GSTR-9C Reconciliation Statement: Who Must File

Short answer: Form GSTR-9C is a reconciliation statement between a taxpayer's annual GST return (GSTR-9) and their audited financial statements. It is mandatory for registered persons whose aggregate turnover exceeds ₹5 crore in a financial year. The statement must be prepared and certified by a Chartered Accountant or a Cost Accountant and filed along with the GSTR-9 by 31st December of the subsequent year.

What is Form GSTR-9C?

Form GSTR-9C is a detailed statement that reconciles the figures reported in your annual GST return (Form GSTR-9) with the figures in your audited annual financial statements. Mandated under Section 44(2) of the CGST Act, 2017, its primary purpose is to ensure that the turnover, taxes paid, and input tax credit (ITC) claimed as per your GST returns are consistent with your audited books of accounts. It serves as a check mechanism to verify the correctness of GST compliance for the financial year.

Who is required to file GSTR-9C?

Every registered person under GST whose aggregate turnover during a financial year exceeds ₹5 crore is required to get their accounts audited under the GST laws and file Form GSTR-9C. This threshold is calculated on a PAN-India basis. This means if you have multiple GSTINs under the same PAN, the combined turnover of all branches is considered. However, government departments, local authorities, and taxpayers under the composition scheme are not required to file GSTR-9C.

What is the due date for filing GSTR-9C?

The due date for filing Form GSTR-9C is the same as for the annual return, GSTR-9. It must be filed on or before 31st December of the year following the relevant financial year. For instance, for the financial year 2025-26, the due date for filing GSTR-9C is 31st December 2026. The government can extend this due date through a notification, but relying on extensions is not a sound compliance strategy.

What are the components of GSTR-9C?

Form GSTR-9C is divided into two main parts:

• Part A: Reconciliation Statement: This part contains the core reconciliation tables. It requires a detailed comparison of financial data between the audited statements and the GSTR-9. The key sections within Part A are:

  • Part I: Basic Details: GSTIN, Financial Year, Legal Name, and Trade Name.
  • Part II: Reconciliation of Turnover: Compares the gross and taxable turnover declared in the audited financials with the turnover declared in the GSTR-9.
  • Part III: Reconciliation of Tax Paid: Reconciles the total tax paid as per the books of accounts with the tax actually paid as declared in GSTR-9.
  • Part IV: Reconciliation of Input Tax Credit (ITC): Compares the ITC availed and utilized as per the audited financials with the ITC declared in the GSTR-9.
  • Part V: Auditor's Recommendation on Additional Liability: The certifying CA/CMA declares any additional tax liability arising from the reconciliation exercise, which the taxpayer must pay.

• Part B: Certification: This part is the certification by the Chartered Accountant or Cost Accountant who has conducted the reconciliation and prepared the statement. The professional certifies the accuracy of the information provided in Part A and the truth and fairness of the reconciliation.

How is 'aggregate turnover' calculated for the GSTR-9C threshold?

Calculating 'aggregate turnover' correctly is critical to determine your liability to file GSTR-9C. As per Section 2(6) of the CGST Act, it is the all-India, PAN-based total value of:

1. All taxable supplies (excluding inward supplies on which tax is paid on a reverse charge basis).
2. Exempt supplies.
3. Exports of goods or services or both.
4. Inter-state supplies of persons having the same Permanent Account Number (PAN).

This sum specifically excludes the Central tax (CGST), State tax (SGST), Union territory tax (UTGST), Integrated tax (IGST), and GST Compensation Cess.

Item Included in Turnover	Included in 'Aggregate Turnover'?
Value of Taxable Sales	Yes
Value of Exempt Sales (e.g., agricultural produce)	Yes
Value of Exports	Yes
Stock transfers to another branch (same PAN)	Yes
Interest income on loans and advances	Yes (as it is an exempt supply)
GST Taxes (CGST, SGST, IGST) Collected	No
Value of inward supplies under RCM	No

Worked example

Let's consider 'Innovate Solutions Pvt. Ltd.', a software development company in Bengaluru, for FY 2025-26.

• Turnover as per Audited Profit & Loss A/c: ₹6,20,00,000
• Turnover as per GSTR-9: ₹6,05,00,000

The CA preparing GSTR-9C must reconcile this difference of ₹15,00,000.

