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Steps to File GSTR-9C - Applicability, Due Dates, Turnover Limit
What is GSTR-9C, its due dates and how to file GSTR-9C
What is GSTR-9C?
In GSTR-9C, reconciliation of the Annual Return (GSTR-9) and Audited Financial Statement is done and if all the details are reconciled then normally GSTR-9C has to be filed. But if there is any unreconciled amount, which creates a liability, it has to be paid and then the return has to be filed.
In which case GSTR-9C will be applicable, what is the turnover limit for GSTR-9C?
Registered persons, whose aggregate turnover exceeds Rs 5 crore are also required to file a Self-Certified Reconciliation Statement along with the Annual Return (GSTR-9). Before filing GSTR-9C, the taxpayer is required to file GSTR-9. i.e. GSTR-9C can only be filled when the taxpayer has filled GSTR–9.
Due date of GSTR-9C
The due date to file GSTR-9C for a financial year is 31st of December of the year following the relevant financial year.
Due date for the FY 2022-23 : The due date to file GSTR-9C for the Financial Year 2022-23 is 31st December 2023.
GSTR-9C has been divided into 4 parts :-
| Part –1 Basic details. |
| Part –2 Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9). |
| Part –3 Reconciliation of tax paid. |
| Part -4 Reconciliation of Input Tax Credit (ITC). |
In GSTR – 9C following items are reconciled:-
| Total Turnover |
| Taxable Turnover |
| Tax Paid |
| Input Tax Credit (ITC) |
Practical Guide to file GSTR-9C :-
GSTR–9C can be filed only through offline utility. To file GSTR-9C, the department provides an offline tool, through which taxpayers create JSON and then upload it on the GST portal. First of all, go to the GST website and download the offline GSTR-9C tool from offline tools in the download tab on the home page. To download, you have to click on the offline GSTR-9C tool and then click on download. If you proceed, the offline tool will be downloaded in a zip file. Now you have to extract that file and work in the Excel sheet of the offline tool. Before filing GSTR-9C, you have to file GSTR-9. Only after that, you can file the GSTR – 9C form.
Now let us understand how to file GSTR-9C with offline utility:
In PART-A, you have to submit basic details like GST No., Financial Year, Legal Name & Trade Name and also mention whether you are liable for audit under any other law (Companies Act, Income Tax etc.) If yes, then that applicable law will have to be mentioned.
Now, let us understand Part B:-
Pt. II. Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (GSTR9)
In this table, the turnover declared in the audited financial statement is compared with the turnover declared in the return (GSTR-9).
Point-A : Turnover (including exports) as per Audited Financial Statement for the State / UT (For multi-GSTIN units under the same PAN, the turnover shall be derived from the Audited Annual Financial Statements )*
In Point-A, turnover as per books of account is to be mentioned. But, if you are working in multiple states, then you will have to file separate GSTR-9C for each state and the turnover of books will also have to be calculated state-wise. This turnover is to be derived from the audited financial statement.
Example : Suppose, you have 2 branches, one is in MP and the other is in Gujarat.
Turnover Details of Branch :-
| MP Branch | Rs. 5.50 Cr |
| Gujarat Branch | Rs. 6.50 Cr |
| Total Turnover | Rs. 12.00 Cr |
If you are filing GSTR-9C of MP then only the turnover of MP i.e. Rs. 5.50 Cr will have to be mentioned in Point-A.
Point-B : Unbilled revenue at the beginning of the Financial Year
In Point-B, unbilled revenue has to be reported at the beginning of the financial year. This means that such bills are included in the turnover of last year's books as per the accounting standard. But, in GST, Tax payment is made according to the time of supply. Therefore, its GST is paid in the current year. By doing this, there will be a difference in the turnover of our books of account and annual return. In this case, Books of Account will show fewer sales this year and GST will show more sales. That difference has to be reported here.
Let us understand this point with an example –
In accounting, revenue recognition is done according to IND AS and in GST, Tax is paid according to the time of supply. Suppose, there was a bill that was recognized in the books of accounts in March 2022. But, if GST on it is payable in April 2022, then it will be shown in the return of April 22, due to which there will be a mismatch in the turnover of books and GST, then this difference has to be reported here in Point B.
