All about Form GSTR-9C

Neethi V. Kannanth , Last updated: 07 July 2022
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Who is required to file form GSTR-9C?

Earlier, every registered person whose aggregate turnover during a financial exceeds Rs. 2 crore was required to get his accounts audited as specified under section 35 (5) of the CGST Act and was required to furnish a copy of audited annual accounts and a reconciliation statement, duly certified from GSTR-9C.

However, with the amendment notified on 31 July 2021, every registered person whose turnover exceeds Rs. 5 crore in the previous financial year is required to file form GSTR 9C on self certification basis. This amendment is applicable from F.Y. 2020-21 onwards.

What is Form GSTR-9C?

Form GSTR 9C is a reconciliation statement between:

Annual Returns in GSTR-9 filed for the financial year and
The figures as per the annual financial statements of the taxpayer.

If any difference is arising from the reconciliation will be reported in this form along with the reasons for such difference. The certified statement shall be issued for every GSTIN and therefore, there can be multiple forms GSTR-9C for a single PAN.

What is the due date for filing Form GSTR-9C?

Form GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant Financial year under audit. The due date may be extended by the Government by way of notification if it deems it to be necessary for it to do so.

What are the contents of form GSTR-9C?

Form GSTR-9C contains a reconciliation statement which is further divided into 5 parts:

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

Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9): This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that most often, the Audited Financial statements are at a PAN level. This might require the break up of the audited financial statements at GSTIN level for reporting in GSTR-9C.

Part-III: Reconciliation of tax paid: 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. Further, it requires the taxpayers to state the additional liability due to unreconciled differences noticed upon reconciliation.

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

Part-V: Auditor’s recommendation on additional Liability due to non-reconciliation: 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

Lastly, the instructions to the format of GSTR-9C specifies that an option will be given to taxpayers to settle taxes as recommended by the auditor at the end of the reconciliation statement.

Summarised table of changes to Form GSTR-9C (Changes applicable for FY 2020-21 and onwards)

Reference to part and/or table no.	Particulars	Changes made
Part-II – Tables 5B to 5N	Reconciliation of the annual turnover as per the audited annual financial statement with the turnover as declared in Form GSTR-9	These tables are optional while filing GSTR-9C for FY 2020-21. If there are any adjustments, those can be done in Table 5O.
Part-III and Table no. 9	Reconciliation of GST rate-wise liability and the amount payable	A new row is inserted below ‘K’ -0.10% to now have ‘K-1’ for other GST rates not listed above it.
Part-III and Table no. 11	Any additional amount to be paid but not paid (on account of the reasons specified under Tables 6,8 and 10)	A new row ‘others’ is inserted below 0.10% to now have other GST rates not listed above it.
Part-IV- Tables 12B, 12C, and 14	Reconciliation of Input Tax Credit (ITC)	These tables are optional while filing GSTR-9C for FY 2020-21.
Part-V	Auditor’s recommendation on any additional Liability due to non-reconciliation	Heading changed to “Additional Liability due to non-reconciliation”A new row ‘others’ is inserted below 0.10% to now have other GST rates not listed above it.
Verification	Verification of the registered person	Replaced by the following lines:I hereby solemnly affirm and declare that the information given herein above is true and correct, and nothing has been concealed therefrom. I am uploading the self-certified reconciliation statement in Form GSTR-9C. As applicable, I am also uploading other statements, including financial statements, profit and loss account and balance sheet, etc.
Instruction -serial no. 7	Part V – Additional Liability due to non-reconciliation	The wordings of the instruction are revised to remove references to the auditor and their recommendations, as follows:Part-V consists of the additional liability to be discharged by the taxpayer due to non-reconciliation of turnover or non-reconciliation of the input tax credit. Any refund that has been mistakenly considered and paid back to the government must also be declared in this table. Lastly, any other pending demand to be settled by the taxpayer has to be declared in this Table.