GSTR-9 Annual Return: Reconciliation and Section-wise Reporting
Who must file GSTR-9, the ₹2/₹5 crore triggers, and the interaction with 9C reconciliation.
GSTR-9 Annual Return: Reconciliation and Section-wise Reporting
The GSTR-9 is an annual return summarising all monthly or quarterly GST returns (GSTR-1, GSTR-3B) filed during a financial year. It's crucial for ensuring compliance, reconciling your outward and inward supplies, and verifying Input Tax Credit (ITC) claims. This return helps the tax authorities and businesses alike to get a consolidated view of the year's transactions, ensuring transparency and accuracy in GST reporting.
Who needs to file GSTR-9 and what are the thresholds?
All registered taxpayers under GST, with a few exceptions, are required to file GSTR-9 annually. This includes regular taxpayers, including those who opted for the composition scheme (GSTR-9A) and e-commerce operators (GSTR-9B). However, certain categories are exempt.
Exemptions from filing GSTR-9:
- Input Service Distributors (ISD)
- Casual Taxable Persons
- Non-Resident Taxable Persons
- Persons paying tax under Section 10 of the CGST Act (Composition Scheme) – these taxpayers file GSTR-9A.
- Persons paying tax under Section 51 (TDS) or Section 52 (TCS) of the CGST Act.
Thresholds:
For a particular financial year, filing GSTR-9 is mandatory for taxpayers whose aggregate turnover exceeds ₹2 crore. For taxpayers with an aggregate turnover up to ₹2 crore, filing GSTR-9 is optional. This optionality was introduced for FY 2017-18, FY 2018-19, and subsequently extended. However, it is always advisable to file it for better record-keeping and reconciliation.
What are the key sections and tables in GSTR-9?
GSTR-9 is divided into six parts, each containing various tables that require specific information about your outward supplies, inward supplies, ITC, and tax payments.
Part I: Basic Details This section auto-populates with your GSTIN, Legal Name, and Trade Name.
Part II: Details of Outward and Inward Supplies declared during the financial year This part consolidates your outward and inward supplies.
- Table 4: Details of advances, inward and outward supplies made during the financial year on which tax is payable. This includes taxable outward supplies (other than zero-rated, nil-rated, and exempted), zero-rated supplies, supplies to SEZ, deemed exports, advances received, and inward supplies attracting reverse charge.
- Table 5: Details of outward supplies made during the financial year on which tax is not payable. This covers exempted, nil-rated, and non-GST supplies, as well as outward supplies on which tax is not payable.
- Table 6: Details of ITC availed during the financial year. This section requires a breakdown of ITC availed on inward supplies, including imports, inward supplies liable to reverse charge, and ITC from ISD.
- Table 7: Details of ITC Reversed and Ineligible ITC during the financial year. This table captures ITC reversals under Rule 37 (payment not made within 180 days), Rule 39 (ISD credit), Rule 42 (exempt/non-business supplies), Rule 43 (capital goods for exempt/non-business supplies), and other reversals.
- Table 8: Other ITC related information. This table provides a reconciliation of ITC as per GSTR-2A (auto-populated) and ITC availed as per GSTR-3B. It highlights any differences, which are crucial for compliance.
Part III: Details of Tax Paid as declared in returns filed during the financial year This section summarises the tax paid through cash and ITC during the financial year, broken down by tax heads (CGST, SGST, IGST, Cess).
Part IV: Details of Tax Payable and Paid This part provides a summary of tax payable and paid during the financial year.
Part V: Particulars of the transactions for the previous financial year declared in returns of April to September of current financial year or up to the date of filing of annual return of the previous financial year whichever is earlier This section is critical for reporting amendments or adjustments related to the previous financial year that were declared in the current financial year's returns (GSTR-1 and GSTR-3B) up to the specified cut-off date.
- Table 10: Supplies/tax declared through amendments.
- Table 11: Supplies/tax reduced through amendments.
- Table 12: Reversal of ITC availed during the previous financial year declared in returns filed during the current financial year.
- Table 13: ITC availed for the previous financial year declared in returns filed in the current financial year.
