As per Section 44 of the CGST Act (not Section 35), Form GSTR-9C is a reconciliation statement linked to the GSTR-9 Annual Return. While GSTR-9 must be filed by all regular GST-registered taxpayers with aggregate turnover exceeding ₹ two crore, filing is optional for those below this threshold.

Businesses with an annual turnover exceeding ₹5 crore are mandated to file GSTR-9C, which reconciles the data in GSTR-9 with the audited financial statements. A valid GSTIN (Goods and Services Tax Identification Number) is required to file both GSTR-9 and GSTR-9C.

As per the Finance Act 2021 and CBIC Notification No. 30/2021-CT dated 30.07.2021, GSTR-9C is now a self-certified statement. The earlier requirement for attestation by a Chartered Accountant or Cost Accountant has been removed from FY 2020-21 onwards.

Read on to explore the complete process for filing GSTR-9C and understand the latest compliance rules.

GSTR 9C is a statement of reconciliation that every business with a yearly turnover over ₹5 Cr has to file at the GST portal. By filling up this form, a business is required to declare and pay the differences between the audited financial statement report and the annual returns filed for the financial year.

It is mandatory to submit the GSTR 9C form by 31st December of each year, i.e. by the end of a fiscal year.

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As per the GST law, the following are the eligibility criteria for filing GSTR 9C:

• The individual or business must be GST-registered.
• Any individual or business with a gross turnover exceeding ₹5 Cr is obligated to file the GSTR 9C form.
• An individual or business with a gross turnover not exceeding ₹5 Cr may file the GSTR 9C form. However, it is not mandatory in such cases.

Note: Composition taxpayers, non-resident taxpayers, and OIDAR service providers to unregistered persons are exempted from filing GSTR-9C.

A registered taxpayer can file the GSTR 9C form either by visiting a facilitation centre or visiting the online GST portal for the same. Learn about how to file GSTR 9C step by step. Follow the steps mentioned below:

Step 1: Visit the official Goods and Services Tax (GST) portal of the Government of India.

Step 2: Click on the Login icon in the top right corner.

Step 3: Enter your login credentials and hit the LOGIN button.

Step 4: The next page will take you to the dashboard, which should display your Ledger Balance. Go to the Services tab on the toolbar, followed by Returns and Annual Returns.

Step 5: Select the fiscal year for which you are willing to file the GSTR 9C and click on SEARCH.

Step 6: It will lead you to the next page. Read all the instructions carefully and find the tab titled Reconciliation Statement GSTR 9C. Click on the INITIATE-FILING button.

Step 7: Now, a form will open in the next window where you can enter all the relevant details as prompted on the website.

Instead of clicking on the INITIATE-FILING button in Step 6, you can click on the PREPARE OFFLINE button. It will lead you to download a spreadsheet-based comprehensive offline tool to file your GSTR 9C. After filling out the form, you can submit it in the GST portal using the above-mentioned method.

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There are a few guidelines for filing the GSTR 9C reconciliation form. GSTR 9C information and rules are circulated and enforced by the GST Council of India:

• From FY 2020-21 onwards, audit certification by a Chartered Accountant or Cost Accountant is no longer mandatory. The form can be filed with self-certification by the taxpayer.
• GST audit must not be performed by an internal auditor of a business (for previous audit years).
• The GST auditor (where applicable) shall be appointed by a business at the beginning of a fiscal year.
• Only a registered Chartered Accountant and/or a Cost Accountant were earlier qualified to submit an audit report, this requirement has now been waived by the government.

To file GSTR 9C, a person must carry the following documents:

• Balance sheet audited by certified Chartered Accountant or Cost Accountant.
• Cash flow sheet.
• Profit and loss statement of income and expenditure amount.
• Other relevant financial reports.

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• There are no government charges levied by the GST Council or CBIC for filing Form GSTR-9C.
• However, taxpayers may incur professional fees if they choose to engage a Chartered Accountant (CA) or Cost Accountant (CMA) for preparing or reviewing the reconciliation statement.
• Since FY 2020-21 onwards, GSTR-9C is a self-certified form, and attestation by a CA/CMA is no longer mandatory. This change was introduced via the Finance Act 2021 and subsequent CBIC notifications.
• Therefore, while there are no statutory filing fees, any costs incurred are related to professional services or internal audit processes, if opted by the business.

Notes: Late fees may apply if GSTR-9C is filed after the due date (usually 31st December following the financial year).

Knowing about GSTR 9C allows taxpayers to reconcile and declare the inconsistencies in their audit reports and returns filed for a fiscal year. It affords the following benefits –

• Allows businesses to self-certify cumulative revenue.
• Verifies the company balance sheet and reduces the chances of misreporting.
• Keeps track of each transaction to establish a transparent relationship between the taxpayers and the government.

If your business’s annual revenue exceeds ₹5 Crore, you must know how to file GSTR 9C. All GST-registered taxpayers are eligible to submit GSTR 9C audit form. Failure to comply with the regulations will incur the following penalties:

• Non-filing of GSTR 9C can result in a general penalty of ₹25000.
• Non-filing of both the Annual Return and GSTR 9C audit form will incur a ₹200 penalty for each day of the default.
• Non-filing of GSTR 9-C even after one year from the due date leads to a penalty of ₹50 (CGST and SGST combined) for each day of the delay.

However, please note that the penalties are capped to a maximum of 0.5% of the taxpayer’s total fiscal turnover.

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