GSTR 9C form filing with easy-to-understand notes

CA Krishnakumar M , Last updated: 31 August 2019
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Parts of GSTR 9C:

Part A - Reconciliation Statement ( This contains 5 Parts-From I to V)
Part B - Certificate

Part A - Reconciliation Statement

Part I- Basic Details (SI No: 1 to 4)

Financial Year(FY),GSTIN, Legal Name, Trade Name, Liability to audit under any Acts
FY means from 01.07.2017 to 31.03.2018. Turnover for this period shall be taken for threshold limit of 2 crores.

Part II- Reconciliation of Turnover in Financial Statements with GSTR 9 (SI No: 5 to 8)

SI No.5: Reconciliation of Gross Turnover

GSTR 9C form filing with easy-to-understand notes

SI No	Action	Description
5A		Turnover(including Exports) as per Financial Statements (here after referred as 'FS') Where multiple GSTIN exist on same PAN, GSTIN wise FS are required
5B	+	Unbilled revenue at the beginning of the FY Means revenue recognized in FS of earlier year, but GST is paid in current year.
5C	+	Unadjusted advances at the end of the Financial Year Advance received for supply of goods before 15.11.17 & for supply of services till 31.3.18 shall be taken, if the supply is not completed as on 31.3.18. Don't include for reconciliation; Advance received for supply of exempt goods or services Advance received for supply of goods on or after 15.11.17 Cross verify GSTR-1(including amendments in next year) with books of accounts
5D	+	Deemed Supply under Schedule I Fixed assets sold/taken by proprietor/Partner where ITC was availed. Higher of tax on transaction value or unexpired ITC(Asset life: 5 years) shall be paid Gift value>50,000 in a FY given to employee is considered as supply Transactions between principal & agent Import of service from a related person/establishment outside India
5E	-	Credit Notes issued after the end of the financial year but reflected in the annual return May occur due to some error, mostly will be Nil.
5F	+	Trade Discounts accounted for in the audited FS, but are not permissible under GST If the sales are shown net of discount in the FS, the discounts not allowed u/s.15(3) shall be declared here Eg: Special discount, rebate, bonus discount.etc which are not established in terms of an agreement before the supply and not specifically linked to invoices.
5G	-	Turnover from April 2017 to June 2017
5H	-	Unbilled revenue at the end of Financial Year
5I	-	Unadjusted Advances at the beginning of the Financial Year Relevant only from next year onwards
5J	+	Credit notes accounted for in the audited FS but are not permissible under GST Similar to 5F
5K	-	Adjustments on account of supply of goods by SEZ units to DTA Units Will be reflected in FS of SEZ unit as sales, but not considered as supply under GST(IGST levied on Bill of Entry and not reported in GSTR-1)
5L	-	Turnover for the period under composition scheme See GSTR-4 & GSTR-9A
5M	+/-	Adjustments in turnover under section 15 and rules there under Any tax other than GST/Compensation Cess collected in the invoices Eg: Entertainment Tax Alternate rates of tax Eg: In case of Air travel agent, value is deemed as 5% or 18% of ticket price, but actual commission may be different.
5N	+/-	Adjustments in turnover due to foreign exchange fluctuations If the forex rate used in books and GST Returns are different, the effect of the same may be disclosed here. Forex gains/losses shown as a separate line item in the P&L shall not be considered here, because the reconciliation is done with Turnover as per P&L
5O	+/-	Adjustments in turnover due to reasons not listed above Eg: Turnover for period in which there was no registration Incentive received from supplier and considered as supply under GST
	Sum 5A :5O	Annual turnover after adjustments as above This turnover ideally should match with GSTR-9.If there's any difference, the same should be reconciled and the reasons shall be mentioned in SI No-6
5Q		Turnover in GSTR-9 May be derived from SI No-5N,10 & 11 of GSTR-9
5R	5Q-5P	Un-Reconciled Turnover Differences shall be shown under SI No.6(Part II) and SI No.11(Part III)