Part VI: Other Information This section includes details like refunds, demands, and HSN-wise summary of outward and inward supplies.
- Table 17: HSN-wise summary of outward supplies.
- Table 18: HSN-wise summary of inward supplies.
How does GSTR-9C relate to GSTR-9, and what is its purpose?
GSTR-9C is a reconciliation statement between the annual return (GSTR-9) and the audited annual financial statements of the taxpayer. It is certified by a Chartered Accountant or a Cost Accountant.
Purpose of GSTR-9C:
The primary purpose of GSTR-9C is to reconcile the figures reported in the annual return (GSTR-9) with the figures appearing in the audited financial statements (e.g., Profit & Loss Account, Balance Sheet). This reconciliation helps identify discrepancies, if any, between the GST returns filed and the financial records maintained by the business. It ensures that the turnover, tax liability, and ITC claimed are consistent across both sets of documents.
Applicability:
GSTR-9C was mandatory for taxpayers whose aggregate turnover exceeded ₹2 crore in a financial year. However, for financial years 2018-19 onwards, the requirement for GSTR-9C certification by a CA/CMA was removed for taxpayers with an aggregate turnover up to ₹5 crore. For taxpayers with an aggregate turnover exceeding ₹5 crore, GSTR-9C must still be filed, but it can be self-certified by the taxpayer themselves, replacing the earlier requirement of certification by a CA/CMA.
Key components of GSTR-9C:
- Part A: Reconciliation Statement: This section reconciles the turnover, tax payable, ITC, and other details as per GSTR-9 with the audited financial statements.
- Part B: Certification: This part contains the certification by the Chartered Accountant/Cost Accountant (or self-certification by the taxpayer, as applicable).
What are the consequences of late filing of GSTR-9?
Late filing of GSTR-9 attracts a late fee under Section 47 of the CGST Act, 2017.
Section 47 of the CGST Act, 2017 states:
"(1) Any registered person who fails to furnish the details of outward or inward supplies required under section 37 or section 38 or returns required under section 39 or section 45 or section 52 within the due date, shall pay a late fee of one hundred rupees for every day during which such failure continues subject to a maximum amount of five thousand rupees. (2) Any registered person who fails to furnish the annual return under section 44 by the due date shall be liable to pay a late fee of one hundred rupees for every day during which such failure continues subject to a maximum amount of five thousand rupees."
Explanation:
The late fee for GSTR-9 is ₹100 per day under the CGST Act and ₹100 per day under the respective State GST Act. This means a total of ₹200 per day (₹100 CGST + ₹100 SGST). This late fee is subject to a maximum of 0.25% of the turnover in the State or Union territory (0.25% CGST + 0.25% SGST, totaling 0.50%).
It's important to note that there is no late fee for IGST.
Apart from the monetary penalty, late filing can also lead to other issues, such as:
- Blocking of e-way bill generation: Non-filers of GSTR-3B for two consecutive tax periods may face restrictions on e-way bill generation. While this is not directly linked to GSTR-9, consistent non-compliance can lead to such actions.
- Impact on compliance rating: Although a formal compliance rating system is yet to be fully implemented, timely filing is crucial for maintaining a good compliance record.
- Difficulty in availing refunds: Any pending annual return might hinder the processing of GST refunds.
Which tables in GSTR-9 are optional versus mandatory?
Over time, the government has provided relaxations, making certain tables in GSTR-9 optional for specific financial years to ease the compliance burden. It's crucial to refer to the latest notifications for the applicable financial year.
