
Introduction
With the annual GST return filing deadline approaching, it’s time for businesses to turn their attention to GSTR-9 and GSTR-9C, two key returns required to complete the GST compliance process for the financial year.
These annual returns offer a complete summary of taxpayers’ transactions, tax liabilities, (ITC), and other vital information, aligning data reported throughout the year in monthly and quarterly returns.
Filing GSTR-9 and GSTR-9C accurately ensures that a business remains compliant, avoiding potential penalties and audit complications in the future.
Whether a business has straightforward transactions or complex supply chains, these returns provide a structured way to review, reconcile, and validate all GST-related data.
Let’s dive into the essentials of both forms, covering everything you need to know.
GSTR-9: The Comprehensive Annual Return
1. What is an Annual Return?
GSTR-9 is the annual return that provides a detailed summary of all transactions reported by a registered taxpayer over the financial year.
It consolidates information from monthly or quarterly returns, such as GSTR-1 (outward supplies) and GSTR-3B (tax paid and ITC claimed), into a comprehensive report.
This return enables businesses to verify that all reported data aligns with their records, offering an annual overview of the taxpayer’s total income, purchases, tax liability, and credits.
2. Who Needs to File GSTR-9?
Annual Return |
Furnished By |
GSTR 9 |
All registered persons excluding Casual Taxpayer Person, ISD, NRTP, Person registered for TDS/TCS |
GSTR 9A |
Composition Tax Payer |
GSTR 9B |
ECO (Not Yet Notified) |
GSTR 9/9A shall not be required to be filed if the turnover of the taxpayer does not exceed Rs 2 Crore.
3. Structure of GSTR-9
GSTR-9 consists of six main parts:
Part I – Basic Details: Contains general information like the financial year, GSTIN, legal name, and trade name.
Part II – Details of Outward and Inward Supplies: Summarizes all outward supplies (sales) and inward supplies (purchases) reported during the financial year, segmented by taxable, exempt, and non-taxable transactions.
Part III – ITC Details: Contains information about input tax credits claimed, reversed, or ineligible, segmented by credit type (e.g., import, domestic, etc.).
Part IV – Tax Paid: A consolidated summary of all taxes paid, including IGST, CGST, SGST, and CESS.
Part V – Adjustments from Previous Financial Year: Captures any transactions from the previous financial year that were adjusted during the current year.
Part VI – Other Information: This includes demands, refunds, HSN-wise summary of outward and inward supplies, and any late fees paid.
4. Key Points to Note
While GSTR-9 simplifies the annual compliance process, it requires accuracy, as discrepancies can lead to audit complications.
Taxpayers should review all sections to ensure they accurately capture ITC claims, tax liabilities, and adjustments.
GSTR-9C: Self-Certified Reconciliation Statement
1. What is GSTR-9C?
GSTR-9C is a self-certified reconciliation statement that acts as a reconciliation report that matches the information reported in GSTR-9 with the taxpayer’s financial statements.
2. Who Needs to File GSTR-9C?
All registered taxpayers with an annual turnover exceeding Rs. 5 crores are required to file self-certified GSTR-9C excluding casual taxable persons, ISD, NRTP, and Persons registered for TDS/TCS compliance.
This reconciliation provides an independent review, enhancing data accuracy and integrity.
3. Structure of GSTR-9C
GSTR-9C consists of five main sections:
Part I – Basic Details: Includes general information about the taxpayer, GSTIN, and trade name.
Part II – Reconciliation of Turnover: Reconciles the turnover reported in the financial statements with the turnover in GSTR-9.
Part III – Reconciliation of Tax Paid: Compares the tax payable as per the financials with the tax paid in GSTR-9.
Part IV – Reconciliation of ITC: Provides a reconciliation of ITC claimed and reported in GSTR-9 versus ITC as per books.
Part V – Additional Liability due to non-reconciliation: Details of additional liability to be paid in cash or ITC, with rate wise bifurcation.
4. Significance of GSTR-9C
GSTR-9C helps authorities verify that the GST data reported matches the audited financial statements, ensuring compliance and minimizing risks of errors, under-reporting, or potential fraud.
Key Changes and Updates for the Current Financial Year
Each financial year, the GST authorities may update forms or requirements.
Table-4
a.A new row labeled G1 has been added after row G, designated for reporting supplies under Section 9(5) by electronic commerce operators (ECOs).
b.The subtotal in row H has been revised to include amounts from rows A through G1.
Table-5
a.A new row labeled C1 has been introduced after row C, specifically for 9(5) supplies reported by the supplier.
b.The turnover calculation in row N has been adjusted to exclude the effect of ECO supplies captured under 4G1.
Table-6
The validation rule requiring equality between CGST and SGST values has been removed for rows 6K and 6L.
Table-7
The validation rule ensuring CGST and SGST values are equal has also been removed from this table.
Table-8
a)Starting from FY 2023-24, data in Table 8A will now be auto-filled using information from GSTR-2B, with the corresponding heading updated accordingly.
b)The heading for Table 8B has also been updated.
Challenges and Tips for Filing GSTR-9 and GSTR-9C
Filing GSTR-9 and GSTR-9C can be complex. Here are some common challenges and tips:
Reconciliation Issues: Many businesses face discrepancies when reconciling ITC between GSTR-3B and GSTR-2B. To avoid issues, regularly compare your ITC records with monthly filings.
Maintaining Accurate Records: Ensure that sales, ITC, and purchase data are accurately recorded. This helps in faster reconciliation and error-free filing.
Software and Automation: Consider using GST software for real-time reconciliation, especially for businesses with high transaction volumes. Automation minimizes manual errors, simplifies adjustments, and speeds up the reconciliation process.
Begin the filing process early to give enough time for any adjustments. Rushing near the deadline often leads to mistakes.
Penalties for Non-Compliance
Missing the deadline for GSTR-9 or GSTR-9C filing can result in penalties, including:
S.No |
Turnover limit |
Late fee per day |
Maximum late fee |
1 |
Up to Rs 5 crore |
Rs 50 (Rs 25 each under CGST and SGST Act) |
0.04% of turnover in state/UT (0.02% each under CGST and SGST Act) |
2 |
More than Rs 5 crore and less than Rs 20 crore |
Rs 100 (Rs 50 each under CGST and SGST Act) |
0.04% of turnover in state/UT (0.02% each under CGST and SGST Act) |
3 |
More than Rs 20 crore |
Rs 200 (Rs 100 each under CGST and SGST Act) |
0.50% of turnover in state/UT (0.25% each under CGST and SGST Act) |
According to Section 125 of the CGST Act, 2017, there is general penalty of Rs 25,000 for non-compliance. Since no specific penalty has been prescribed for late filling of GSTR 9C, general penalty shall apply.
Interest on Tax Payable: If there’s an outstanding tax, the taxpayer will be liable for interest on unpaid amounts.
Possible Audit and Compliance Issues: Delays in annual returns may impact the GST compliance rating, raising the risk of audits. This can affect the taxpayer’s reputation with authorities.
Conclusion
In conclusion, GSTR-9 and GSTR-9C are essential filings for GST compliance, providing a consolidated, annual overview of a business’s tax liability and reconciliation with its financials.
As the deadline approaches, businesses should ensure they have an accurate, complete record of their transactions and ITC to avoid compliance issues.
Don’t wait until the last minute—start preparing the annual return today.