GSTR 9C – Meaning, Due Date, Applicability, Turnover Limit, Format, and Steps to File

GSTR-9C is an annual GST reconciliation statement that must be filed by taxpayers whose aggregate turnover during a financial year exceeds ₹5 crore. This form requires taxpayers to reconcile the figures declared in their annual GST return (GSTR-9) with the audited financial statements of their business. Along with the form, a copy of the audited annual accounts must also be submitted. In this article will look into the GSTR 9C in detail.

Latest Updates

1. GSTR-9 & GSTR-9C for FY 2024-25 are now live on the GST portal – file by Dec 31, 2025!

2. 55th GST Council Meeting (21st December 2024)

The GST Council issued a circular clarifying the late fee under Section 47(2) of the CGST Act, 2017 for delays in filing GSTR-9 and GSTR-9C.
A recommendation was made to issue a notification under Section 128 of the CGST Act, 2017 to waive late fees for GSTR-9C for financial years 2017-18 to 2022-23.
The waiver applies to the excess late fees beyond the amount payable until the filing of GSTR-9, provided GSTR-9C is filed by 31st March 2025.

3. 53rd GST Council Meeting (22nd June 2024)

Taxpayers with aggregate annual turnover below ₹2 crore for FY 2023-24 are relaxed from filing GSTR-9/9A. This relaxation was notified via CGST Notification 14/2024 dated 10th July 2024.

What is GSTR-9C?

As mentioned, GSTR-9C is the annual GST reconciliation statement that must be filed by eligible taxpayers. Any registered taxpayer whose aggregate turnover exceeds ₹5 crore in a financial year is required to submit this form.

Along with GSTR-9C, taxpayers must also provide a copy of their audited annual accounts.

Also read: Year-End GST Reconciliations

Importance of GSTR-9C

GSTR-9C plays a vital role in maintaining transparency and accountability under the Goods and Services Tax (GST) system. It acts as a reconciliation statement between a taxpayer’s audited financial statements and the GST returns filed during a financial year.

Key Reasons Why GSTR-9C Matters

Ensures Accuracy in GST Reporting: GSTR-9C helps identify discrepancies between turnover, tax paid, and input tax credit (ITC) claimed. This ensures that the data filed under GST matches the audited financials.
Promotes Transparency and Compliance: The reconciliation process builds trust and ensures compliance with GST laws, minimizing the risk of errors or intentional misreporting.
Facilitates Audit and Verification by Authorities: Tax authorities rely on GSTR-9C to verify the accuracy of GST returns. It serves as a key tool for assessing whether the taxpayer’s GST filings reflect their true financial position.
Prevents Legal and Financial RisksFiling: GSTR-9C correctly helps avoid penalties, notices, and scrutiny from tax authorities. It demonstrates proactive compliance with statutory obligations.
Encourages Financial Discipline: Preparing GSTR-9C requires businesses to maintain organized and accurate books of accounts, promoting better financial management practices.
Supports Creditworthiness for Loans: Since GSTR-9C reflects financial integrity and consistency, it strengthens a business’s credibility while applying for business or MSME loans.

GSTR-9C Turnover Limit

As per CBIC Notification No. 30/2021 dated 30th July 2021, every registered GST taxpayer whose aggregate turnover exceeds ₹5 crore during a financial year is required to file GSTR-9C.

GSTR-9C Applicability

GSTR-9C must be filed by all registered taxpayers whose annual turnover exceeds ₹5 crore during a financial year.

Applicability

GSTR-9C applies only to regular taxpayers whose turnover exceeds ₹5 crore.
Composition scheme taxpayers and e-commerce operators filing GSTR-8 are not required to file GSTR-9C, even if their turnover exceeds the threshold.
The form serves as a self-assessment tool, allowing businesses to identify and correct discrepancies between GST returns and audited accounts, ensuring transparency in financial reporting.

Exemptions

Foreign Companies in the Airline Business: As per CBIC CGST Notification No. 09/2020 dated 16th March 2020, foreign airline companies compliant with the Companies Act 2013 provisions are exempt from filing GSTR-9C.