Here's a general comparison, but always verify with the latest official pronouncements:
| Table Number | Description
| Part II: Details of Outward and Inward Supplies declared during the financial year |
| 4B | Outward supplies (B2C) | Mandatory | Mandatory |
| 4C | Zero-rated supply (Export) on payment of tax (except supplies to SEZ) | Mandatory | Mandatory |
| 4D | Supply to SEZ on payment of tax | Mandatory | Mandatory |
| 4E | Deemed Exports | Mandatory | Mandatory |
| 4F | Advances received on which tax has been paid but invoices have not been issued | Mandatory | Mandatory |
| 4G | Inward supplies attracting reverse charge | Mandatory | Mandatory |
| 4H | Sub-total (4A to 4G) | Mandatory | Mandatory |
| 4I | Credit Notes issued in respect of transactions specified in 4B to 4E | Mandatory | Mandatory |
| 4J | Debit Notes issued in respect of transactions specified in 4B to 4E | Mandatory | Mandatory |
| 4K | Supplies declared through amendments (Net of debit notes and credit notes) | Mandatory | Mandatory |
| 4L | Supplies reduced through amendments (Net of debit notes and credit notes) | Mandatory | Mandatory |
| 4M | Sub-total (4I to 4L) | Mandatory | Mandatory |
| 4N | Taxable outward supplies (4H + 4M) | Mandatory | Mandatory |
| 5A | Exempted supplies | Mandatory | Mandatory |
| 5B | Nil-rated supplies | Mandatory | Mandatory |
| 5C | Non-GST supply | Mandatory | Mandatory |
| 5D | Zero-rated supplies (Export) without payment of tax | Mandatory | Mandatory |
| 5E | Supplies to SEZ without payment of tax | Mandatory | Mandatory |
| 5F | Deemed Exports | Mandatory | Mandatory |
| 5G | Advances received on which tax has not been paid | Mandatory | Mandatory |
| 5H | Sub-total (5A to 5G) | Mandatory | Mandatory |
| 5I | Credit Notes issued in respect of transactions specified in 5A to 5H | Mandatory | Mandatory |
| 5J | Debit Notes issued in respect of transactions specified in 5A to 5H | Mandatory | Mandatory |
| 5K | Supplies declared through amendments (Net of debit notes and credit notes) | Mandatory | Mandatory |
| 5L | Supplies reduced through amendments (Net of debit notes and credit notes) | Mandatory | Mandatory |
| 5M | Sub-total (5I to 5L) | Mandatory | Mandatory |
| 5N | Non-taxable outward supplies (5H + 5M) | Mandatory | Mandatory |
| 6A | Total ITC available for the financial year | Mandatory | Mandatory |
| 6B | ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZ) | Mandatory | Mandatory |
| 6C | ITC on inward supplies (including services received from SEZ) liable to reverse charge | Mandatory | Mandatory |
| 6D | ITC on import of goods | Mandatory | Mandatory |
| 6E | ITC on import of services | Mandatory | Mandatory |
| 6F | ITC received from ISD | Mandatory | Mandatory |
| 6G | Any other ITC availed | Mandatory | Mandatory |
| 6H | Sub-total (6B to 6G) | Mandatory | Mandatory |
| 6I | ITC reclaimed which was reversed under Rule 37, 39, 42 & 43 in earlier financial year | Mandatory | Mandatory |
| 6J | Net ITC available (6H - 6I) | Mandatory | Mandatory |
| 7A | ITC reversed as per Rule 37 (payment not made within 180 days) | Mandatory | Mandatory |
| 7B | ITC reversed as per Rule 39 (ISD credit) | Mandatory | Mandatory |
| 7C | ITC reversed as per Rule 42 (exempt/non-business supplies) | Mandatory | Mandatory |
| 7D | ITC reversed as per Rule 43 (capital goods for exempt/non-business supplies) | Mandatory | Mandatory |
| 7E | ITC reversed on account of Section 17(5) (ineligible ITC) | Mandatory | Mandatory |
| 7F | Any other ITC reversal | Mandatory | Mandatory |
| 7G | Sub-total (7A to 7F) | Mandatory | Mandatory |
| 7H | Net ITC available for utilisation (6J - 7G) | Mandatory | Mandatory |
| 8A | ITC as per GSTR-2A (auto-populated) | Mandatory | Mandatory |
| 8B | ITC as per GSTR-3B | Mandatory | Mandatory |
| 8C | ITC on inward supplies (other than imports and inward supplies liable to reverse charge but includes services received from SEZ) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8D | ITC on inward supplies (including services received from SEZ) liable to reverse charge | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8E | ITC on import of goods | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8F | ITC on import of services | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8G | ITC received from ISD | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8H | Any other ITC availed | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8I | Sub-total (8C to 8H) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8J | ITC reclaimed which was reversed under Rule 37, 39, 42 & 43 in earlier financial year | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8K | Net ITC available (8I - 8J) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8L | Difference (8A - 8K) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8M | ITC available but not availed (8L > 0) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 8N | ITC availed but not available (8L < 0) | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| Part V: Particulars of the transactions for the previous financial year declared in returns of April to September of current financial year or up to the date of filing of annual return of the previous financial year whichever is earlier |