Point-C : Unadjusted advances at the end of the Financial Year
In Point-C, the unadjusted advance has to be reported at the end of the year. If any advance is received then it is not recognized as revenue in the books as per accounting standards. But in the GST Act, if any advance is received above Rs 1000, then in such case, the applicability of GST arises. In this case, your current financial year turnover will show less in the books. But, there will be show sales shown in the annual return. That difference has to be reported here in Point-C.
Let us understand this point with an example –
Suppose, you received an advance related to service on 28th February 2022, which was billed in April 2022, on which GST was paid in March 2022, i.e. last year itself. So in this case, sales will show more in the books of account in the current FY 2022-23, but sales will show less in the annual return. That difference has to be reported here in Point-C.
Point-D : Deemed Supply under Schedule I
Transactions notified in Schedule I are reported in Point-D. Deemed supply is defined in this schedule. If more than one GST number is registered on the same PAN and any transaction is made between them, then it will be called deemed supply. This means that, even if it is your branch, but if you get a separate GST number on the same PAN, it is considered a distinct person and GST is charged even on transfer from one branch to another.
Let us understand this point with an example–
Suppose you have 2 branches, one is in MP and the other is in Gujarat. You sold goods worth Rs. 50 lakhs from the MP branch to the Gujarat branch. So in this case, you would have paid GST on Rs. 50 lakh. But, when you would have finalized the books of account, then this sale of Rs. 50 lakh would have been excluded from the total sales. By doing this there will be a difference in the turnover of our books of account and annual return. In this case, fewer sales will be shown in Books of Account and more sales will be shown in GST. That difference has to be reported here.
Point- E: Credit Notes issued after the end of the financial year but reflected in the annual return
Point-E is related to a Credit note which is issued after the end of the financial year but is included in the annual return. If we understand from the example, suppose you have made a sale on 30th March 2023, where the customer did not like the goods and the customer returned the goods. Whose credit note was issued by you on April-23. But, you have considered this credit note while filing your annual return. This means that your outward liability in your GSTR-9 has been reduced. But in books, a credit note will be shown only in April-23, due to which there will be more turnover in books in F.Y.2022–23, due to which there will be the difference in turnover of books and turnover of annual return which has to be reported in point-E.
Point-F: Trade Discounts accounted for in the audited Annual Financial Statement but are not permissible under GST
Point-F is related to trade discounts. Any trade discount given which is not allowed in GST. This means that, due to giving a trade discount, even if the sales in the books of account have reduced, but you will have to pay GST on the entire sales only. Because of this, the turnover in books of account reduces, but in GST this trade discount is not allowed due to which there is a difference between the turnover of GST and the turnover of books. That difference was reported here in point-F.
Point-G : Turnover from April 2017 to June 2017
Point-G Turnover from April-17 to June-2017, this point is applicable only for 9C of FY 2017-18. Because GST became applicable in July-2017. So in that case, more sales will be shown in the books of account for FY 17-18 and fewer sales will be shown in GST. That difference was reported here.
Point-H : Unbilled revenue as of the end of the Financial Year
In Point-B we understood about unbilled revenue at the beginning of the financial year, here in Point-H, the amount related to the end of the financial year has to be entered.
Meaning that such bills are included in the current year's turnover in the books of account. But, in GST, payment will be made according to the time of supply. Therefore, its GST payment is made in the next financial year. By doing this there will be a difference in the turnover of our books of account and annual return. In this case for the current year, there will be more sales in Books of Account and fewer sales will be shown in GST. That difference has to be reported here.
Let us understand this point with an example –
In accounting, revenue recognition is as per IND AS, and in GST, GST is paid as per the time of supply. So suppose there was a bill that was recognized in the books of accounts in March 2023. But, GST on it is payable in April-2023, due to which there will be a mismatch in the books and GST turnover of FY 2022-23, so this difference has to be reported here in Point-H.
