GSTR 9C – Applicability, Due Date, Turnover Limit

  Staying compliant with GST is not just about filing returns, as it is about ensuring your records truly match your business reality. GSTR?9C plays a key role in this process by reconciling annual GST filings with audited financial statements. It helps businesses maintain accuracy, build transparency, and avoid unwanted tax issues. By reviewing and validating reported details, this form strengthens trust and keeps GST compliance smooth and hassle-free for businesses of every size.

What is GSTR-9C?

GSTR?9C is a yearly reconciliation form that ensures your GST returns truly reflect your business’s financial statements. It acts like a review, highlighting any differences between the annual GST filing and audited accounts. This process helps maintain accuracy, transparency, and compliance with tax rules. The form needs to be certified either by the business itself or by a Chartered Accountant or Cost Accountant before being submitted online. By filing GSTR?9C, businesses can avoid errors, build trust with authorities, and ensure their GST reporting stays hassle-free.

GSTR-9C Applicability and Turnover Limit

If your business is registered under GST and your annual turnover goes beyond ?5?crore, you are required to file Form GSTR?9C. It ensures you have audited your accounts and reconciled all GST data. This includes comparing figures in your annual GST return with your audited financial statements to highlight differences – a key compliance step.

• Some types of taxpayers are exempt from this requirement, even if their turnover crosses the threshold. This includes businesses under the composition scheme, casual or non-resident taxpayers, service distributors, and government departments.
• Recent updates allow self-certification of GSTR?9C instead of mandatory CA/CMA certification, offering more flexibility for eligible taxpayers. The deadline to file GSTR?9C is the same as GSTR?9, usually by December?31 of the year following the financial year. If this date is missed, general penalties under Section 125 of the CGST Act may apply.

Due Date for Filing GSTR-9C

For businesses crossing the turnover threshold, GSTR?9C must be filed along with the annual return (GSTR?9) by December?31 following the end of the financial year. For example, the annual return for the financial year 2024–25 is due on December?31, 2025.

This deadline was re-established by the Central Board of Indirect Taxes and Customs (CBIC) under the CGST rules, which clarify that both GSTR?9 and GSTR?9C are treated as a single filing obligation, due on the same date.

Late Filing: What Happens?

If you miss the due date, late fees and interest penalties apply. The late fee under CGST usually continues until you file both forms, though CBIC has occasionally granted fee waivers for past years if GSTR?9C was filed by the extended deadline. Staying ahead prevents extra charges and protects your compliance record.

Importance of GSTR-9C

GSTR?9C is more than a form, as it is a vital tool for keeping your GST reporting trustworthy and accurate. It ensures that the numbers you declare in your annual GST return (GSTR?9) match exactly with your audited financial statements. This comparison helps find and explain any gaps, ensuring your taxes reflect true business activity.

• Boosts Financial Transparency

Reconciliation under GSTR?9C bridges business records with GST figures, making sure every turnover, tax paid, and input tax credit (ITC) is consistent. This transparency reassures regulators, lenders, partners, and stakeholders that your tax reporting is solidly backed by your official books.

• Strengthens Accountability

By certifying the form, either yourself or through a CA/CMA, you show willingness to be answerable for any differences. This helps audit officials move quickly through your records and focus on real issues, rather than wasting time on mismatched data.

• Strengthens Compliance and Reduces Penalties

Tax authorities use GSTR?9C to improve compliance and reduce errors. Businesses that file accurately and on time avoid penalties and build a stronger compliance history. In short, it is a shield against late fees, investigations, and trust issues.

• Validates Input Tax Credit (ITC)

GSTR?9C helps check that all ITC claimed during the year reflects genuine invoices and payments. This accurate reconciliation helps you avoid credit reversals or notices during future audits.

• Creates a Strong Audit Trail

Your reconciliation forms a clear audit trail for the year, showing the logic behind all figures. This makes it easier for tax authorities to verify data and for you to defend your books under scrutiny.

• Supports Better Decision-Making

By reconciling your books annually, you gain insights into financial performance: revenue trends, credit utilisation, and discrepancies. These insights guide smarter tax strategy, better budgeting, and stronger financial planning.

