GSTR 9C: Reconciliation Statement & Certification- Filing, Format & Rules


In the vast landscape of India’s GST regime, GSTR-9C emerges as a pivotal document, facilitating a crucial bridge between a business’s audited annual statements and their declared GST returns. If you’ve ever grappled with understanding this critical form, you’re in the right place. Dive into this guide to decode every nuance of GSTR-9C.

What Exactly is GSTR-9C?

Before wading through its intricacies, let’s define GSTR-9C. If your business’s annual turnover surpasses the ₹5 crore threshold, you’re mandated to reconcile your annual returns in GSTR-9 with your audited financial statements. This exercise culminates in the GSTR-9C – a reconciliation statement.

Essentially, GSTR-9C is a meticulous comparison of:

  • The details in the Annual GSTR-9 returns for a financial year, and
  • The figures as presented in the taxpayer’s audited annual financial statements.
  • One of its pivotal aspects is addressing any discrepancies between the GST returns and the audited accounts. Highlighting these differences and their reasons is an integral part of GSTR-9C. For each GSTIN, there’s a dedicated GSTR-9C, implying that for a singular PAN, you might end up filing multiple GSTR-9C forms.

Key Stakeholders: Who Should Brace for GSTR-9C?

Any GST-registered taxpayer breaching the ₹5 crore turnover mark must prepare, self-certify, and subsequently file GSTR-9C on the GST portal. Alongside, they’re also expected to furnish a copy of their audited accounts and the annual return in GSTR-9.

However, there are exceptions to this rule. As per a directive from the Central Board of Indirect Taxes & Customs (CBIC) in July 2021, certain foreign airline businesses compliant with the Companies Act 2013’s provisions aren’t tethered to the GSTR-9C obligation. Similarly, non-resident entities providing OIDAR services to unregistered Indian consumers have been graciously exempted.

Spotlight on Deadlines: When Should You File GSTR-9C?

The due date for GSTR-9C shadows that of GSTR-9, implying an annual deadline of 31st December of the subsequent year for the fiscal year in question. However, the government, in its prudence, can extend this timeline.

Deciphering GSTR-9C’s Structure

Diving into its core, GSTR-9C comprises two segments:

Part-A: Reconciliation Statement – This segment is a meticulous match-up between the audited financial statement figures (at the PAN level) and the data declared in GSTR-9 for a specific GSTIN.

Part-B: Self-certification – As the name suggests, this section underscores the taxpayer’s affirmation of the statement’s veracity.

Recent amendments, especially Notification No: 56/2019, issued in November 2019 for FY 2017-18 & 2018-19, made some parts optional. For instance, adjustments in turnover details from tables 5B to 5N can now be consolidated in Table 5O. Similarly, reconciliation of ITC details in tables 12B, 12C, and 14 has been made discretionary.

Key Developments in GSTR-9C’s Landscape

Being a dynamic component of the GST regime, GSTR-9C has witnessed significant updates:

31st March 2023: Via CGST Notification 07/2023, the GST Council shared insights on late fee rationalization for tardy GSTR-9 submissions. This step ensures a more structured late fee imposition based on a taxpayer’s turnover.

18th February 2023: The 49th GST Council meeting spotlighted late fee reconfigurations and introduced a conditional amnesty scheme, further simplifying the landscape for businesses.

5th July 2022: A major relief came for GST-registered entities with turnovers up to ₹2 crore for FY 21-22, as they were exempted from filing GSTR-9C.

The Significance of GSTR-9C in the GST Ecosystem

GSTR-9C isn’t just a mandatory submission; it’s an affirmation of the accuracy of the taxpayer’s returns. With GST authorities utilizing this document to corroborate the veracity of submitted GST returns, GSTR-9C serves as a crucial checkpoint. The self-certification by the taxpayer adds another layer of accountability.

Notable Changes and Evolution

Up until 31st December 2018, GSTR-9C required certification by a Chartered Accountant (CA). However, in an evolutionary move, from FY 2020-21 onwards, the CA/CMA certification was abolished. Instead, it transitioned to a system emphasizing taxpayer accountability, where they are entrusted with the responsibility of the statement’s authenticity.

In Closing

GSTR-9C is a testament to the meticulousness and precision expected in the GST regime. While it may appear complex, understanding its structure, intent, and nuances can considerably ease the filing process. As the GST landscape continually evolves, staying updated and informed is paramount.