GSTR 9C

Introduction

GSTR 9C is a reconciliation statement that aligns GSTR annual returns with figures from taxpayers’ audited financial reports for a given fiscal year. First introduced on 13th September 2018, this document plays a vital role in maintaining the accuracy of GST compliance. In this guide, we delve into the significance of GSTR 9, its format, the filing process, necessary documents, and its distinct role in GST audits.

What is GSTR 9C?

GSTR 9C functions as an audit form comparable to a tax audit report. It includes critical figures like gross and taxable turnover and is mandatory for taxpayers whose annual income is audited. As per GST law, any entity with an annual turnover exceeding Rs. 2 crore must file Form GSTR 9. This form must be submitted alongside an audit certification and reconciliation statement to validate that the figures align with GSTR 9, the annual GST return.

Typically, GSTR 9C should be filed by 31st December of the following assessment year, though deadlines may occasionally be extended by government notification.

GSTR 9C Format and Structure

GSTR 9 is structured into two primary parts:

1. Part A – Reconciliation Statement

This part compares the annual turnover declared in the audited financial statement with that declared in GSTR 9. It consists of the following sub-sections:

Basic Information: Includes fiscal year, GSTIN, taxpayer’s legal name, business trade name, and audit eligibility.
Turnover Reconciliation: Matches the turnover declared in financial statements with that in the GSTR 9.
Liability Reconciliation: Reconciles tax liability based on turnover, including rate-wise breakdowns.
Input Tax Credit (ITC) Reconciliation: Compares ITC in financial books with ITC in GSTR 9.
Auditor’s Recommendations: Highlights additional liabilities that arise due to discrepancies in ITC or turnover.

2. Part B – Auditor’s Certification

This section includes the certification completed by a Chartered Accountant (CA) post-audit. The auditor confirms the accuracy of the GSTR 9 and certifies it with two components:

Direct Certification by the Auditor: Affirms that the form was filled out by the individual who conducted the audit.
Audit-Based Certification: Confirms accuracy based on audit observations.

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Preparation and Submission of GSTR 9C

A Chartered Accountant or Cost Accountant prepares and certifies GSTR 9. Taxpayers can file it online via the GST portal or through facilitation centers. This form should be filed in conjunction with the GSTR 9 return and requires submission of essential financial documents, such as:

Balance sheet
Profit & Loss account
Cash flow statement
Audited annual reports and accounts

Importance of GSTR 9C

Filing GSTR 9C ensures that businesses with a turnover exceeding Rs. 2 crore maintain compliance with GST requirements. A digitally signed certificate from a GST auditor, GSTR 9 validates the accuracy of GST returns filed in a given fiscal year.

The form highlights any liabilities or discrepancies between the GSTR returns and audited financials, establishing GSTR 9C as a key measure for authorities to evaluate compliance.

How to Download GSTR 9C

Taxpayers can download GSTR 9C using two methods:

1. Online Portal

Log in to the GST portal using your credentials.
Go to the ‘Annual Return’ tab on the dashboard.
Select the relevant fiscal year.
Click on ‘Initiate e-filing’ to proceed.

Note: GSTR 9 must be filed before accessing the GSTR 9 form.

2. Offline Tool

Visit the GST portal and navigate to the ‘Downloads’ option.
Select ‘Offline Tools’ and click on GSTR-9C Offline Tool.
Download the zip file, extract it, and enable editing and content settings.
Input basic details like GSTIN, fiscal year, and legal name in the tool.

Upon completing these steps, save the form and upload it for filing.

Documents Required for GSTR 9C Filing

Taxpayers need to submit the following documents:

Copy of balance sheet
Profit & Loss account
Cash flow statement
Copy of audited accounts
Copy of the annual report

Note: The audit report should be certified by an authorized auditor.

Penalties for Missing GSTR 9C Due Date

Taxpayers who miss the GSTR 9C filing deadline are subject to a penalty of Rs. 200 per day, including Rs. 100 as CGST and Rs. 100 as SGST. The total penalty cannot exceed 0.50% of the aggregate turnover. Therefore, timely filing is crucial to avoid late fees.

GSTR 9C vs. GSTR 9: Key Differences

Criteria	GSTR 9C	GSTR 9
Type	Reconciliation statement	Annual GST return
Legal Provision	Section 35(5) of the GST Act	Rule 80 under Section 44 of CGST Act
Applicable for	Taxpayers with audited reports	Registered taxpayers
Annual Turnover Threshold	> Rs. 2 crores	Not applicable for certain taxpayer types
Filing Deadline	31st December (with or post GSTR 9 filing)	31st December of the following fiscal year
Penalty	Rs. 25,000 general penalty	Rs. 200 per day with a 0.25% turnover ceiling
Filing Mode	GST portal or facilitation center	GST portal or facilitation center
Documentation Requirement	Audited P&L, balance sheet	No such requirement
Digital Signatures	Auditors and taxpayers	Taxpayers only

This comparison clarifies that GSTR 9 is the general annual return, while GSTR 9C is an audit certification. For businesses eligible for GSTR 9, understanding these differences is essential for accurate filing.

Conclusion

GSTR 9C is an essential audit and reconciliation statement that helps ensure accurate GST filings by aligning GST returns with audited financials. Failure to file on time results in penalties, making it crucial for eligible taxpayers to adhere to GSTR 9 requirements diligently.