Contents & Format of GSTR?9C

GSTR?9C checks if your annual GST return (GSTR?9) matches your audited books. It has two main parts:

• Part?A?– Reconciliation Statement
• Part?B?– Certification (omitted on the form itself from FY 2020?21, but still part of the filing)

Part A – Reconciliation Statement

This is the heart of GSTR?9C. The numbers in your audited books are at the PAN level, while GST returns are per GSTIN. So, you will extract figures (turnover, tax, ITC) for each GSTIN from your consolidated accounts. It is structured into five clear sections:

• Part I – Basic Details: Enter your GSTIN, financial year, legal name, trade name, and whether you are audited under any other law.
• Part II – Turnover Reconciliation: Compare turnover from audited books with figures in GSTR?9. Most audits are more comprehensive, so splitting by GSTIN may be needed. Optional detailed tables (5B–5N) were simplified by Notification?56/2019; now just use Table?5O if there is any difference.
• Part III – Tax Paid Reconciliation: Report GST due and paid at each tax rate, comparing values in books vs GSTR?9. Any mismatch or extra tax due must be highlighted.
• Part IV – Input Tax Credit (ITC) Reconciliation: Match ITC claimed in GSTR?9 with ITC reflected in audited statements. You also need a breakdown of total ITC availed (eligible vs ineligible) and reconcile any reversal. Sections like Tables 12B, 12C, and 14 are optional per Notification?56/2019.
• Part?V – Auditor’s / Taxpayer’s Recommendation: Summarise any additional tax or interest due to reconciliation mismatches. This section is now sealed in Part?B certification.

Part B – Verification / Certification

Though not shown on the form for FY?2020?21, certification remains mandatory. It comes in two flavours:

• By the auditor who conducted the audit
• By another CA if different from the auditor

It confirms that books and GST returns agree and notes any qualifications.

Key Updates in GSTR?9C Format & Filing

Let us discuss the key updates in the GSTR-9C format & filing:

• Self-Verification Replaces CA/CMA Certification

From FY 2020–21 onwards, businesses can self-certify their GSTR?9C form—no need for a Chartered or Cost Accountant’s stamp. This change, introduced by the 2021 Finance Act, reduces cost and speeds filing, though accuracy remains crucial.

• Mandate to File All GST Returns

To complete GSTR?9C, you must have filed GSTR?1, GSTR?3B, and GSTR?9 for every month of the year. This ensures the reconciliation covers consistent, full-year data.

• Pay Additional Tax via Form DRC?03

If reconciliation shows extra tax is due, GSTR?9C now lets you pay immediately through DRC?03, selecting “Reconciliation Statement” in the drop-down, and settling via your electronic cash ledger.

• Removal of Old Part?B Certification Format

Previously, Part?B had to be signed by the same or a different CA/CMA who carried out the audit. From FY 2020–21, this requirement is completely eliminated.

Why These Changes Matter

• Simplifies Compliance: No audit certification cuts fees and paperwork for eligible businesses.
• Speeds Up Filing: Self-verification lets responsible parties complete reconciliation directly.
• Improves Accuracy: Immediate tax payment through DRC?03 ensures clean, up-to-date filings.
• Encourages Full Compliance: Mandatory filing of all monthly returns prevents data gaps.

GSTR?9C is more than just a form, but a powerful tool to ensure accuracy, transparency, and trust in your GST compliance. By reconciling annual returns with audited records, it protects businesses from errors, penalties, and future disputes. With self-certification making the process simpler, filing GSTR?9C on time not only keeps you legally safe but also strengthens your financial credibility. In this blog you learn about GSTR-9C in detail, along with its documents, applicability, due date and turnover limit. Contact Online Legal India to get assistance and support in filing a GSTR-9C from professional experts.

FAQ

1. What is GSTR?9C?

GSTR?9C is a yearly GST reconciliation form that matches your annual GST return with audited financial statements to ensure accuracy and compliance.

2. Who needs to file GSTR?9C?

Businesses with an annual turnover above the prescribed limit (currently ?5?crore) must file GSTR?9C along with their annual GST return.

3. Is CA/CMA certification still required for GSTR?9C?

No. From FY?2020?21 onwards, GSTR?9C can be self?certified by the taxpayer. External CA/CMA certification is no longer mandatory.

4. What happens if there are mismatches in GSTR?9C?

Any extra tax liability found during reconciliation must be paid immediately through Form DRC?03 using your electronic cash ledger.

5. When is the due date for filing GSTR?9C?

It must be filed by December?31 of the year following the relevant financial year, along with GSTR?9.