SI No.6: Reasons for un - Reconciled difference in Annual Gross Turnover

Due to non reporting in GSTR-9

SI No.7: Reconciliation of Taxable Turnover

SI No	Description
7A	Annual turnover after adjustments (from 5P above)
7B	Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover Shall be reported net of Dr/Cr Notes & amendments Can be derived from 5D,5E & 5F of GSTR-9 Also consider 5H,5I (Dr/Cr Notes) and 5J & 5K(amendments) of GSTR-9
7C	Zero rated supplies without payment of tax Can be derived from 5A & 5B of GSTR-9 and amendments in 5J & 5K of GSTR-9
7D	Supplies on which tax is to be paid by the recipient on reverse charge basis
7E	Taxable turnover as per adjustments above (A-B-C-D)
7F	Taxable turnover as per liability declared in Annual Return (GSTR9) Refer Table(4N-4G)+(10-11) in GSTR-9
7G	Un-reconciled taxable turnover (F-E)

SI No.8: Reasons for un - Reconciled difference in taxable turnover

Reasons under SI No-6 may repeat here(non reporting in GSTR-9) or reasons such as wrong treatment of exempt supply as taxable supply may be reported

Part III- Reconciliation of tax paid (SI No: 9 to 11)

SI No.9: Reconciliation of rate wise liability and amount payable thereon

SI No	Description
9A-9O	Taxable turnover as per SI.No-7E shall be bifurcated according to applicable rates Forward & Reverse charge to be shown separately Interest, late fee, penalty also to be disclosed
9P	Total amount to be paid = Sum(9A:9O)
9Q	Total amount paid as declared in Annual Return (Refer Table 9 & 14 of GSTR 9)
9R	Un-reconciled payment of amount =9Q-9P

SI No.10: Reasons for un-reconciled payment of amount

This may occur due to;

Non consideration of sales in GST Returns
Short /Excess payment of tax

SI No.11: Additional amount payable but not paid

Due to reasons specified in SI No.6, 8 and 10

Part IV- Reconciliation of Input Tax Credit (ITC) (SI No: 12 to 16)

SI No.12: Reconciliation of Net ITC

SI No	Action	Description
12A		ITC availed as per audited FS(Net of reversals)
12B	+	ITC booked in earlier FY claimed in current FY Since this is 1st year, this column would be ideally zero. Next year onwards, this column would be bearing the same amount of column 12C of Previous FY
12C	-	ITC booked in current FY to be claimed in subsequent FY ITC of 2017-18,claimed in GSTR-3B for 2018-19 Value should be equal to sum of amounts reported in clause 12&13 of GSTR-9
12D		ITC availed as per audited FS =Sum(12A:12C)
12E		ITC claimed in Annual Return (Table 7J of GSTR9)
12F		Un-reconciled ITC= 12E-12D

SI No.13: Reasons for un-reconciled difference in ITC

Due to excess ITC claim
Non reversal of ITC
ITC booked but not availed(lapsed)

SI No.14: Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account

Column 14A to 14Q requires to disclose;
- Amount of expense
- Total ITC
- Amount of eligible ITC availed
Column 14R : Total amount of eligible ITC availed=Sum(14A:14Q)
- 14R must be equal to 12A(Since both are as per FS/books)
Column 14S : ITC Claimed in Annual return= Table 7J of GSTR-9
Column 14T : Un-reconciled ITC= 14S-14R

SI No.15: Reasons for un-reconciled difference in ITC

May be due to;

Reasons specified in SI No.13
Ineligible ITC availed
ITC of 2017-18 availed in GSTR-3B of 2018-19(Column 13 of GSTR-9)
ITC of 2017-18 reversed in GSTR-3B of 2018-19(Column 12 of GSTR-9)

SI No.16: Tax payable on un-reconciled difference in ITC (Due to reasons in column 13 &15)

Part V- Auditor's recommendation on additional tax liability due to non-reconciliation

Tax may be payable due to non-reconciliation of either turnover or ITC(Columns T11 & T16)
Rate wise breakup required
For ITC there is separate column
This is auditor's recommendation only, not legally binding on the taxpayer
The department will use this as a tool for their assessment purpose

Part B - Certification

Maintenance/non-maintenance of books of accounts as required by Act/ rules /notifications
Agreement of books of accounts with balance sheet, profit and loss and cash flow statement
Obtained necessary information and explanation
Documents prescribed u/s 35(5) and Reconciliation u/s 44(2) in Form 9C have been annexed
Particulars given in Form No.GSTR-9C are true and correct
Qualifications /observations

The author can be reached at cakrishnakumarm@gmail.com