GSTR 9 Vs GSTR 9C, which One should You Prepare this Year

GSTR 9 vs GSTR 9C is a discussion going in the GST lobby since the forms were announced and new taxpayers sometimes still remain perplexed about the applicability of the form type to them. Should they be filing GSTR 9 or GSTR 9C or both? And who is to file what?

This article throws light on the base logic behind the two forms and helps you decide which one is for you.

To start with, an annual return is a statement of return which is required to be filed annually by each registered person (except a few specified categories of persons) under GST giving summarized details of outward supply and taxes paid thereon, input tax credit claimed, taxes paid and GST refund claimed in the financial year in respect of which such monthly/quarterly returns are filed. This annual return has to be filed annually with the GSTN using form GSTR 9.

For all the updates regarding GSTR 9 Due-date extension, please refer to this article: FAQs Around GST Annual Return

Now the form GSTR 9 in itself is categorized in various form types based on taxpayer entities.

Sr. No.	Annual Return	Applicability to Taxpayers
1	GSTR 9	All taxpayers other than those mentioned below in note 1
2	GSTR 9A	Taxpayer who applies for the composition scheme. (This form has been scrapped!)
3	GSTR 9B	Tax collector who files GSTR 8. Read Note 2 mentioned
4	GSTR 9C	Taxpayer whose aggregate turnover exceeds 2 cr. and needs to audit his accounts under GST

Who Need NOT file GSTR 9:

- Casual Taxable Person
- Non-Resident Taxable Person
- Input Service Distributor
- Composition Dealers
- Persons subject to TCS or TDS provision

Let’s have a brief comparison of GSTR 9 and GSTR 9C, their formats, applicability and variation in form types.

While GSTR 9 is an annual return form filing, GSTR 9C is essentially a reconciliation statement to be prepared by taxpayers whose aggregate turnover exceeds Rs. 2 crore and have undergone GST audit. So, ideally, GSTR 9C is dependent on preparation of your GSTR 9 return. Read more about GSTR 9C self certification.

An additional point to note here is that there are no revision provisions for the annual return yet. Hence, the return should be prepared with complete accuracy.

Basic differences between the two forms: GSTR 9 and GSTR 9C

Key Points	GSTR-9 Annual Return	GSTR-9C Reconciliation Statement
Nature	It is compilation /consolidation of all details provided in GST returns i.e. GSTR 1 and GSTR 3B made during financial year 2017-2018.	It is reconciliation between annual GSTR 9 return filed and audited annual financial statements
Applicable to	As per Legal provision of Section 44(1) of CGST Act, every registered person shall be required to file GSTR-9. Hence, irrespective of the Turnover, every registered person under GST is required to file GSTR-9.	Every registered person, whose aggregate turnover during a financial year exceeds the prescribed limit of Rs. 2 Crore, shall get his accounts audited by a chartered accountant or a cost accountant and need to file GSTR 9C.
Not applicable to	Casual Taxable Person Non-Resident Taxable Person Input Service Distributor Input Service Distributor Composition Dealers	Those who are not applicable to file GSTR-9 And also a registered person whose aggregate turnover in an FY is less than INR 2 Cr.
Due date for filing	31st December of the subsequent financial year E.g. 31st December 2018 for FY 2017-18 This due date extended till 30th June 2019 (Order No.03/2018-Central tax)	31st December of the subsequent financial year E.g. 31st December 2018 with or after filing GSTR-9 for FY 2017-18 This due date extended till 30th June 2019 (Order No.03/2018-Central tax)
Late fees &	As per section 47(2) of CGST Act, Late fee for belated filing of GSTR-9 is Rs.100 per day	In a situation where a registered person files only GSTR 9, but fails to file GSTR 9C, the filing of GSTR 9C is not considered to
penalty	subject to maximum of 0.25% of turnover in a state/UT. Similar provision is there in SGST Act also. Hence, in total there will be late fee of Rs.200 per day subject to 0.50% of turnover in a state on late filing of GSTR-9.	have been defaulted. However, For GSTR 9C there may be consequences of default in complying with the provisions of Section 44(2).
Additional Tax liability	Additional liability for the FY 2017-18 not declared in FORM GSTR-1 and FORM GSTR-3B may be declared in this return. (As per Notification 74/2018 dt 31/12/2018 )	In GSTR 9C, GST auditor need to mention additional tax liability arise and it’s reasons of arise.
Payment of additional Tax liability	Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ?Annual Return? in the drop down provided in FORM DRC-03. It may be noted that such liability can be paid through electronic cash ledger only (As per notification 74/2018 dt 31-12-2018)	Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ?reconciliation statement in the drop down provided in FORM DRC-03. It may be noted that such liability can be paid through electronic cash ledger only(As per notification 74/2018 dt 31-12-2018)
Availed ITC	Taxpayers cannot claim input tax credit unclaimed during FY 2017-18 through this return.	ITC cannot be availed through GSTR 9C
Details need to provide in Return	Details of the outward supplies, inward supplies on which tax is payable, ITC and tax paid, late fees as per the GST returns filed between July 2017 and March 2018 Along with its amendments made between April 2018 and September 2018. Declaration of demands/ refunds, supplies from composition dealers, Job works, goods sent on an approval basis HSN wise summary of outward Supplies HSN summary for inward supplies. Here for inward supplies need to consider only which in value independently account for 10% or more of total value of inward supplies (As per notification no 74/2018 dt 31/12/2018) • Late fees payable is required.	Part-A -Reporting of reconciliation needed between turnover, tax paid and ITC. Report on Auditor’s recommendation of any additional tax liability. Part -B -Certificate by GST Auditor/ CA/ CMA
Return Mandatory	It is mandatory to file all your FORM GSTR-1 and FORM GSTR-3B for the FY 2017- 18 before filing this GSTR 9 return. The details for the period from July 2017 to March 2018 are needed to be provided in this return.	GSTR 9 is mandatory to file before filing of GSTR 9C
Annexures	No annexures to be attached	Annexure of Audited financial statement is required

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