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Understanding the Difference Between GSTR-9 and GSTR-9C

Writer's picture: Rashmita ChoudharyRashmita Choudhary

Comprehensive reports known as GST Annual Returns are submitted annually by taxpayers who have registered for GST. A financial year's worth of outgoing and inbound supply details, taxes paid, input tax credits claimed, and other pertinent financial data are compiled in these filings. Since CBIC released the GSTR-9 and GSTR-9C forms, there has been an ongoing misunderstanding over who is required to file them and whether the information needed for both is the same. You can quickly compare GSTR-9 with GSTR-9C in this post.

 

Table of content

 

What is GSTR-9?

Taxpayers who are registered under GST are required to file the GSTR-9 return each year. It includes information about the supplies that were sent and received during the relevant fiscal year under various tax heads, such as CGST, SGST, IGST, and HSN codes. All of the quarterly and monthly returns (GSTR-1, GSTR-2A, and GSTR-3B) submitted throughout that year are combined into it. Despite its complexity, this return aids in thorough data reconciliation for disclosures that are 100% transparent.

GSTR-9 must be filed by all normal taxpayers who have submitted their monthly or quarterly returns, including developers and those holding SEZ units. Information on inbound and outgoing supplies, input tax credits claimed, taxes paid, and other declarations are all included in GSTR-9. December 31st of the year after the fiscal year being reported is the filing deadline.


What is GSTR-9C?

On September 13, 2018, the audit form known as GSTR 9C was introduced. Taxpayers with a yearly turnover of more than two crores are required to file it, and a certified chartered accountant must certify it. In essence, it serves as a reconciliation statement between the taxpayer's audited yearly financial accounts and the annual returns submitted in GSTR-9.

After combining all of the taxpayers' GST returns for the fiscal year, the form will include the gross and taxable turnover as reported in their accounting books, reconciled with the corresponding figures, and any discrepancies found during the reconciliation. The distinction and the rationale behind it have to be made clear. For each GSTIN, a GSTR-9C has to be issued.


Difference Between GSTR-9 and GSTR-9C

 

GSTR-9

GSTR-9C

Type

An Annual Return

A Reconciliation Statement

GST Act 

Section 44(1) of the CGST Act

Section 35(5) of Section 44 of the CGST Act

Applicability

To be filed by all Registered Taxpayers under GSTTurnover up to Rs. 2 Cr – OptionalRs. 2Cr. – Rs. 5 Cr – MandatoryMore than Rs. 5Cr – Mandatory

To be filed if the turnover in an FY exceeds Rs 2CrTurnover up to Rs. 2 Cr – N/ARs. 2Cr. – Rs. 5 Cr – OptionalMore than Rs. 5Cr – Mandatory

Exceptions

  • Composition Dealers

  • Casual Taxable Person (CTP)

  • Input Service Distributor (ISD)

  • Non-Resident Taxable Person (NRTP)

  • Unique Identification Number (UIN) holders 

  • Persons subject to TCS or TDS provisions

  • Online Information and Database Access Retrieval (OIDAR) Service providers 

Persons mentioned under the column for GSTR-9 along with registered persons whose aggregate turnover in financial year is less than Rs.5 crore

Signature

Digitally signed by the registered taxpayer.

Digitally signed by the GST Auditor (CA/CMA). However, there is no such requirement now.

Threshold

No threshold

Subject to a threshold

Annexures

Financials need not be annexed

Financials need to be annexed

 Timeline 

Must be filed before GSTR-9C

GSTR-9C must follow the GSTR-9 annual return

Due date

31st December of the next FY

31st December of the next FY (with or after filing GSTR-9)

Return to be filed

On GST portal/through facilitation centre

On GST portal/through facilitation centre at the time of or after filing GSTR-9

Return format

Consolidated detailed summary of:

  • Turnover

  • ITC and tax paid

  • Late fees paid in GST returns filed during the financial year

  • Amendments made between April to 30th November of next financial year

The following must also be declared wherever applicable: 

  • Supplies from composition dealers

  • Job works

  • Demands/ refunds

  • Late fees payable

  • Goods sent on an approval basis

  • HSN wise summary of purchases and sales 

Part-A: Reconciliation of turnover, tax paid, and ITC must be reported. Report on any additional tax liabilities suggested by the auditor. 

Part B: CFO/Finance head self-certification.


Late fees

Minimum: 

  • Rs 50 daily (Rs 25 each under CGST and SGST Act) for turnover below Rs. 5 cr

  • Rs 100 (Rs 50 each under CGST and SGST Act) for turnover of Rs. 5- 20 cr

  • Rs 200 (Rs 100 each under CGST and SGST Act) for turnover more than Rs. 20 cr



Maximum: Can be a quarter per cent of the taxpayer turnover

As per Section 125 of CGST Act, 2017, a penalty of up to Rs 25,000 is applicable for not getting the accounts audited


Conclusion

Businesses must comprehend the subtleties of GSTR-9 and GSTR-9C in order to maintain compliance, maximise their tax positions, and stay out of trouble. Businesses can more successfully negotiate the difficulties of GST yearly returns and audits by implementing best practices, utilising technology, and remaining up to date on GST laws.


FAQ

Q1. Are Forms GSTR-9 and GSTR-9C different in any way? 

Yes, the difference between the two forms is that GSTR-9 must be provided by every regular taxpayer. On the other hand, assessees with an annual turnover of Rs 2 cr or more for that fiscal year are required to produce Form GSTR 9C. According to section 44(2) of the CGST Act, the assessee must have their account audited by a certified public accountant (CA) and provide a copy of the audited annual accounts and reconciliation statements in GSTR-9C.


Q2. What fields in the GSTR-9C get auto-populated from Form GSTR-9?

The following details get auto-populated from Form GSTR-9:

  • Turnover declared in GSTR-9

  • Taxable turnover according to the liability declared in GSTR 9 

  • Total tax liability paid according to GSTR-9

  • ITC claimed in GSTR-9


Q3. Who is liable to file GSTR-9 and GSTR-9C?

The yearly GST reconciliation statement form, GSTR-9C, is submitted by eligible taxpayers. This form must be submitted by any registered person whose total revenue for a fiscal year exceeds Rs. 5 crore. A copy of the audited yearly accounts must also be provided.


Q4. How do you reconcile GSTR-9 and 9C?

The purpose of GSTR-9C is to reconcile the amounts in the taxpayer's audited financial statements with the yearly GSTR-9 of a fiscal year. This reconciliation statement must be filed by any registered taxpayer whose turnover exceeds Rs. 5 crore in a fiscal year.


Q5. Can we file GSTR 9C without CA?

Form GSTR-9C must be self-certified, according to the CBIC's notification. Therefore, it is no longer necessary for a CA to certify it.


 
 
 

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