Non-Resident Providers of OIDAR Services: As per CBIC Notification No. 30/2019 dated 28th June 2019, non-resident taxpayers providing OIDAR services to unregistered persons in India are exempt from submitting both GSTR-9 and GSTR-9C.

Penalty for Non-Filing

Failing to file GSTR-9C on time attracts a penalty of ₹200 per day (₹100 CGST + ₹100 SGST), with a maximum of 0.50% of the taxpayer’s turnover. Eligible businesses must file on time to avoid these penalties.

GSTR-9C Due Date

The due date for filing GSTR-9C aligns with the deadline for submitting the Annual Return in GSTR-9. Therefore, GSTR-9C must be filed on or before 31st December of the year following the financial year under audit.

For example, the GSTR-9C due date for the financial year 2024-25 is 31st December 2025.

Late Fees and Penalties

According to Section 125 of the CGST and SGST Acts, 2017, a general penalty of ₹25,000 applies for non-compliance. Since no specific penalty is prescribed for late filing of GSTR-9C, this general penalty applies to taxpayers who fail to submit the form on time.

To avoid penalties and potential scrutiny from tax authorities, businesses should proactively plan and integrate GST compliance into their regular financial management practices. Timely filing ensures accurate reconciliation, reduces last-minute stress, and maintains transparency in GST reporting.

Also read: Consequence of non-maintenance of Books of Accounts under GST

Contents and Format of GSTR-9C

The GSTR-9C comprises two main sections:

Part A: Reconciliation Statement
Verification/Self-Certification by the Taxpayer

Part A: Reconciliation Statement

Figures in the reconciliation are usually drawn from audited financial statements prepared at the PAN level. For GSTR-9C, relevant details (turnover, tax paid, and ITC earned) for each GSTIN (State/UT) must be extracted from these accounts.
The reconciliation statement is structured into five parts:

Part	Description
I	Basic details: Covers financial year, GSTIN, legal/trade name, and audit applicability under any other law.
II	Reconciliation of turnover: Matches gross/taxable turnover in audited accounts to the turnover in GSTR-9. In most cases, sales data must be broken down to the GSTIN level. Turnover adjustments (Tables 5B–5N) are now optional; necessary adjustments can be entered in Table 5O per Notification No. 56/2019.
III	Reconciliation of tax paid: Compares tax liability as per books and as reported in GSTR-9, rate-wise. Discrepancies or additional tax liability from the reconciliation must also be stated.
IV	Reconciliation of Input Tax Credit (ITC): ITC availed/utilised, as reported in both GSTR-9 and audited accounts, is compared. Any adjustments—eligible/ineligible ITC and reversals—are to be reconciled. Tables 12B, 12C, and 14 (detailed ITC reconciliation) are optional after the 2019 notification.
V	Recommendation of additional liability: Taxpayer must declare any extra tax, interest, penalty, or other amounts identified through reconciliation, payable due to unreconciled differences.

Verification/Self-Certification

GSTR-9C must be verified and self-certified by the taxpayer from FY 2020-21 onwards. The taxpayer affirms that the reconciliation has been prepared accurately in accordance with GST provisions, and all required documents (such as audited annual accounts) are correctly reflected in the filing

Documents Required to be Submitted with GSTR-9C

When filing GSTR-9C, taxpayers must submit the following documents:

Audited Financial Statements: Include the balance sheet, profit and loss statement, and any other relevant financial statements for the financial year.
Reconciliation Statement: A detailed statement reconciling turnover, tax paid, and input tax credit claimed, comparing the audited financial statements with the GST returns filed.
Certified Copy of GSTR-9: Attach the annual return (GSTR-9) filed for the same financial year.
Certificate by Chartered Accountant or Cost Accountant: A certification confirming the accuracy of the information provided, signed by a CA or CMA.

To manage unexpected costs related to preparing these documents, businesses can explore pre-approved business loans or other financing options to ensure timely submission without delays.

