Missed GSTR-9C Filings? CBIC Waives Late Fees Until March 31, 2025!

Missed Filing GSTR-9C for FY 2017-18 to 2022-23? Good News! If you failed to file your GSTR-9C form for the financial years 2017-18 to 2022-23, CBIC has announced a waiver of late fees for these filings. To take advantage of this waiver, you must submit your GSTR-9C by March 31, 2025. After filing, request the GST proper officer to cancel any Show Cause Notices (SCNs), thereby stopping any GST demands.

IndiaFilings experts are here to help! We can assist you in filing your GSTR-9C before the due date. Talk to our experts today and take advantage of this late fee waiver.

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File Pending GSTR-9C by March 31, 2025 to Avail Late Fee Waiver

On January 23, 2025, the Central Board of Indirect Taxes and Customs (CBIC) issued Notification No. 8/2025, addressing the late fees applicable to registered taxpayers who failed to file GSTR-9C along with GSTR-9. For the financial years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, and 2022-23, if a taxpayer did not submit their GSTR-9C form with their GSTR-9, the late fee for the delay in filing GSTR-9C will be calculated up to the date of its submission, provided that GSTR-9C is filed on or before March 31, 2025. It is important to note that no refunds will be available for any late fees already paid.

Failing to file by this deadline will result in continued late fees and potential GST notices. The official notification is attached here for reference:

What is GSTR-9?

In the GST regime, all registered persons, except Input Service Distributors, persons liable to deduct TDS/TCS, casual taxable persons, and non-resident taxable persons, are required to file an annual return in Form GSTR-9 by 31st December following the end of the financial year. The threshold for filing GSTR-9 is an annual aggregate turnover of ₹2 Crores.

What is GSTR-9C?

GSTR-9C is an annual GST reconciliation statement that applicable taxpayers must file. This form serves as a detailed comparison between the figures reported in a taxpayer's annual GST return (GSTR-9) and their audited financial statements.

Who Must File GSTR-9C? 

Every registered taxpayer whose aggregate turnover during a financial year exceeds ₹5 Crore is required to file GSTR-9C. Additionally, these taxpayers must furnish a copy of their audited annual accounts along with the form to ensure the accuracy and authenticity of the reported GST data.

Importance of GSTR-9C

GSTR-9C is a vital GST reconciliation statement that taxpayers must prepare annually. This document identifies and explains any discrepancies between the sales, taxes, or input tax credit details reported in the GST returns and those reflected in the taxpayer's audited financial accounts. By detailing these differences and providing reasons for them, GSTR-9C serves as a foundation for GST authorities to verify the accuracy and compliance of the GST returns filed by taxpayers after self-certification.

Purpose of Filing GSTR-9C:

Filing GSTR-9C, the reconciliation statement, along with the GSTR-9 annual return, is crucial under India's Goods and Services Tax (GST) laws for taxpayers whose aggregate turnover exceeds ₹5 Crore in a financial year. 

• GSTR-9C is a mandatory filing under Section 44(2) of the CGST Act, 2017, applicable to taxpayers meeting the aforementioned turnover threshold.

• GSTR-9C reconciles the figures reported in the annual return (GSTR-9) with the taxpayer's audited financial statements. It helps identify discrepancies, if any, and ensures the accuracy of GST declarations.

What is the Due Date for Filing GSTR-9C?

The deadline for filing GSTR-9C coincides with the submission date for the annual return in GSTR-9. Consequently, GSTR-9C must be filed on or before December 31 of the year following the relevant financial year under audit.

For instance, for the financial year 2023-24, the GSTR-9C form must be submitted by December 31, 2024. Adhering to this deadline is essential to ensure compliance with GST regulations and to avoid potential penalties for late submission.

CBIC has announced a waiver of late fees for filing GSTR-9C for the financial years 2017-18 to 2022-23. To take advantage of this waiver and prevent GST notices, ensure that you submit your GSTR-9C by March 31, 2025.

