has been made to explore the inclusions and parts of this reconciliation statement for the ease of understanding of the readers and assesses. 

1. What is a GSTR-9 C Reconciliation Statement?

It is the reconciliation statement for  a particular Financial Year to be filed by the assesee on or before 31^st Dec. The said reconciliation statement is to be filed after getting it certified by CA’s. The said reconciliation statement is required to be filed along with GSTR 9 (Annual Returns) and the Audited Financial Statements on the GST portal or be filed through the facilitation centres.

2. What are the contents of the reconciliation statement of GSTR 9C?

In simple words this reconciliation statement i.e. GSTR 9 C reconciles the information furnished by the assesse in the GSTR 9 of a particular financial year and the information mentioned in the audited financial statements of the assesse.  In other words, one can also refer the similarity that exists between the Tax Audit Report furnished under Income Tax Act 1961 wherein also the reference of the annual audited financial statements is made.

3. Who will prepare this GSTR 9C reconciliation statement?

The GSTR 9 C is to be prepared by a Chartered Accountant or a Cost Accountant and when we are referring a CA/ CMA here , needless to say that we mean a certified Chartered Accountant/ Cost Accountant from the Institute of Chartered/ Cost Accountants of India.

4. Where GSTR 9C is to be filed?

GSTR 9C reconciliation statement is required to be filed along with GSTR 9 (Annual Returns) and the Audited Financial Statements on the GST portal or be filed through the facilitation centres.

5. Who is required to file GSTR 9C?

The reconciliation statement is required to be filed by all the tax payers who are required to get their accounts audited under GST rules and regulations. In other words we can say that all those tax payers will file this reconciliation statement whose aggregate turnover exceeds Rs. 2 crores in a particular financial year.

6. What is the Due Date to file GSTR 9C?

It is the same as applicable for GSTR 9.The last date of filing of GSTR 9 i.e. the Annual Return has been revised and finalized as 30^th June 2019 i.e. return for the period July 2017- March 2018 is 30^th June 2019. Prior this the return was required to be filed by 31^st Dec 2018  which was extended to 30^th June 2019 during 31^st GST Council Meeting held on 22^nd Dec 2018.

7. What are the details required in the GSTR-9C form?

The form GSTR 9 C consists of following 2 parts i.e.

Part A- Reconciliation Statement

Part B- The Certification Part 

8. What are the details to be reported in the Part A of GSTR 9C?

The following information is required to be reported in the part a of the form-

a. Basic details

b. Reconciliation of the turnover declared in the Annual Audited Financial Statement with the turnover declared in the Annual Return i.e. GSTR 9

c. Reconciliation of the tax paid

d. Reconciliation of the Input Tax Credit

e. Any recommendation given by the auditor on the non reconciled matters

The heads are explained as follows-

Basic details- It Consists of FY, GSTIN, Legal Name and Trade Name. The taxpayer must also mention if he is subject to audit under any other law.

Reconciliation of the turnover declared in the Annual Audited Financial Statement with the turnover declared in the Annual Return i.e. GSTR 9- This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that mostly the Audited Financial statement is at a PAN level. This might require the break up of the audited financial statement at GSTIN level for reporting in GSTR-9C.

Reconciliation of the tax paid- This section requires GST rate-wise reporting of the tax liability that arose in FY 2017-18 as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to unreconciled differences noticed upon reconciliation.

Reconciliation of the Input Tax Credit-This part consists the reconciliation of input tax credit availed and utilised by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement. Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any 

Any recommendation given by the auditor on the non reconciled matters and liability arising any thereof- Here, the Auditor must report any tax liability identified through the reconciliation exercise and GST audit, pending for payment by the taxpayer. This can be non-reconciliation of turnover or ITC on account of :

• Amount paid for supplies not included in the Annual Returns(GSTR-9)
• Erroneous Refund to be paid back
• Other Outstanding demands to be settled

9. What are the details to be reported in the Part B of GSTR 9 C?

The following form of information related to the certification is required to be reported in the part b of the form. Under this certification, there can be two different scenarios i.e

• Certification done by the person who has conducted GST Audit of the tax payer
• Certification done by the person who has not conducted GST Audit of the tax payer.

10. Offline Utility released by the Government in the excel form

The Government has recently released the offline utility in the excel form for filing GSTR 9 C. The download link for the same is https://tutorial.gst.gov.in/offlineutilities/returns/GSTR_9C_Offline_Utility.zip

After clicking this a zip folder will be downloaded wherein two files will be there i.e.

1. Excel form utility

2. Release Notes

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