Step-by-Step Reconciliation (Part II of GSTR-9C):

1. Start with Turnover as per Audited Financials: ₹6,20,00,000
2. Analyze the difference: The accountant finds that the P&L includes ₹20,00,000 of 'unbilled revenue' recognized at year-end as per accounting standards (Accrual basis). However, GST is payable only upon the issue of an invoice or completion of service (Time of Supply rules). This revenue pertains to a project where the milestone was completed on 31st March 2026, but the invoice was raised on 5th April 2026.
3. Make Adjustments in GSTR-9C:
   • Table 5B (Turnover as per Audited Financials): ₹6,20,00,000
   • Table 5D (Unbilled revenue at the beginning of the Financial Year): Nil (Assuming)
   • Table 5F (Unadjusted advances at the end of the Financial Year): ₹5,00,000 (An advance received in Feb 2026 for a project starting in May 2026, on which GST was paid in Feb 2026 itself, but revenue is not recognized in P&L for FY 2025-26).
   • Table 5O (Unbilled revenue at the end of the Financial Year): ₹20,00,000
4. Calculate Reconciled Turnover:
   • Audited Turnover: ₹6,20,00,000
   • Add: Unadjusted advances: + ₹5,00,000
   • Less: Unbilled revenue at year end: - ₹20,00,000
   • Reconciled Turnover for GST: ₹6,05,00,000
5. Compare with GSTR-9: This reconciled figure of ₹6,05,00,000 matches the turnover declared in the annual return (Table 5N of GSTR-9C), so there is no unreconciled difference. The reconciliation is successful.

Common mistakes

1. Incorrect Turnover Calculation: Failing to include exempt supplies or inter-state stock transfers in the 'aggregate turnover' calculation, leading to non-filing of GSTR-9C when it was actually required.
2. Ignoring Auditor's Observations: Treating the auditor's recommendations in Part V for additional tax liability as optional. Any liability identified must be paid via Form DRC-03.
3. Mismatch in ITC: Inability to reconcile ITC as per books with ITC availed in GSTR-3B/GSTR-9, often due to non-compliance with Section 16 conditions, like non-receipt of goods or supplier's non-payment of tax. Explore our guide on Input Tax Credit rules.
4. Forcing the Reconciliation: Making lump-sum, unexplained adjustments to force the turnover or tax figures to match, which can be easily flagged during departmental audits. Proper reasons for differences must be stated.
5. Missing the Deadline: Filing GSTR-9C after the 31st December due date, attracting a general penalty under Section 125 of the CGST Act, which can be up to ₹25,000 each under CGST and SGST Act.

How SP & SC helps

Navigating the complexities of GSTR-9C requires meticulous attention to detail and a deep understanding of both accounting standards and GST law. SP & SC Legal and Taxation Services provides end-to-end assistance for your GST compliance. Our team of Chartered Accountants will thoroughly review your books of accounts, GST returns, and other records. We prepare the GSTR-9C reconciliation statement, identify any potential discrepancies or liabilities, provide clear recommendations, and ensure timely and accurate filing. We handle the entire process, giving you peace of mind. For comprehensive GST support, explore our GST return filing services.

Frequently asked questions

H3: Is GSTR-9C required if my business is under tax audit but turnover is below ₹5 crore?

No. The requirement to file GSTR-9C is solely based on the 'aggregate turnover' exceeding ₹5 crore under GST law. It is independent of the requirement for a tax audit under the Income-tax Act, 1961. So, if your turnover is, say, ₹4 crore, you might need a tax audit under Section 44AB of the Income-tax Act, but you will not be required to file GSTR-9C.

H3: Can I file GSTR-9C myself?

No. GSTR-9C must be prepared and certified by a practicing Chartered Accountant or a Cost Accountant. A business owner or an in-house accountant cannot certify Form GSTR-9C. You must engage an independent professional for this compliance.

H3: What are the penalties for not filing GSTR-9C?

There is no specific penalty prescribed for the non-filing of GSTR-9C. Therefore, it falls under the general penalty provision, Section 125 of the CGST Act, 2017. This can attract a penalty of up to ₹25,000 under the CGST Act and another ₹25,000 under the SGST Act, for a total of ₹50,000.

H3: Does GSTR-9C need to be filed for each GSTIN separately?

Yes. If a legal entity (with one PAN) has multiple GSTINs in different states, and its aggregate (all-India) turnover exceeds ₹5 crore, GSTR-9C must be filed for each GSTIN that is registered.

H3: Can GSTR-9C be revised after filing?

No. Currently, the GST portal does not allow for the revision of Form GSTR-9C once it has been filed. It is crucial to ensure all details are accurate before submission. Any errors or omissions can only be clarified through submissions during a departmental audit or scrutiny.

Get a fixed-fee quote

Before you file your annual returns, ensure your books and GST records are perfectly reconciled. Share your documents with us for a review and a written fixed-fee quote for GSTR-9 and GSTR-9C preparation and filing. Contact SP & SC today, or message us on WhatsApp at +91 90356 74566. Our team is equipped to handle all your GST compliance needs, end to end.