GSTR 9C - A detailed guide with meaning, due dates & details

GSTR 9C – A detailed guide with meaning, due dates & details

Introduction to GSTR 9C

In this post, we’ll talk about theGSTR-9C, its due date, and other details. Let’s see each section in detail: 

What is GSTR 9C?

It is an audit form that was launched on September 13, 2018. It must be filed yearly by taxpayers with a turnover of more than 2 crores. Also, it must be validated by a CA. It is mainly a reconciliation statement between the yearly returns filed in GSTR-9 and the audited annual financial statements of the taxpayer. This form will contain the taxpayer’s gross and taxable turnover determined from their accounting books, reconciled with corresponding figures after combining all GST returns for the financial year, and any differences uncovered by the reconciliation. It is important to specify the difference and the reason for it. For each GSTIN, a GSTR-9C must be issued.

Who Should File GSTR 9C?

The form must be submitted by each taxpayer whose annual reports are subject to audit. (If a taxpayer’s total annual turnover exceeds Rs. 2 crores during a financial year, their annual reports must be audited.) In order to file a GSTR 9C, a chartered accountant or cost accountant must prepare and certify the form, after which the taxpayer must use either the GST portal or a facilitation centre to file it. Additionally, the taxpayer may have to submit a copy of their audited accounts and an annual return in a GSTR-9 form along with the GSTR 9C form.

Who will prepare and submit this return?

Chartered Accountant or Cost Accountant must prepare and certify GSTR 9C. It must be filed on the GST site together with:
  • the GST Annual Returns(GSTR-9) and
  • the Audited Financial Statements
This declaration applies to every taxpayer who, in accordance with GST legislation, must have an audit of their annual accounts.

What is the due date for filling ?

The deadline for submitting the GSTR 9C is the same as the deadline for filing the GSTR 9. As a result, you must file GSTR 9C on or before December 31st of the year after the financial year under audit. For example, the deadline for reporting GSTR 9C for fiscal year 2017-18 will be December 31, 2018.

The importance of this return

A Chartered accountant or cost accountant will prepare this GST Reconciliation statement. The CA has to report any differences between the details in GST returns and the audit. Also, this statement acts as a base for the GST authorities to verify the correctness of the GST returns filed by the taxpayers. This is because the CA has to certify any additional liability arising out of the reconciliation exercise and GST audit in GSTR 9C.

The content to be shown in GSTR-9C

GSTR-9C consists of two main parts:
  • Part-A: Reconciliation Statement
  • Part-B: Certification

Part-A: Reconciliation Statement

The figures in the audited financial statements are at PAN level. So, it is necessary to extract the turnover, tax paid, and ITC collected for a specific GSTIN from the organisation’s overall audited statements. The Reconciliation Statement consists of five parts as follows

Part-I:

Basic details -> Consists of FY, GSTIN, Legal Name, and Trade Name. The taxpayer must also mention if they are 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) -> the process consists of reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. As 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.

Part-III:

Reconciliation of tax paid -> This section requires GST rate-wise reporting of the tax liability that arose in FY as per the accounts and paid as reported in the GSTR 9 respectively with the differences thereof. Also, 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 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. Also, it needs a reporting of expenses booked as per the audited accounts, with a breakup of eligible and ineligible ITC. And the 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 process 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 in case not included in the Annual Returns(GSTR 9)
  • Return of an incorrect refund
  • Additional unresolved claims

Part-B: Certification

The GSTR 9C can be certified by the same CA who conducted the GST audit.  Also, it can be certified by any other CA who did not conduct the GST Audit for that particular GSTIN. The difference between both is that in case the CA certifying the GSTR 9C did not conduct the GST audit, he must have based an opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format for the certification report will vary depending on who the certifier is. And with that, we end this post of GSTR 9C. If you have any questions, drop them in the comment section below.

FAQs on GSTR-9C

What are the prerequisites to file the form GSTR-9C?

  • The taxpayer must have an account on the GSTR Portal.
  • Taxpayers should have filed their GSTR-9 Form for the applicable tax period.
  • The government requires that taxpayers have their accounts audited.
  • The Taxpayer’s yearly aggregate turnover must be at least Rs. 2 Crores.

What are the two parts of GSTR-9C?

GSTR-9C Consists of 2 Parts, namely- Part A- Reconciliation Statement Part B- Audit Certification

How to download the GSTR-9C offline utility?

Go to GST Portal Downloads > Offline Tools > Offline Tools. Offline GSTR-9C Tool Unzip the GSTR 9c Offline Utility.xls excel sheet file. Read the instructions and fill out the form accordingly.

How to upload the generated JSON File using GSTR-9C Offline Utility?

Log in to the GST portal > Annual return > Select Financial year and click on Search > Click on ‘Prepare Offline’ option in GSTR-9C tile > Go to the ‘upload’ tab.

What is the process of filing GSTR-9C?

The Cost Accountants/CA verify, audit, and sign the Accounts before submitting them to the Taxpayer in JSON format. After reviewing it, the taxpayer submits it to the GST Portal along with any necessary supporting documents, such as a balance sheet, profit and loss statement, expense account, etc.

When is the filing of GSTR-9C enabled on the GST Portal?

A taxpayer can only enable File GSTR-9C after successfully filing Form GSTR-9.