GSTR 9C is an annual audit form for all the taxpayers having a turnover above 2 crores in a particular financial year. It includes a reconciliation statement for a particular FY to be filed by taxpayers on or before 31st December. GSTR 9C form has a reconciliation statement for reconciling turnover, input tax credits and tax payments.

Let’s see in brief about GSTR 9C:

Structure of reconciliation statement under GSTR 9C

The reconciliation statement is required to be prepared in two parts:-

• Part A is the reconciliation statement
• Part B is the certification by the chartered accountant or the cost accountant who has drawn the Part A.

Let us understand both the parts in detail:

Part A – Reconciliation Statement

This part if further subdivided into 5 parts as discussed below:

1. Part-I Basic details

It seeks the basic details about the registered person i.e. FY, GSTIN, legal name, trade name. In addition, it also requires mentioning as to whether the registered person is liable to be audited under any other Act and if yes, the reference to that Act has to be specified.

2. Part II

This part requires the reconciliation of turnover declared in an audited financial statement with the turnover declared in Annual return (GSTR 9).

• Table 5 – Need to provide reconciliation between Gross turnover and need to mention un-reconciled turnover
• Table 6 – Auditor need to explain reason of un-reconciled gross turnover
• Table 7 – Need to provide reconciliation between taxable turnover and need to mention un-reconciled turnover as declared in the audited annual financial statement with the GSTR-9 taxable turnover. The difference between Table 5 and Table 7 is that in case of Table 5, the reconciliation is between gross turnover (which includes taxable as well as non-taxable turnover) whereas Table 7 provides for reconciliation between taxable turnover.
• Table 8 – Need to explain reason of un-reconciled taxable turnover

3. Part III

This part deals with the reconciliation of taxes paid

• Table 9 – Need to provide reconciliation of rate wise liability and the amount payable thereon. The turnover in the audited annual financial statement may be liable to tax at different rates. There is need to provide details of taxable value and tax payable for goods or services supplied at various rates. This amount is required to be compared with the total turnover and tax liability declared in the Annual Return.
• Table 10 – Auditor need to explain the reasons for un-reconciled payment of amount.
• Table 11 – This table is summary of the additional amount payable. The tax declared under this table has to be paid in cash.

4. Part IV

This part deals with reconciliation of Input Tax Credits as per books of account and ITC as declared in the Annual Return.

• Table 12 – Need to provide reconciliation of net input tax credits as per audited annual financial statements for the GSTIN and Input Tax Credit availed in the GSTR-9 suitably adjusted for the credits pertaining to the one financial year availed in different financial year. The difference between the two is un-reconciled ITC.
• Table 13 – Need to provide reasons for un-reconciled ITC has to be declared
• Table 14 – This table requires submission of details as to the credits availed on various categories of expenses as per audited annual financial statement or books of account. This detail has to be reconciled with the credits availed in the GSTR-9
• Table 15 – Need to provide a reason of the difference in credits arrived under Table 14 have to be reported under this table.
• Table 16 – Auditor need to comment upon the tax payable on un-reconciled differences in ITC which has arisen in table 13 and Table 15.

5. Part V

Auditor needs to recommend additional liability arising due to non-reconciliation. The additional liability has be mentioned separately under various categories of rates of tax, input tax credits, interest, late fees, penalty, any other amount not included in the GSSTR-9, erroneous refund to be paid back and outstanding demands to be settled.

Part B: Auditor Certification

This part provides the format of certification by the auditor. The Format I is applicable when the certification is done either by the chartered accountant/cost accountant who had conducted the audit whereas Format II is applicable where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other than the person who had conducted the audit of the accounts.

So, while GSTR9 is your annual return, GSTR9C is more of an audit certification. Read our blog on GSTR 9 and GSTR9C for more details.

Changes Related to GSTR 9C Self-Certification

As per the Finance Act – 2021, a proposal was released to omit certification by CA by amending Section 35(5) of the CGST Act. In the 43rd GST Council Meeting, the finance ministry suggested changes in furnishing the reconciliation statement in order to simplify the compliance requirement. These changes suggested that taxpayers would be able do GSTR-9C self-certification instead of getting it certified by chartered accountants. This change will apply for Annual Return for FY 2020-21. Amendments in sections 35 and 44 of CGST Act made through Finance Act, 2021.

The GST Notification 29/2021 stated: “w.e.f. 1st August, Section 35(5) of the CGST Act which mandated the certification of GSTR-9C by the Chartered Accountant or a Cost Accountant is substituted by Sec 44 of the CGST Act which requires a self-certified reconciliation statement in place of an audit report.”

• As per the 43rd GST Council meeting held on 28^th May 2021, GSTR-9 shall continue to be optional for taxpayers with turnover up to Rs.2 crore
• GSTR-9C for FY 2020-21 will be required to be filed by taxpayers with annual aggregate turnover above Rs 5 Crore.
• Taxpayers would be able to self-certify the reconciliation statement in GSTR 9C, instead of getting it certified by chartered accountants. This change will apply for Annual Return for FY 2020-21.
• CBIC issued Notification No. 16/2020dated 23rd March 2020 to revise GSTR 9C turnover threshold limit to Rs. 5 Cr. For F.Y. 2018-19 & onwards.
• Also as per notification 56/2019 dated 14^th Nov 2019 below details made option to fill up:
  • Option to not fill table 5B to 5N. If there are any turnover adjustments required to be reported then the same may be reported in Table 5O.

Option to not fill tables 12B and 12C [ITC adjustments for booked earlier but claimed in the current year or booked in the current year but to be claimed in a subsequent year].