GSTR-9C is the annual reconciliation statement that bridges the gap between your audited financial statements and your GST annual return (GSTR-9). Mandatory for taxpayers with aggregate turnover exceeding ₹5 crore. Self-certified from FY 2020-21 onwards.
| Period | Requirement | Status |
|---|---|---|
| FY 2017-18 to 2019-20 | CA/CMA certification mandatory if turnover > ₹2 Cr | Archived |
| FY 2020-21 onwards | Self-certification by taxpayer (CA certification removed) | Current |
| FY 2023-24 onwards | Mandatory for turnover > ₹5 Cr. Self-certified. Filed along with GSTR-9. | Current |
Reconcile turnover declared in audited financial statements with turnover declared in GSTR-9 annual return. Identify and explain differences — unbilled revenue, advances, adjustments, credit notes.
Reconcile tax paid as per audited accounts with tax paid as per GSTR-9. Map output tax, ITC claimed, ITC reversed, and net tax payable. Explain any tax differences.
Reconcile Input Tax Credit as per books of accounts with ITC claimed in GSTR-9. Cover ITC availed vs eligible, ITC reversed, ITC on expenses, and ITC lapsed.
Report any additional tax liability payable due to non-reconciliation. Tax, interest, and late fee payable after reconciliation. Must be paid through DRC-03.
Under old rules (pre FY 2020-21): CA/CMA recommendations. Under current self-certification: Taxpayer's declaration on correctness of reconciliation.
Key items to reconcile between audited financials and GSTR-9:
| Item | Source | Match With GSTR-9 |
|---|---|---|
| Turnover as per Books | Audited P&L Statement | Table 5 of GSTR-9 (Total Turnover) |
| Unbilled Revenue | Revenue recognition (Ind AS / AS) | Not in GSTR-9 — explain difference |
| Advance Received | Liability side of Balance Sheet | Table 4 of GSTR-9 (Advances) |
| Credit Notes Issued | Sales Register / ERP | Table 4 of GSTR-9 (CN adjustments) |
| ITC as per Books | GST Input Ledger | Table 6-8 of GSTR-9 (ITC claimed) |
| ITC Reversed | Rule 42/43 calculations | Table 7 of GSTR-9 (ITC reversed) |
| Tax Paid | Electronic Cash & Credit Ledger | Table 9 of GSTR-9 (Tax Paid) |
GSTR-9C is filed as a part of GSTR-9. Ensure your annual return (GSTR-9) is accurately prepared before starting the reconciliation statement.
Obtain audited financial statements — P&L account, Balance Sheet, and Tax Audit Report (Form 3CD if applicable). These are the basis for reconciliation.
Compare gross turnover in audited financials with GSTR-9 turnover. Account for unbilled revenue, advances, deemed supplies, SEZ supplies, and adjustments.
Reconcile tax payable per audited accounts with tax declared in GSTR-9. Map CGST, SGST, IGST, and Cess. Explain any differences.
Match ITC in books with ITC in GSTR-9. Account for ITC on expenses not in GST returns, ITC booked but not claimed, ITC reversed under Rule 42/43.
Calculate any additional tax payable due to reconciliation differences. Pay through Form DRC-03 (voluntary payment).
Login → GSTR-9 → Scroll to GSTR-9C section → Upload reconciliation → Self-certify → File via DSC or EVC.
Typical mismatches found during GSTR-9C preparation and how to resolve them:
Revenue recognition timing — accrual basis in accounts vs invoice date in GST
Report in Part A with explanation. No additional tax if already paid.
ITC booked in accounts but not eligible under GST (personal use, blocked credits under Sec 17(5))
Reverse excess ITC in Part C. Pay additional tax via DRC-03 with interest.
Rate differences, classification errors, or missed invoices in GST returns
Declare in Part D. Pay differential tax + 18% interest via DRC-03.
CN issued in books before GSTR-1 filing or CN rejected by recipient
Adjust in Part A turnover reconciliation. Ensure CN is within the time limit.
Every registered taxpayer whose aggregate turnover in a financial year exceeds ₹5 crore must file GSTR-9C along with GSTR-9. From FY 2020-21 onwards, it is self-certified by the taxpayer — no CA/CMA certification required.
GSTR-9C is filed along with GSTR-9. The due date is December 31 of the year following the financial year. For FY 2025-26, the due date would be December 31, 2026 (unless extended by the government).
Non-filing of GSTR-9C can attract a general penalty under Section 125 of the CGST Act — up to ₹25,000. Additionally, if the reconciliation reveals unpaid tax, interest at 18% p.a. will apply from the due date.
Yes, from FY 2020-21 onwards, GSTR-9C does not require a statutory audit. It is a self-certified reconciliation statement. However, you still need audited financials if your turnover exceeds tax audit thresholds under Income Tax Act.
If GSTR-9C shows you paid more tax than required, you cannot directly claim a refund through the reconciliation. You must file a separate refund application under Section 54 for the excess amount paid.