In India’s Goods and Services Tax (GST) regime, businesses are required to file periodic returns summarizing their supply transactions, tax payments, and input tax credits (ITC) availed. Among the various returns filed under GST, two critical ones that reflect a company’s annual financial activities are GSTR-9 and GSTR-9C.
Both GSTR-9 and GSTR-9C serve different purposes but play an integral role in ensuring that businesses comply with the GST laws. This guide will help you understand what GSTR-9 and GSTR-9C are, their applicability, due dates, differences, and recent changes that taxpayers need to be aware of.
What is GSTR-9?
GSTR-9 is the annual return that all regular taxpayers registered under GST must file. It provides a summary of all the outward and inward supplies made and received throughout the financial year. In essence, GSTR-9 consolidates all the monthly or quarterly returns filed by the taxpayer, such as GSTR-1 and GSTR-3B, into one comprehensive document for a particular financial year.
Key Features of GSTR-9:
- Annual Return: GSTR-9 serves as a compilation of all the GST returns filed during the year, showing a complete picture of a taxpayer’s activities.
- Self-Filed: The taxpayer is responsible for filing GSTR-9, ensuring that all data reported is accurate and consistent with monthly/quarterly filings.
- No Additional Taxes: GSTR-9 does not impose any additional tax liability; instead, it serves to validate the accuracy of past returns.
- Auto-Population of Data: Certain data in GSTR-9, like outward and inward supplies, are auto-populated from GSTR-1, GSTR-3B, and GSTR-2A.
Applicability of GSTR-9
A. Who should file? All regular taxpayers registered under GST, including businesses, professionals, and service providers.
B. Who is exempt? The following categories are not required to file GSTR-9:-
- Taxpayers registered under the Composition Scheme (who file GSTR-9A instead).
- Input Service Distributors (ISD).
- Casual taxable persons.
- Non-resident taxable persons.
- Persons liable to deduct tax at source (TDS) under GST.
What is the due date for GSTR-9
The due date for filing GSTR-9 is 31st December following the end of the financial year.
For example, for the financial year 2023-24, the filing deadline is 31st December 2024.
What are the Components of GSTR-9
GSTR-9 contains six parts, each designed to capture different aspects of a business’s GST activity throughout the year:-
Part I: Basic details such as GSTIN, legal name, and trade name.
Part II: Details of outward and inward supplies made during the financial year. This includes the taxable value, tax liability, and exemptions availed.
Part III: Input tax credit (ITC) details. This section covers ITC claimed, reversed, or declared during the year.
Part IV: Taxes paid under different heads like IGST, CGST, and SGST.
Part V: Details of transactions pertaining to the previous financial year that were reported in the current financial year.
Part VI: Miscellaneous information such as demands, refunds, late fees, supplies received from composition taxpayers, and more.
What are the Late Fees for GSTR-9?
If GSTR-9 is not filed within the stipulated deadline, a late fee of ₹100 per day per Act (i.e., ₹100 for CGST and ₹100 for SGST, totaling ₹200 per day) will be levied. The maximum penalty is 0.25% of the taxpayer’s turnover in the relevant state or Union Territory.
What is GSTR-9C?
GSTR-9C is a reconciliation statement that must be filed by taxpayers whose annual turnover exceeds ₹5 crore. This form serves as a GST audit and requires taxpayers to reconcile their annual return (GSTR-9) with their audited financial statements. It must be certified by a Chartered Accountant (CA) or Cost Accountant, ensuring that the reported data matches the company’s financial records.
Key Features of GSTR-9C
- Reconciliation Statement: GSTR-9C reconciles the details submitted in GSTR-9 with the taxpayer’s audited financial statements.
- Audit Requirement: GSTR-9C is essentially an audit form, confirming that the financial statements and the GST returns are consistent.
- Certification: This form must be certified by a CA or Cost Accountant, ensuring that the data is accurate and complete.
What is the Applicability of GSTR-9C?
- Who should file? Taxpayers with an annual turnover exceeding ₹5 crore must file GSTR-9C along with GSTR-9.
- Who is exempt? Businesses with a turnover of less than ₹5 crore are not required to file GSTR-9C, as this reconciliation is not mandatory for them.
Due Date for GSTR-9C
GSTR-9C must be filed by 31st December following the end of the financial year, along with GSTR-9.
What are the Components of GSTR-9C?
Part A: Contains reconciliation of turnover declared in GSTR-9 with the turnover in the audited financial statements, tax liability reconciliation, and input tax credit reconciliation.
Part B: Certification by the auditor (CA or Cost Accountant), verifying that the reconciliation and other statements are true and accurate.
Key Differences Between GSTR-9 and GSTR-9C
| Aspect | GSTR-9 | GSTR-9C |
|---|---|---|
| Purpose | Annual return summarizing inward and outward supplies, ITC, and tax payments. | Reconciliation of GSTR-9 with audited financial statements. |
| Applicability | Applicable to all regular taxpayers registered under GST. | Mandatory for taxpayers with turnover exceeding ₹5 crore. |
| Certification | No certification required. | Certification required from a CA/Cost Accountant. |
| Filing Type | Self-filed by the taxpayer. | Filed by the taxpayer but certified by a CA or auditor. |
| Content | Provides a summary of transactions for the financial year. | Provides reconciliation between books of accounts and GST returns. |
| Due Date | 31st December following the financial year. | 31st December following the financial year, along with GSTR-9. |
Filing GSTR-9 and GSTR-9C Based on Turnover
The applicability of GSTR-9 and GSTR-9C depends on the annual turnover of the taxpayer:-
A. Turnover less than ₹2 crore.
GSTR-9: Filing is optional. The government has provided relief to small taxpayers, making GSTR-9 filing voluntary for those with turnover below ₹2 crore.
GSTR-9C: Not applicable.
B. Turnover between ₹2 crore and ₹5 crore.
GSTR-9: Filing is mandatory.
GSTR-9C: Not applicable.
C. Turnover above ₹5 crore.
GSTR-9: Filing is mandatory.
GSTR-9C: Filing and certification by a CA or Cost Accountant are mandatory.
Important Updates and Changes in GSTR-9 and GSTR-9C
In recent years, there have been several changes to simplify the filing process for taxpayers:-
- Simplified Reporting for Small Taxpayers.
Small taxpayers with a turnover below ₹2 crore have been exempted from mandatory filing of GSTR-9 to reduce their compliance burden.
- Late Fee Relief
The government has offered waivers or reductions in late fees for delayed filing of GSTR-9 in some cases, particularly for small taxpayers.
- Auto-Population of Data
GSTR-9 now includes auto-populated data from GSTR-1, GSTR-3B, and GSTR-2A, reducing manual errors and easing the filing process for taxpayers.
- Changes in GSTR-9C
Certain fields in GSTR-9C, such as Table 12B, 12C, and 14, have been made optional, further simplifying the reconciliation process for businesses.
- Extended Due Dates
Due dates for GSTR-9 and GSTR-9C have been extended in the past, especially due to the challenges posed by the COVID-19 pandemic, providing relief to businesses.
Conclusion
Filing GSTR-9 and GSTR-9C is a critical part of a business’s GST compliance journey. While GSTR-9 provides a consolidated report of all GST-related transactions for the year, GSTR-9C ensures that the reported data is consistent with the company’s audited financial statements.