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GSTR 9C: Reconciliation Format, Certificate, Filing, and Rules

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A taxpayer under GST must file different returns and statements in a financial year. Apart from regular monthly and quarterly GST returns, taxpayers are required to file annual returns. These annual returns are filled in the form GSTR 9. In some cases, GSTR 9 is accompanied by another form GSTR 9C. 

GSTR 9C is made mandatory to be filled by certain taxpayers. Due to recent changes, It is easy for a layman to get confused. The following sections will help you understand GSTR 9C, Its format, applicability and the procedure to file it.  

Did you know? Earlier, GSTR 9C was required to be certified by either a Chartered Accountant or Cost Accountant, but this requirement no longer applies. 

What is GSTR 9C?

In simple words, GSTR 9C is a GST reconciliation statement. It is a reconciliation between the GST annual return that is GSTR 9 and corresponding figures from the audited financial statement of the relevant year. 

The details of gross turnover, taxable turnover, input tax credit, GST payable and GST paid are taken from the audited financial statement and then compared with the details of the GST annual return. The main purpose of GSTR 9C is to report unreconciled items between audited books of accounts and GSTR 9, along with the reasons for such differences.

Also read: Legal Name and Trade Name Based on GST

The accuracy of GSTR 9 is very crucial as it is one of the main components of the reconciliation statement. It is consolidated information from relevant years GSTR 1, GSTR 3B and GSTR 2A. The sales details and GST outward are derived from GSTR 1, and the during-the-year purchase details are captured from GSTR 2A. Information about the tax paid and the input tax credit is taken from GSTR 3B. GSTR 9 is a type of cross verification, and if any additional tax payable arises, it would be paid before filing of GSTR 9. 

Multiple GSTR 9C for a Single Taxpayer

The GSTR 9C is GSTIN specific. A person holding multiple GSTINs must file a separate GSTR 9C for each GSTIN. But the year’s audited financial statement is in respect of the taxpayer’s PAN. GSTIN is state-specific, so a single person can hold more than one GSTIN. But a single PAN is for complete India. Thus the total turnover, tax and ITC as per the audited financial statement is needed to be bifurcated among different GTINs. The bifurcated detail will be used in filing respective GSTR 9C. 

Applicability of GSTR 9C for the Year 2021-22

Section 44 of the Central Goods and Service Tax Act is amended by notification no. 29/2021. As per the amendment section, registered taxpayers whose annual turnover exceeds 2 crores in a year are compulsorily required to file annual returns along with GST reconciliation statements GSTR 9C. The form is exempted for taxpayers whose turnover is below 2 crores. Following are the other classes of taxpayers who are exempted from filing GSTR 9C:

  • Casual taxable person 
  • Input service distributor
  • Non-resident taxable person
  • Person supplying OIDAR (online Information database access and retrieval) services from outside India to the unregistered persons in India. 
  • Government departments that are subjected to audits by the CAG (Comptroller and Auditor General of India)
  •  Composition scheme taxpayer
  • Taxpayers who deduct TDS and collect TCS

The section also provides power to the commissioner on the recommendation of the GST council can provide relaxation from GSTR 9C to a particular class of taxpayers.

Also read: GST Number Search: 15 Digits Every Business Needs

Due Date of Filing GSTR 9C

As GSTR 9C is filled after the annual return GSTR 9, thus the due date of filing of both returns is the same. It should be filed on or before 31st December of the year next to the relevant financial year. 

For example, the GSTR 9C for April 2021- March 2022 will be filed on or before 31st December 2022.

GSTR 9C Format

The reconciliation statement GSTR 9C is divided into two parts:

  • Part one is the main body of the return, and it is the Reconciliation Statement.
  • The second part is Self-Certification. Earlier it required certification by a Chartered Accountant or Cost Accountant, which is no longer applicable.

Let’s look into the format in detail.  

Part-A: Reconciliation Statement

It is further divided into two five parts. Let’s look into each division.

  • Part 1: Basic Details.

This section contains general information about taxpayers. It contains:

  1.  Financial year
  2. GSTIN of taxpayer
  3. The legal name of the business
  4. Trade name
  5. Mention the act under which the taxpayer is liable for audit. To be filled only when 
  • Part 2: Reconciliation of turnover declared in the audited Annual Financial Statement with turnover declared in Annual Return (GSTR 9).

Under this part, the turnover under audited accounts is reconciled with the turnover declared in GST annual return. In the case of Multi-GSTINs, the audited account’s turnover is broken to the relevant GSTIN. Reasons for such differences should accompany each unreconciled item reported in GSTR 9C. 

  • Part 3: Reconciliation of tax paid.

Similarly, like part 2 here, tax liability as per audited financial statements is compared with tax paid under Annual Report GSTR 9. The taxpayer has to report rate-wise GST payable details. In the case of differences in reconciliation, there will be an additional tax liability. The form required to specify the reasons behind such differences and state that payment of such additional liability has been made. 

  • Part 4: Reconciliation of Input Tax Credit (ITC).

Here, ITC availed and utilised as per the annual audited financial statement is reconciled with the ITC claimed in the Annual Return GSTR 9. 

The taxpayer reports expenses as per accounts along with details of eligible and ineligible ITC. In this part, the ITC booked in the earlier financial year and claimed in the current financial year will be added to the ITC availed as per audited accounts.  And ITC booked in this year which should be claimed in the upcoming year, will be subtracted will reconciling.

Part-B: Self Certification 

The earlier part B was for CA or CMA certification, but by the recent amendment, form GSTR 9C is required to be self-certified by the taxpayer.

How to File GSTR 9C?

You can file GSTR 9C in two ways, and it can be filed online on the GST portal or offline by using GSTR 9C offline utility. Let’s look into both procedures.

Online Procedure to file GSTR 9C

  • First login to www.gst.gov.in
  • From the dashboard, select “Annual Return”.
  • Select the relevant financial year for which GSTR 9C is required to be filed.
  • Afterwards, select “initiate e-filing”. If you have not filled out GSTR 9, the system will ask you to file GSTR 9 first. 
  • Now proceed to file GSTR 9C. 

Offline Method of Filing GSTR 9C

  • First, download the offline utility for this visit www.gst.gov.in, then go to downloads, click on offline tools, select GSTR 9C offline tool, and download the zip file.
  • Unzip the offline utility.
  • There will be a file “Read me” in the utility folder, and it has all the instructions that need to be followed. 
  • Fill out the worksheet for GSTR 9C
  • After this, create the JSON file.
  • Now JSON file is uploaded on GST portal, for this login to www.gst.gov.in go to return dashboard and select “Annual Return”
  • Now Select the relevant assessment year. 
  • Select “Prepare Offline”, and then click on the upload option and upload the JSON file.
  • After uploading the file, preview the return before submitting it.   
  •  Now submit the GSTR 9C.

 Also read: All you need to Know About GST Certification Course | Legaltree

Conclusion

Now you have a better understanding of GSTR 9C,  its applicability, the due date of filing the form, its format and the procedure to file it. By referring to the applicability section of the article, you will easily know whether you are exempted from GSTR 9C or covered by it and can easily file GSTR 9C form from the GST portal. 

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