| 10 | Supplies/tax declared through amendments | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 11 | Supplies/tax reduced through amendments | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 12 | Reversal of ITC availed during the previous financial year declared in returns filed during the current financial year | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 13 | ITC availed for the previous financial year declared in returns filed in the current financial year | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| Part VI: Other Information |
| 15A | Refunds claimed | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 15B | Refunds sanctioned | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 15C | Refunds rejected | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 15D | Refunds pending | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 16A | Demands of tax | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 16B | Taxes paid in respect of demands | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 17 | HSN-wise summary of outward supplies | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
| 18 | HSN-wise summary of inward supplies | Mandatory | Optional (for FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23) |
Note: The "Optional" status for tables 8, 10, 11, 12, 13, 15, 16, 17, and 18 has been extended for several financial years, including FY 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, and 2022-23. Always refer to the latest CBIC notifications for the specific financial year you are filing for.
How SP & SC helps
Navigating the complexities of GSTR-9 and GSTR-9C can be challenging. SP & SC Legal and Taxation Services offers expert assistance with annual GST return filings, ensuring accurate reconciliation, timely submission, and full compliance with all statutory requirements. Our services help you minimise risks and focus on your core business operations. Learn more at /services/compliance/annual-filings.
Frequently asked questions
What is the due date for filing GSTR-9?
The due date for filing GSTR-9 for a particular financial year is typically 31st December of the subsequent financial year. For example, for the financial year 2023-24, the due date would be 31st December 2024. However, the government may extend these dates through notifications, so it's always advisable to check the latest announcements.
Can GSTR-9 be revised after filing?
No, GSTR-9 cannot be revised once it has been filed. Therefore, it is crucial to exercise extreme caution and verify all details thoroughly before submitting the return. Any errors or omissions can only be rectified in the subsequent financial year's GSTR-9, if permitted by law, or through other compliance mechanisms.
What is the difference between GSTR-9 and GSTR-3B?
GSTR-3B is a monthly or quarterly summary return for outward supplies, inward supplies attracting reverse charge, and ITC availed, along with tax payment. GSTR-9, on the other hand, is an annual consolidated return that summarises all the GSTR-3B and GSTR-1 filings for the entire financial year, providing a comprehensive overview.
Is it mandatory to file GSTR-9 even if there are no transactions?
If a taxpayer is registered under GST and the aggregate turnover exceeds the threshold (currently ₹2 crore for mandatory filing), they must file GSTR-9, even if there were no transactions during the financial year. In such cases, a 'Nil' return would be filed. If the turnover is below the threshold, filing is optional.
What is the importance of reconciling GSTR-9 with GSTR-2A?
Reconciling GSTR-9 with GSTR-2A (and GSTR-2B) is critical for verifying the Input Tax Credit (ITC) claimed. GSTR-2A/2B reflects the ITC as reported by your suppliers. Any discrepancies between your claimed ITC (as per GSTR-3B and GSTR-9) and the auto-populated ITC in GSTR-2A/2B need to be investigated and resolved to avoid potential demands from tax authorities.
What documents are required for filing GSTR-9?
To file GSTR-9, you typically need:
- All GSTR-1 and GSTR-3B returns filed during the financial year.
- Audited financial statements (if applicable).
- Purchase and sales registers.
- ITC ledger and electronic cash ledger.
- Details of outward and inward supplies (including exempted, nil-rated, non-GST supplies).
- HSN-wise summary of outward and inward supplies (if applicable).
- Details of any amendments made in the subsequent financial year for the previous year's transactions.