Point-I : Unadjusted Advances as at the beginning of the Financial Year
In Point-I the unadjusted advance at the beginning of the year has to be reported. If any advance has been received in the last year, then as per the accounting standard it would not have been recognized in the books as revenue last year. But in the GST Act, if any advance of more than Rs.1000 is received then in such case, the applicability of GST comes only after the advance is received. In this case, your current financial year's turnover will show more in the books. But, the annual return will show less turnover. That difference has to be reported here in Point-I.
Let us understand this point with an example –
Suppose you have received an advance related to service on 28th February 2022, which was billed in April 2022, on which GST was paid in March 2022, i.e. last year itself. So in this case, sales will be shown more in the books of account in FY 2022-23, but the annual return will show less turnover. That difference has to be reported here in Point-I.
Point J : Credit notes accounted for in the audited Annual Financial Statement but are not permissible under GST
Point J is to report such credit notes that are related to the last financial year whose credit note has been issued and accounted for during the current financial year, but this credit note is not allowed or permissible in GST (For example, a credit note has not been issued before 30th November or return), then it will not be permissible in GST. Due to this your current year’s turnover will be reduced, but there will be no reduction in GST turnover, due to which a difference will be created and this difference will be reconciled by adding it to point J.
Point-K : Adjustments on account of supply of goods by SEZ units to DTA Units
Point K- is related to the adjustment of supply made from the SEZ unit to the DTA unit. Here it is important to understand that in reality it is a sale, but there is no need to report the sales made by SEZ in GST, due to which the turnover in books is higher and the GST turnover is lower. So to reconcile this difference, we reduce the supply of SEZ to DTA at point k, so that the turnover becomes equal to the annual return.
Point-L : Turnover for the period under the composition scheme
Point -L is related to the turnover of the composition scheme. For example, let us assume that in FY 2022-23, you were in the composition scheme from April-22 to June-22. After that you opted for the normal scheme. The turnover made in the composition scheme is not included in GSTR-9 (annual return). Due to this, in FY 2022-23, the turnover in the Book of Account will show more, but it will show less in the annual return, due to which a difference will be created and this difference will be reconciled by reporting it in point-L.
Point-M : Adjustments in turnover under section 15 and rules thereunder
In Point M, the adjustment of the difference in turnover of books and GST, due to section 15 of CGST (value of supply of goods & services) and its rules will have to be reported here.
In Books of Account, Transaction value (sales) is determined according to the Accounting Standard. However in GST, according to Section 15, transaction value is determined. Due to this, there may be differences in Books of Account and GST Turnover. This difference can be both positive/negative. You can add or reduce as per the situation.
If we understand from the example, for a certain transaction the transaction value in GST is Rs. 10,00,000/-, but according to the books of account the value is Rs. 12,00,000/-. So you have to mention 200000 in the negative at this point. Due to this GST and book of accounts turnover will be reconciled.
Point-N : Adjustments in Turnover due to foreign exchange fluctuation
The difference that has arisen due to foreign exchange fluctuations has to be reported in Point N. Due to foreign exchange fluctuations, there may be a difference in the Books of Account and GST Turnover. This difference can be both positive/negative. You can add or reduce as per the situation.
If you want to increase the turnover of books then you will have to enter the figure in positive and if you want to reduce the turnover then you will have to enter the figure in negative.
Point-O : Adjustment in Turnover due to reasons not listed above
In this point, apart from all the points discussed so far, if there is a difference between the annual return and the audited financial statement due to any other reason, then that difference has to be mentioned. This difference can be both positive/negative. You can add or reduce as per the situation.
Point P : Annual Turnover after adjustments as above(A+B+C+D-E+F-G-H-I+J-K-L+M+N+O)
According to the figure reported in points above, in point-P, the figure of automatically adjusted turnover will be shown.
Point-Q : Turnover as declared in Annual Return (GSTR9)
In Point Q, the turnover declared in the Annual Return (GSTR – 9) has to be mentioned.
Point-R : Un-Reconciled turnover (Q- P)
After making all the adjustments, your audited annual turnover should match with the turnover mentioned in GSTR – 9 (annual return). If there is any difference, it will be shown here.
Reasons for Un - Reconciled difference in Annual Gross Turnover :-
After making all the adjustments, if there is a difference between the audited annual turnover and the turnover mentioned in GSTR – 9 (annual return), then you have to mention the reason here why your turnover is mis-match.
