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GSTR-9C: Reconciliation Statement

The development of Form GSTR-9C was motivated by the need for a mechanism to verify the accuracy of the information reported in Form GSTR-9 and to ensure compliance under GST. Form GSTR-9C requires a thorough audit, performed by a Chartered Accountant or a Cost Accountant, to reconcile the figures reported in the annual returns with the audited financial statements of the taxpayer. This process improves the overall integrity of the GST regime. 

 

Read the guide to get a closer look of each aspect of Form GSTR-9C.

GSTR-9C

Form GSTR-9C is a reconciliation statement or audit form that must be filed by the taxpayers annually whose turnover exceeds a certain threshold. This form effectively bridges the gap between a taxpayer’s financial statements and information contained in the annual return Form GSTR-9. This ensures transparency and accuracy in GST declarations.

Who should File Form GSTR-9C?

The registered taxpayer with an annual aggregate turnover of more than INR 5 Crore in a financial year should get their accounts audited. Moreover, Form GSTR-9C is to be filed on or before 31st December of the year following the relevant financial year under audit.

Eligibility and Rules for Filing Form GSTR-9C

  • Eligibility for Filing Form GSTR-9C:

    • Form GSTR-9C must be filed by taxpayers with an annual aggregate turnover of more than INR 5 Crore during the financial year.

    • Form GSTR-9C is filed alongside the annual return form, that is, GSTR-9, and is essentially a reconciliation statement between the annual returns filed and the amount as per the audited financial statements.

  • Rules for Filing Form GSTR-9C:

    • The filing of Form GSTR-9C is compulsory for taxpayers having an annual aggregate turnover of more than INR 5 Crore.

    • The form should specify the details of any discrepancies between the reported data in the returns and the audited financial statements, and also provide explanations for such discrepancies.

Format or Content of Form GSTR-9C

Form GSTR-9C serves as a mechanism for verifying the accuracy of GST returns filed throughout the entire financial year. Form GSTR-9C is divided into two sections: Part A for the reconciliation statement and Part B for the certification.

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  • Part A: Reconciliation Statement:

Part A is further divided into various sections with the purpose of capturing detailed information for reconciling the data reported in Form GSTR-9 with the audited financial statements.

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  • Basic Information: This section provides the information on the financial year, GSTIN, legal name, and trade name.

  • Reconciliation of Turnover declared in Audited Financial Statements and Turnover declared in Annual Return Form GSTR-9: This section requires the taxpayer to reconcile the turnover as per the financial statements and the turnover declared in Form GSTR-9. Also, the explanations should be provided in case of any discrepancies.

  • Reconciliation of Tax Paid: Under this a comparison is made between the tax paid as per Form GSTR-9 and the tax determined based on the audited financial statements. The breakup of each type of GST like CGST, SGST, IGST, Cess is important along with the explanation of discrepancies, if any.

  • Input Tax Credit (ITC) Reconciliation: The comparison between the ITC claimed and availed under Form GSTR-9 must be made to the ITC entitled under the financial statements. If there arises any discrepancies, the same should be explained.

  • Auditor’s Recommendation on Additional Liability because of Non-Reconciliation: If the auditor discovers any tax liabilities due to the discrepancies in reconciliation, it is reported under this section. The additional liability is categorized into tax, interest, penalty, and others.

 

  • Part B: Certification:

Part B provides information related to certification and is further divided into two options based on the whether the reconciliation statement and financial statements have been audited by the same or the different person:

  • Certification in cases where Form GSTR-9C is prepared by the same person who conducted the audit: This certificate is used when the person who conducts the audit and prepares Form GSTR-9C is the same. The declaration is to be made by the auditor certifying the accuracy of the information provided in Form GSTR-9C based on the review conducted on the books of accounts.

  • Certification in cases where Form GSTR-9C is prepared by the person other than who conducted the audit: This certificate becomes applicable when Form GSTR-9C is prepared by one person and the audit of the financial statements are conducted by another person. It includes a declaration similar to the first option, but specifies that the certification is prepared on the basis of the reconciliation statement prepared by another auditor.

 

  • Additional Aspects: 

    • Attachments: Taxpayers may need to attach additional documents or statements to support the reconciliation or provide explanations to any discrepancies.

    • Auditor’s Recommendations: Form GSTR-9C also includes detailed recommendations from the auditor with respect to additional liability identified in the reconciliation process. It acts as an integral part of Form GSTR-9C providing guidance to the taxpayers on compliance adjustments.

Steps for Filing Form GSTR-9C

Form GSTR-9C filing involves detailed steps which should be followed for a successful error-free filing. Following are the steps:

  1. Prepare All the Documents: 

    • Ensure the financial statements are audited and kept ready.

    • Form GSTR-9 should be filed prior to filing of Form GSTR-9C.

    • Create a reconciliation statement outlining the discrepancies between the financial statements and the GST returns filed throughout the year.

