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GSTR 9C – Reconciliation between Accounting Records and Annual GST Return

Reconciliation is one of the crucial elements of the GST framework, which helps in ensuring that GST returns are in sync with the books of accounts.

Form GSTR 9C has to be filed as a reconciliation statement as per GST laws.

What is GSTR 9C?

GSTR 9C is a statement that reconciles the figures filed in GST Annual return vis-à-vis figures mentioned in audited annual financial statements.

It has to be submitted by every registered person, who is required to get his accounts audited under the GSTact. GSTR 9C has to be filed electronically through the portal either directly or through a facilitation centre.

What is the due date of submitting GSTR 9C?

Form GSTR 9C will be submitted on or before 31st December along with the GST Annual Return (GSTR 9) and the Audit Report. For the FY 2017-18, reconciliation statement has to be filed till 31st December 2018 and will contain the details about the period between July 2017 to March 2018.

Who will certify GSTR 9C?

A Chartered Accountant or A Cost Accountant, will certify GSTR 9C. It is not necessary that the auditor, who has audited the books of accounts for GST purposes, should certify it.

Will GSTR 9C be filed for each GSTIN separately?

GSTR 9C has to be filed for each GSTIN number separately. Some taxpayers may operate in several states and possess multiple GSTINs against one PAN number. Hence, they have to calculate the figures GSTIN wise.

How will GST authorities deal with the differences raised in GSTR 9C?

On the basis of un-reconciled differences reported in GSTR 9C, the authorities will conduct further enquiry and investigations by issuing show cause notices to the defaulters, seeking clarifications from them.

What is the format of GSTR 9C?

GSTR 9C consists of two parts – Part A &Part B. Part A is the reconciliation statement, while PART B is the certificate.

What are the details to be mentioned in Part A of GSTR 9C?

Part A has been divided into 5 subparts –

1. Basic Details – Financial Year, GSTIN Number, Legal Name and Trade Name, any other Act in which the taxpayer is liable to get audited

2. Reconciliation of turnover declared in Annual GST Return vis-à-vis audited annual financial statements

a. Reconciliation of
i. Gross Turnover, and
ii. Taxable Turnover

b. Reasons for un-reconciled differences

3. Reconciliation of tax paid vis-à-vis tax payable

a. Reconciliation of tax wise liability and the tax amount payable,

b. Reasons for un-reconciled payment of tax amount,

c. Additional tax liability due to difference in turnover or tax amount

4. Reconciliation of Net Input Tax Credit

a. Reconciliation of ITC as per GSTR 9 vis-à-vis financial statements,

b. Reasons for un-reconciled differences,

c. Tax payable on un-reconciled difference in ITC

5. Auditor’s recommendation on the additional liability arising due to non-reconciliation

a. Taxable Value and the tax liability to be shown rate wise

At the end of the statement, the preparer has to mention his name, membership number, and his address.

How will Part-B of GSTR 9C be filled?

Two different certificates have been prescribed in Part-B:

  1. Certification, if the GST auditor has done the reconciliation,
  2. Certification, if the reconciliation has been done by any other CA or Cost Accountant

In the certificate, the preparer will mention the observations/ qualifications related to Form GSTR 9C. He will also certify that the audit report and the audited annual financial statements are attached with the reconciliation statement.

In the end, he will mention the name, membership number and the address.