How to file GSTR-9C

Here’s a clear, step-by-step guide on how to file GSTR-9C for FY 2024-25 in 2025:

Step 1: Ensure All GST Returns Are Filed

Complete filing of GSTR-1 (outward supplies) and GSTR-3B (monthly/quarterly summary) for the financial year 2024-25. File GSTR-9 (annual return) before starting GSTR-9C.

Step 2: Maintain Records and Prepare Financial Statements

Keep detailed books of accounts and supporting documents. Prepare annual financial statements at the PAN level:

Balance Sheet
Profit & Loss Account
Income & Expenditure Account
Cash Flow Statement (if applicable)

Step 3: GST Audit (If Applicable)

Taxpayers with aggregate turnover above ₹5 crore must reconcile GSTR-9 with audited accounts. GST audit at PAN level is usually sufficient.

From FY 2020-21 onwards, CA/CMA certification is optional for eligible taxpayers; self-verification is allowed.

Step 4: Reconcile Details

Collect GSTIN-wise data: turnover, taxes paid, and Input Tax Credit (ITC). Reconcile with GSTR-9 in Part A of GSTR-9C. Report discrepancies and additional liabilities, if any.

Step 5: Pay Any Additional Liability

Use FORM DRC-03 to pay any extra tax liability declared in GSTR-9C. Select ‘Reconciliation Statement’ in the drop-down menu. Payments must be made through the electronic cash ledger only.

Step 6: File GSTR-9C on the GST Portal

Option 1: Generate and Upload GSTR-9C JSON File Using the Offline Utility

Filing GSTR-9C requires generating a JSON file using the offline utility and uploading it to the GST portal. Follow these streamlined steps to ensure a smooth filing process:

Download Necessary Forms and Tables: Log in to the GST Portal using your GSTIN and credentials. Download Form GSTR-9 for the relevant financial year. Download GSTR-9C Tables derived from Form GSTR-9.
Download the GSTR-9C Offline Tool: Navigate to the Downloads tab on the GST portal. Select “Offline Tools” and then choose “GSTR-9C Offline Tool” to download the utility.
Prepare the GSTR-9C Statement: Open the GSTR-9C Offline Utility Worksheet.

Input the relevant data into the tables provided in the worksheet.
Generate a preview PDF to review the draft version of Form GSTR-9C.
Create the JSON file once all data is accurately entered and reviewed.

Steps to Upload the GSTR-9C JSON File on the GST Portal

Login and Navigate to Returns: Log in to the GST portal using the GSTR-9C Offline Utility. Go to the “Returns” tab and select “Annual Return”. Choose the appropriate financial year and click “Search”.

Prepare for Upload: On the returns page, select “Prepare Offline”. Click the “Upload” button to begin uploading your JSON file.

Upload and Edit (if necessary):

Upload the generated JSON file.
If needed, make edits or changes to the GSTR-9C form.
Re-generate the JSON file after any changes and re-upload it through the offline utility.

Note: If errors are detected during upload, download the Error Report, correct the issues, and upload the updated JSON file.

Option 2: Steps to File the GSTR-9C on the GST Portal

Upload Financial Statements: After uploading the JSON file, proceed to add financial statements such as the Balance Sheet and Profit & Loss Statement. Ensure all documents are in PDF format, with each file not exceeding 5 MB and a maximum of 2 files per section.
Save Each Document: After uploading each document, click the “SAVE” button to confirm the upload. The status should show as “Processed”. Failing to save each upload will result in errors when proceeding to file.
Proceed to File: Once all required documents are uploaded and saved, the “PROCEED TO FILE” button will become active.

Preview your GSTR-9C draft by clicking “PREVIEW DRAFT GSTR-9C (PREVIEW)”.
After verification, click “PROCEED TO FILE” to navigate to the verification page.
Confirm your verification details and click “FILE GSTR-9C” to complete the filing process.

