What is GSTR 9C Reconciliation statement and certification? Who need to filed GSTR 9C?

What is GSTR-9C?

It is a reconciliation statement between the annual returns filed in GSTR-9 and the taxpayer’s audited annual financial statements.

The form will contain the taxpayer’s gross and taxable turnover according to their accounting books, reconciled with the corresponding figures after consolidating all of their GST returns for the financial year, and any difference revealed by the reconciliation. The difference, and the reason for it, should be mentioned explicitly (i.e., in a clear and detailed manner).

 

Who needs to file GSTR-9C?

If the annual turnover of a registered taxpayer is more than Rs.2 crores in a financial year, he is required to get his accounts audited by a Chartered Accountant or Cost Accountant every year.

Note- For businesses with an annual turnover of less than Rs.5 crores, filing of GSTR-9C for FY 2018-19 is waived off.

 

What includes in aggregate turnover?

The term Aggregate Turnover (AT) is defined as PAN based turnover for a particular financial year which means that calculation of AT must be PAN-based. Therefore, once the turnover under the PAN is more than Rs.2 crores all business entities registered under GST for that PAN will be liable for GST audit for a financial year.

Items included while calculating turnover:

• All taxable (inter-state and intra-state) supplies other than supplies on which reverse charge is applicable.
• Supplies between separate business verticals.
• Goods supplied to/received from job worker on principal to principal basis.
• Value of all export/zero-rated supplies.
• Supplies of agents/ job worker on behalf of the principal.
• All exempt supplies. E.g. Agricultural produce supplied along with branded ready-to-eat food.
• All taxes other than those covered under GST.

Items excluded while calculating turnover:

• Inward supplies on which tax is paid under reverse charge.
• All taxes and cess charged under Goods and Service Tax like CGST, SGST or IGST, Compensation Cess.
• Goods supplied to or received back from a Job Worker.
• Activities which is neither supply of goods nor service under S-III^rd of CGST Act.

 

Due date for filing GSTR-9C form

The due date for submitting the Annual returns in GSTR-9 is the same deadline for submission of GSTR-9C. Hence, the GSTR-9C must be filed on or before 31st December of the year subsequent to the relevant FY under audit. The due date can be extended by the Government if deemed necessary.

 

Notification as on 5^th May 2020:

The due date of filing GSTR-9 & GSTR-9C for the FY 2018-19 now stands extended up to 30th September, 2020.

Penalty and late fees for failing to file GSTR 9 & 9C on time?

The late fees for not filing of GSTR-9 within the due date are Rs100 per day under CGST & SGST each. Thus, the total liability is Rs200 per day of default. This is subject to a maximum of 0.25% of the taxpayer’s turnover in the relevant state or union territory.

 

Note- CBIC vide press release dated 14 March 2020 stated that No Late fees for delayed filing of the Annual Return for the financial year 2017-18 and 2018-19 for taxpayers with aggregate turnover less than Rs.2 crores.

 

However, there is no specific provision for GSTR-9C late fee. But subjects to a general penalty of Rs.25000.

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