Conditions for Waiver of Late Fees for GSTR-9C Filing

The recent notification has waived late fees for filing GSTR-9C for the financial years 2017-18 to 2022-23 under specific conditions:

• On-Time GSTR-9 Filing: If a taxpayer has filed their GSTR-9 on or before the deadline, late fees for GSTR-9C will not be levied for the specified financial years.
• Late GSTR-9 Filing with Fees Paid: If a taxpayer has filed GSTR-9 after the deadline but has already paid the applicable late fees, additional late fees for GSTR-9C will not be imposed separately.
• Handling Show Cause Notices (SCNs): Previously, the GST department issued Show Cause Notices (SCNs) for non-payment of late fees related to delayed GSTR-9C filings.

With this new notification, taxpayers can now respond to these SCNs by requesting the GST proper officer to cancel the notices, thereby stopping any GST demands associated with the late filing.

Consequences of Not Filing GSTR-9C by March 31, 2025

If a GST-registered person fails to file their GSTR-9C return by the final deadline of March 31, 2025, after having filed their GSTR-1 and GSTR-3B returns with proper reconciliation against GSTR-2A and GSTR-2B, the GST department may take stringent actions. During GST return scrutinies, audits, inspections, or searches, the department may initiate proceedings for any discrepancies found in outward supplies, tax liabilities, and Input Tax Credit (ITC) claims related to purchases under the Reverse Charge Mechanism (RCM).

Issuance of Notices

Initially, the GST department will send a Show Cause Notice (SCN) requiring the taxpayer to file the GSTR-9C within a specified timeframe. The department may issue a Show Cause Notice (SCN) under the following:

• Section 73 for non-fraudulent discrepancies, or
• Section 74 for fraudulent activities.

Penalties:

Failure to file GSTR-9C can attract penalties under Section 125 of the CGST Act, imposing a general penalty of up to ₹25,000 for non-compliance.

• State GST Penalties: State GST laws may impose equivalent penalties, potentially doubling the financial burden.
• Late Fees: Late filing of GSTR-9C attracts a late fee, adding to the taxpayer's financial liabilities.
• GST Audits and Assessments: The GST authorities may initiate audit or assessment proceedings to examine the taxpayer’s filings and uncover any discrepancies or non-compliance issues.
• Increased Scrutiny: Persistent failure to file GSTR-9C can result in heightened scrutiny of the taxpayer’s GST returns, potentially leading to allegations of fraud or tax evasion.

GSTR-9C  Submission Process

GSTR-9C must be filed through the GST portal or via a facilitation centre, accompanied by:

• A copy of the Audited Accounts and
• The Annual Return in Form GSTR-9.

Pre-requisites to Prepare and File GSTR-9C

To successfully file the GSTR-9C form, the following prerequisites must be fulfilled:

• Valid GST Registration: Ensure you have a valid GSTIN and are registered under GST.
• Active Login Credentials: Your username and password for the GST portal must be current and functional.
• Filing of GSTR-9: You must have filed Form GSTR-9 (Annual Return) for the relevant financial year.
• Aggregate Turnover: Your business must have an aggregate turnover exceeding ₹5 Crore.

Procedure to File GSTR-9C

Filing GSTR-9C, the annual GST reconciliation statement is a crucial compliance requirement for eligible taxpayers. Follow this step-by-step guide to ensure a smooth and accurate filing process:

How to 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.

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.

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.

Practical Steps for Taxpayers:

• File GSTR-9C Promptly: Ensure that any pending GSTR-9C filings for the financial years 2017-18 to 2022-23 are submitted by March 31, 2025, to benefit from the waiver of late fees.
• Respond to SCNs: If you have received an SCN for late GSTR-9C filing, utilise this notification to request the cancellation of the notice by contacting the GST proper officer.
• Upgrade Compliance Systems: Consider using automated tools like IndiaFilings’s Ledgers to streamline your GST compliance processes, ensuring timely filings and reducing the risk of penalties.

By taking these actions, taxpayers can effectively manage their GST obligations, avoid unnecessary penalties, and maintain smooth business operations.

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