Track Filed Returns: Post submission, you can track your filed returns by navigating to the “Services” tab. Select “Returns” from the dropdown and then choose “View Filed Returns” to monitor your submission status.

Step 7: Certification (If Required)

For businesses still under audit requirement, Part B should be certified by a CA or CMA. Otherwise, eligible taxpayers can self-certify.

Step 8: Keep Records

Maintain copies of GSTR-9C, GSTR-9, and audited financial statements for future reference and GST audits.

Troubleshooting Tips:

Error Handling: If the JSON file shows errors during upload, download the Error Report, rectify the issues, and re-upload the corrected file.

Changes in GSTR-9C Format & Filing

Several important changes have been made to the GSTR-9C format and filing procedure from FY 2020-21 onwards:

Self-Certification Introduced: Taxpayers must now verify and self-certify the GSTR-9C instead of requiring certification by a Chartered Accountant (CA) or Cost Accountant (CMA). The previous certification requirement has been completely removed.
Verification by Registered Taxpayers Added: Registered taxpayers affirm the accuracy of their reconciliation statements themselves.
Mandatory Filing of All GST Returns: Taxpayers must file all monthly/quarterly GST returns for the financial year — GSTR-1, GSTR-3B, and then the annual return in GSTR-9.
Payment of Additional Liability via FORM DRC-03: At the end of the GSTR-9C filing, taxpayers can pay any additional tax liability declared through FORM DRC-03, selecting “Reconciliation Statement” in the dropdown. Such payments must be made solely through the electronic cash ledger.
Revised Format and Optional Tables: Some detailed reconciliation tables (like turnover adjustments and ITC reconciliation) have been made optional, simplifying reporting as per Notification No. 56/2019.
Removal of Part-B (Auditor Certification): The older Part-B certification section by auditors has been removed. Now, Part-A (Reconciliation Statement) is self-certified by the taxpayer.

Click here to know more about the Recent Changes in the GSTR-9 and 9C

Difference Between GSTR-9 and GSTR-9C

Parameters	GSTR-9C (Reconciliation Statement)	GSTR-9 (Annual Return)
Nature	A reconciliation statement analyzing GST returns.	An annual return consolidating all GST returns.
GST Act	Prescribed under Section 35(5) read with Section 44 of the GST Act.	Prescribed under Rule 80 of Section 44 of the CGST Act.
Who File It?	GST-registered taxpayers subject to audit.	All GST-registered taxpayers.
Exclusions	Not applicable to taxpayers with turnover under Rs.2 crore.	Excludes casual taxable persons, non-resident taxpayers, UIN holders, composition dealers, TCS/TDS provisions, and OIDAR service providers.
Due Date	31st December of the following fiscal year, along with or after GSTR-9.	31st December of the following fiscal year.
Penalty	General penalty of Rs.25,000 for non-compliance.	Late fee of Rs.200/day, capped at 0.25% of aggregate turnover.
Returns Filing	Can be filed via the GST portal or facilitation center, with GSTR-9 or separately.	Filed through the GST portal or facilitation center.
Format / Structure	Divided into Part A (Reconciliation of turnover, tax, ITC) and Part B (Auditor certification).	Simple annual return consolidating details of sales, purchases, and ITC.
Contents	Consolidates turnover, paid taxes, ITC, late fees, amendments, job work details, HSN summary, and refunds.	Consolidates sales, purchases, ITC, and adjustments.
Annexures	Requires uploading audited financial statements (Profit & Loss and Balance Sheet).	No annexure requirement.
Certification	Requires digital signatures from both auditors and taxpayers.	Requires the taxpayer’s digital signature only.

Click here to learn more about the key difference between GSTR-9 and GSTR-9C

Conclusion

In summary, GSTR-9C plays a crucial role in the GST compliance framework for businesses with significant turnover. Timely and accurate filing of this reconciliation statement is vital to avoid penalties and maintain compliance. Given the detailed nature of GSTR-9C, businesses need meticulous record-keeping and proactive planning throughout the financial year to ensure all data aligns correctly between GST returns and audited financial statements.

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