Annual Return: GSTR-9 (and GSTR-9C if applicable)

As a GST-registered business, filing your monthly or quarterly returns (GSTR-1, GSTR-3B) is a routine. However, the annual GST returns – GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) – are crucial for a comprehensive reconciliation of your entire year’s GST activities. These filings ensure full transparency, rectify past errors, and finalize your GST compliance for the financial year. At Account Assure, a leading Financial Audit Firm, we provide expert services for accurate preparation and timely filing of GSTR-9 and GSTR-9C, safeguarding your business from discrepancies and potential audits.

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GSTR-9

GSTR-9 is an annual GST return return filed by 31st December of the year following the particular financial year. GSTR-9 return contains sales, purchases and GST charged and paid on the same during the financial year. Registered taxpayers under GST must file GSTR-9 if their annual turnover limit exceeds Rs. 2 crores.

GSTR 9 is an annual return to be filed yearly by taxpayers registered under GST. Points to note:

It consists of details regarding the outward and inward supplies made/received during the relevant financial year under different tax heads i.e. CGST, SGST & IGST along with the cess and HSN codes.
It is a consolidation of all the monthly/quarterly returns (GSTR-1, GSTR-2A, GSTR-2B, and GSTR-3B) filed in that year. Though complex, this return helps in extensive reconciliation of data for 100% transparent disclosures.

GSTR 9 applicability: Who should file GSTR-9 annual return?

All GST registered taxpayers must file their GSTR 9. However, the following are NOT required to file GSTR 9:

Taxpayers opting composition scheme (They must file GSTR-9A)
Casual Taxable Person
Input service distributors
Non-resident taxable persons
Persons paying TDS under section 51 of CGST Act
person collecting TCS under section 52 of CGST Act

What is GSTR 9 due date?

GSTR 9 last date for FY 2024-25 is 31st December 2025. GST annual return due date or GSTR-9 due date is 31st of December of next year for a particular financial year.

GSTR 9 filing steps

GSTR 9 filing steps can be summarised as follows-

Finish the filing of GSTR-1 and GSTR-3B to date, especially for FY 24-25.

Perform an in-depth ITC reconciliation and sales reconciliation from begining of the financial year to date.

Communicate with the vendors and customers about any gaps found upon reconciliation.

Make disclosures related to FY 24-25 in the form in the government’s offline tool or even better by using any cloud-based software such as Clear for easy auto-fills and end-to-end filing!

Pay via DRC-03 any short payment of tax or excess ITC claims identified for FY 24-25.

File the GSTR-9 on the GST portal.

GSTR-9C

What is it: This is a statement of reconciliation between the annual turnover as declared in the audited annual financial statements and the turnover as declared in the annual return (GSTR-9) for a financial year. It also reconciles the Input Tax Credit declared in the annual return (GSTR-9) with the ITC as per the audited annual financial statement.

Purpose: It aims to highlight any differences between the GST returns and the company’s books of accounts, facilitating transparency and detecting discrepancies that could impact tax liability. It essentially acts as a bridge between financial accounting and GST reporting.

GSTR-9C applicability and GSTR-9C turnover limit

As per CBIC notification no. 30/2021 dated 30th July 2021, every registered person under GST whose turnover during a financial year exceeds the prescribed GSTR-9C turnover limit of Rs.5 crore satisfies the GSTR-9C applicability condition to file this statement.

Further, as per CBIC’s CGST notification no. 09/2020 dated 16th March 2020, all foreign companies which are in the airline business and compliant with the relevant provisions and rules of the Companies Act 2013 are exempted from the GSTR-9C requirement.

In addition to the above, persons who are non-residents and are providing OIDAR service in India to unregistered persons have been exempted from submitting GSTR-9 and GSTR-9C as per CBIC notification no. 30/2019 dated 28th June 2019.

^The limit is enhanced to Rs 5 crore for the GSTR-9C of FY 2018-19, FY 2019-20, FY 2020-21, FY 2021-22 and FY 2022-23 as per the CBIC notifications.

What is the due date for GSTR-9C?

The due date to file GSTR-9C is the same as due date for submitting the Annual returns in GSTR-9. Hence, the GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant FY under audit. The due date can be extended by the Government if deemed necessary. For instance, the GSTR-9C due date for FY 2024-25 is 31st December 2025.

Contents and format of GSTR-9C

The GSTR-9C consists of two main parts:

Part-A: Reconciliation Statement

The figures in the audited financial statements are at PAN level. Hence, the turnover, Tax paid and ITC earned on a particular GSTIN (or State/UT) must be pulled out from the audited accounts of the organisation as a whole.

The Reconciliation Statement is divided into five parts as follows:

Part-I: Basic details

Consists of FY, GSTIN, Legal Name and Trade Name. The taxpayer must also mention if he is subject to audit under any other law.

Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9)

This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that most often, the Audited Financial statements are at a PAN level.

This might require the break up of the audited financial statements at GSTIN level for reporting in GSTR-9C. Details of turnover adjustments to be made in tables 5B to 5N have been made optional, and adjustments, if any, which are required to be reported can be reported in Table 5O by the taxpayer. This update is as per Notification No: 56/2019 issued on 14th November 2019.

Part-III: Reconciliation of tax paid

This section requires GST rate-wise reporting of the tax liability that arose as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to unreconciled differences noticed upon reconciliation.

Part-IV: Reconciliation of Input Tax Credit (ITC):

This part consists of the reconciliation of input tax credit availed and utilised by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement.

Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any.

A Taxpayer has the option to not fill details of ITC reconciliation in tables 12B, 12C and 14. This update is as per Notification No: 56/2019 issued on 14th November 2019.

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