  2. Download the GSTR-9C Utility: 

    • Visit the GST portal at https://www.gst.gov.in/.

    • Navigate to the ‘Downloads’ section and select offline tools.

    • Download the GSTR-9C offline Utility Tool.

  3. Fill Out the Form GSTR-9C using the Offline Utility: 

    • Open GSTR-9C Utility Excel Tool.

    • Fill the required fields in the tool, including the reconciliation data and any tax liabilities discovered during the reconciliation process.

    • Validate the data provided by clicking on the ‘Validate’ button in the utility to check for errors or missing data.

    • After all the sections have been completed correctly, use the utility to generate the JSON file.

  4. Log into the GST Portal:

    • Access the GST portal and log into the same.

    • Go to ‘Services’>’Returns’>’Returns Dashboard’ and select the financial year and the return filing period for GSTR-9C.

  5. Upload the JSON file of GSTR-9C:

    • Under the title GSTR-9C, select the ‘Prepare Offline’ option.

    • To upload the JSON file generated by the offline tool, click on the ‘Upload’ button.

    • Wait for the upload to complete.

    • Once uploaded, the portal will display the status of the upload.

    • If there are any errors, the portal will generate a report outlining the issues that should be addressed.

  6. Correct errors, if any:

    • If any error report is generated, fix the same in the offline utility and re-generate the JSON file.

    • Re-upload the corrected JSON file, following the same steps mentioned above.

  7. File the Form GSTR-9C on the GST portal:

    • Once the JSON file has been successfully uploaded and reflected in the portal, proceed to file Form GSTR-9C.

    • The filing process can be completed by attaching the Electronic Verification Code (EVC) or Digital Signature Certificate (DSC).

  8. Acknowledgement:

    • After successful completion of the filing, an acknowledgement will be received to the registered email and mobile number.

    • The acknowledgement can be obtained from the GST portal.

Distinguish Between GSTR-9 and GSTR-9C

Following are the points of distinction between Form GSTR-9 and GSTR-9C:

Distinguish Between GSTR-9 and GSTR-9C - Table.png

Frequently asked questions

Q

Explain Form GSTR-9C in short.

A

Form GSTR-9C is a reconciliation statement that is required to be filed once a year by the taxpayers with annual turnover of more than INR 5 Crore. It is a reconciliation of the audited financial statements and the GST returns filed during the financial year.

Q

What is the deadline for filing Form GSTR-9C?

A

The due date for filing Form GSTR-9C is similar to that of filing Form GSTR-9, which is 31st of December following the end of the financial year.

Q

Who can certify Form GSTR-9C?

A

A Chartered Accountant or a Cost Accountant can certify Form GSTR-9C after auditing the taxpayer’s financial records.

Q

Is Form GSTR-9C equivalent to the audit report?

A

No. Form GSTR-9C is a reconciliation statement. It is a part of the GST audit process, and not the audit report. It supplements the audit by providing a reconciliation of the audited financial statements with the GST returns submitted.

Q

Can a taxpayer file Form GSTR-9C without first filing Form GSTR-9?

A

No. Form GSTR-9C must be filed with the Form GSTR-9. It supports the information provided in Form GSTR-9. Thus, it is to be filed in conjunction with the annual return, that is, Form GSTR-9.

Q

What is the consequence of non-filing Form GSTR-9C?

A

Non-filing of Form GSTR-9C results in penal and interest consequences. Moreover, it may also result in scrutiny from the GST authorities.

Q

How can a taxpayer rectify the errors in the submitted Form GSTR-9C?

A

At present the GST portal does not support the revision of a previously filed Form GSTR-9C. The errors and mistakes can only be prevented by carefully reviewing the form before submitting the same.

Q

Is it compulsory to file Form GSTR-9C online?

A

Yes. Form GSTR-9C must be submitted electronically only through the GST portal along with the digital signature of the certifying auditor.

Q

What are the documents required for filing Form GSTR-9C?

A

​An audited financial statements, tax audit report, and annual return, that is, file Form GSTR-9 will be needed to file Form GSTR-9C.

Q

Can a taxpayer file Form GSTR-9C on his own?

A

The taxpayer is responsible for filing Form GSTR-9C online via the GST portal. However, a Chartered Accountant or a Cost Accountant must certify Form GSTR-9C prior to filing the same. Therefore, a taxpayer can prepare the form, certification and final preparation has to be done by a professional.

Prachi Jain

Chartered Accountant

Prachi Jain is a Chartered Accountant with a passion for simplifying finance and tax-related matters through her insightful and informative blogs. With a background in finance and a deep understanding of tax regulations, Prachi has established herself as a trusted source of financial wisdom. Prachi is committed to empowering her readers with the knowledge they need to make informed financial decisions. Her expertise and dedication shine through in every blog post, helping her audience navigate the intricacies of finance and taxes with confidence. Follow Prachi Jain's blog for practical insights and guidance on managing your finances effectively.

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