In this table, reconciliation is done between the taxable turnover of the books of account and the annual return.
Point-A : Annual Turnover after adjustments [from 5(P) above]
This figure is auto-populated from the work done in the previous tables.
The adjusted turnover that has come after making various adjustments in the previous table is shown here.
Point-B : Value of Exempted, Nil Rated, Non-GST Turnover, No supply turnover
In this point Exempted, Nil Rated, Non-GST Turnover, and No Supply Turnover have to be mentioned.
Point-C : Zero-rated supplies without payment of tax
In this Point-C, zero-rated supply without payment of tax has to be mentioned.
Point-D : Supplies on which tax is to be paid by the recipient on a reverse charge basis
In this Point-D, the amount of supplies on which the recipient has paid tax in the reverse charge mechanism has to be mentioned.
Point-E : Taxable turnover as per adjustments above (A-B-C-D)
After entering the amount in the above points, the taxable turnover is auto-calculated and shown in this table. Points B, C & D are deducted from Point A.
Point-F : Taxable turnover as per liability declared in Annual Return (GSTR-9)
Here the taxable turnover declared in the annual return has to be mentioned in this point.
Point-G: Unreconciled Taxable Turnover (F-E)*
If there is a difference in turnover, it will be auto-calculated and shown here and the reason will have to be mentioned in the next Excel sheet.
This table is of unreconciled taxable turnover. If your taxable turnover is not reconciled, then you will have to mention the reason here.
This table is of reconciliation of tax paid, in this reconciliation of rate rate-wise liability has to be done. All the rates are given in this table in which you have to enter the taxable value and taxes as per the books and do reconciliation with the tax amount paid as declared in GSTR-9 and if there is any difference, then its reason has to be mentioned in the next Excel sheet.
In this sheet, if there is any difference between the taxes paid as per the books and the tax amount paid as declared in GSTR-9, the reason for the same has to be mentioned.
In this table, additional liability has to be shown which has arisen due to a difference in turnover, or difference in taxable turnover, or difference in tax paid. This means you have paid less to the Government and this amount will have to be paid in cash.
This table is of reconciliation of input tax credit.
In Point-A, you have to mention the ITC of the state for which you are filing GSTR-9C from the audited financial statement.
In Point-B, such ITC has to be mentioned which has been booked in the previous financial year but claimed in this financial year.
In Point-C, ITC has to be mentioned which has been booked in the current financial year but will be claimed in the subsequent financial year.
In Point-D, the ITC availed in the audited financial statements or books of account will be auto-populated here.
In Point-E, you have to mention the ITC claimed in GSTR-9 (annual return).
Point-F : If there is a difference between the ITC claimed in the annual return and the ITC as per books of account, it will be shown here. If there is any difference, then its reason has to be mentioned in the next sheet and if you have claimed excess ITC, then you have to pay it.
If ITC cannot be reconciled, then its reason will have to be mentioned in this sheet.
This table is optional, here you have to give bifurcation of expense-wise ITC as declared in books and mention the declared ITC in the annual return. If there is any difference between the two, the reason for the difference has to be mentioned in the next table.
If ITC cannot be reconciled, then its reason will have to be mentioned in this sheet.
In this sheet, any additional liability that is payable due to a difference in ITC has to be mentioned along with interest and penalty.
This is the last table of GSTR-9C. The additional liability arises due to a lack of reconciliation in the books of account and the annual return has to be mentioned in this sheet and in this sheet, the rate-wise value and GST amount have to be mentioned. Along with that, interest and penalty also have to be mentioned.
Whatever liability has arisen, will have to be paid through DRC-03.
After this, you have to click on the Home sheet. From here, you can generate the PDF, take a preview, and re-check it from your records. After verifying all the details, you will have to create JSON by clicking on the option to create a JSON file.
After creating the JSON file, you will have to login in the GST portal.
After login, in the service menu, click on annual return in user services.
After that, the financial year for which you want to file an annual return will have to be selected from the drop down menu
After that, in the tab of GSTR-9C, this JSON file will have to be uploaded, and then it will have to be verified with DSC and submitted. In this way, GSTR-9C will be filed.
