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GSTR-9C- Reconciliation Statement

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GSTR-9C is a statement of reconciliation between the GST Annual Return filed in GSTR-9 and the figures as per the audited annual financial statements of the taxpayer. All the GST dealers who have an annual turnover above Rs. 2 Crores in a financial year will have to file GSTR-9C for that year. It should be prepared and certified by a Chartered Accountant or Cost Accountant and filed along with a copy of audited accounts and Annual Return in Form GSTR-9. The limit is enhanced to Rs. 5 Crores for FY 2018-19 as per notification dated 23rd March 2020

 

Due Dates for GSTR-9C:

 Due date of submitting GSTR-9C is on or before 31st December subsequent to the relevant financial year; however, the due date can be extended by the Government , if necessary

Presently, extended due dates for various financial years are as:

  • F.Y. 2017-18       : 5th & 7th February 2020 in staggered manner state-wise
  • F.Y. 2018-19         : 30th June 2020

Step by Step Procedure of GSTR-9C- Reconciliation Statement

STEP 1

Submission of relevant documents and figures by you for filing of GSTR-9C

STEP 2

Verification of documents by our associate or team leader

STEP 3

Preparation of GSTR-9C

STEP 4

Online submission of GSTR-9C along with GSTR-9

STEP 5

Providing you with a copy of return and acknowledgement

Frequently Asked Question

What is the penalty for late filing of GSTR-9C?

There is no specific provision for penalty or late fees for delayed filing for GSTR-9C. However, there is a general penalty of Rs. 25,000. So, the defaulting taxpayer may be asked by the assessing officer to pay a general penalty of Rs. 25,000

What are the documents required to be filed along with GSTR-9C?

The registered person is required to submit electronically a copy of:-

  • Audited Financial Statements of the entity
  • Annual Return in Form GSTR-9
  • Reconciliation statement duly certified, reconciling the value of supplies declared in the Annual Return along with the audited financial statements and
  • Such other particulars as may be prescribed

Can GSTR-9C be revised?

There is no provision for revision of GSTR-9C at present

How to ascertain the turnover for ascertainment of applicability of GSTR-9C?

Aggregate turnover means the aggregate value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same Permanent Account Number, to be computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess

Does stock transfer made between two branches having different GSTIN will be included in the Aggregate Turnover?

Yes, the definition of Aggregate Turnover clearly mentions that supplies made between two distinct persons having the same Permanent Account Number will be included in the aggregate turnover. Thus stock transfer provided from a branch located in one state to a branch located in another state will be included in the aggregate turnover of the branch supplying the goods or services

Whether Non-GST supplies will be included in the turnover or not?

Non-GST supplies includes supply of alcoholic liquor for human consumption, motor spirit (commonly known as petrol), high speed diesel, aviation turbine fuel petroleum crude and natural gas and transactions specified in Schedule III of the CGST Act

All above are part of the exempt supplies and the definition of aggregate turnover includes exempt supplies

Whether supplies made between the period April 2017 to June 2017 will be include in the turnover to determine the eligibility for filling of GSTR-9C?

As per the latest Clarification regarding Annual Returns and Reconciliation Statement dated 03/07/2019, the aggregate turnover for this purpose shall be reckoned for the period July, 2017 to March, 2018

To determine the limit of aggregate turnover of Rs.2 Crore, GSTIN wise turnover has to be checked?

It may be noted that the aggregate turnover i.e. the turnover of all the registrations having the same Permanent Account Number is to be used for determining the requirement of filing of reconciliation statement. Therefore, if there are two registrations in two different States on the same PAN, say State A (with turnover of Rs. 1.5 Crore) and State B (with turnover of Rs. 1 Crore) they are both required to file reconciliation statements individually for their registrations since their aggregate turnover is greater than Rs.2 Crore

Can the Internal Auditor of the registered person certify FORM GSTR-9C?

An internal auditor cannot certify FORM GSTR-9C as per the instructions issued by ICAI

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