What are GSTR-9 and 9C? Difference, Turnover Limit & Due Date

Filing GST annual returns is one of the most important compliance obligations for registered businesses in India. Every taxpayer registered under the Goods and Services Tax (GST) regime must understand the difference between Form GSTR-9 and Form GSTR-9C to avoid penalties, reconcile tax records, and ensure accurate reporting for the financial year.

GSTR-9 is the annual GST return that registered taxpayers must file to summarize their entire year’s business transactions. On the other hand, GSTR-9C is a reconciliation statement that a chartered accountant or cost accountant prepares alongside the annual return. It certifies that the data in GSTR-9 matches the company’s audited financial statements.

GSTR 9 and 9C Applicability

To understand the basic difference between GSTR 9 and 9C, one first needs to clearly know their usage. The applicability of these GST return filing forms depends on specific criteria related to turnover and business type:

GSTR-9 Applicability

GSTR-9 is required to be filed for:

• All registered taxpayers under GST (except those filing GSTR-4)
• Composition dealers who file quarterly returns
• Input Service Distributors (ISDs)
• Non-resident taxable persons
• Casual taxable persons (with certain conditions)

GSTR-9C Applicability

GSTR-9C filing is mandatory for:

• Regular taxpayers whose aggregate turnover exceeds Rs. 5 crores during the financial year
• Companies need to get their accounts audited under the Companies Act, 2013
• Taxpayers who have claimed Input Tax Credit (ITC) over a specified threshold

It’s important to note that composition dealers, Input Service Distributors, and casual taxable persons are generally exempt from filing GSTR-9C.

GSTR 9 and 9C Turnover Limit

The turnover limits play a crucial role in determining filing obligations. The applicability of GSTR-9 and GSTR-9C depends primarily on your annual aggregate turnover during the financial year:

For GSTR-9:

• Registered taxpayers under GST must file if their annual turnover limit exceeds Rs. 2 crores.
• All taxpayers with GST registration must file, regardless of turnover (with specific exemptions)

For GSTR-9C:

• Mandatory for taxpayers with aggregate turnover exceeding Rs. 5 crores
• Optional for taxpayers with a turnover below Rs. 5 crores
• The turnover is calculated based on the value of supplies made during the financial year.

This turnover threshold has been revised over the years, initially being set at Rs 1 crore, then 2 crores and now Rs 5 crores, effective from August 1, 2021, to reduce compliance burden on smaller businesses.

Who Can File GSTR 9 and 9C?

Not every GST-registered taxpayer needs to file both GSTR-9 and GSTR-9C. The applicability of each form varies based on business turnover and GST audit provisions. Let’s know who the authorized personnel are for filing annual GST returns and certification requirements.

Must hold a valid authorization from the taxpayer	Who Can File / Certify	Conditions / Authorization Required
GSTR-9 (Filing Authority)	Registered taxpayers	Must be GST-registered and responsible for annual return filing
	Authorized representatives	Must hold valid authorization from the taxpayer
	Tax practitioners	Must be registered as GST practitioners and duly authorized
	Company Secretaries (CS), Chartered Accountants (CA), Cost Accountants (CMA)	Must have proper power of attorney or authorization letter
GSTR-9C (Certification Authority)	Chartered Accountants (CA)	Must be members in practice with a valid Certificate of Practice
	Cost Accountants (CMA)	Must be members in practice with a valid Certificate of Practice

GSTR 9 and 9C Due Date and Late Fees

The GSTR-9 and 9C differences can also be identified from their filing dates. While both forms relate to annual GST reporting, their filing timelines and penalty structures differ.

Due Date for GSTR-9

The due date for filing GSTR-9 is generally 31st December of the financial year following the relevant FY. For example, for FY 2024–25, the due date is typically 31st December 2025.

However, the government may extend this deadline through official notifications, so taxpayers should regularly check updates from the GST portal or the CBIC.

Due Date for GSTR-9C

The due date for GSTR-9C is usually the same as GSTR-9, i.e., 31st December following the end of the financial year, unless extended by the government. Since GSTR-9C involves reconciliation with audited financial statements, taxpayers should plan the audit process well in advance to meet the deadline.

GSTR 9 and 9C late fees are applicable when returns are filed after the due date:

GSTR-9 Late Fees

• Rs 200 per day of delay (Rs 100 under CGST + Rs 100 under SGST)
• Maximum late fee capped at 0.25% of the turnover in the state/union territory
• For nil returns or where no tax is payable, a nominal fee of Rs 100 under CGST and Rs 100 under SGST applies

GSTR-9C Late Fees

• Rs 200 per day of delay until the return is filed
• No separate provision for capping the late fee for GSTR-9C
• The late fee continues to accumulate until the form is submitted.

Difference Between GSTR 9 and 9C

For a quick preview, let’s understand the difference between GSTR-9 and 9C:

Aspect	GSTR-9	GSTR-9C
Nature	Annual Return	Reconciliation Statement
Filed by	Taxpayer	Certified by CA/CMA
Applicability	All registered taxpayers	Turnover > Rs 5 crores
Purpose	Consolidate annual transactions	Reconcile with the financial statements
Sections	Multiple sections covering supplies, ITC, and tax paid	Fewer sections focusing on reconciliation
Dependency	Independent filing	Must accompany GSTR-9
Verification	Self-certified	Professional certification required

Essential Checklist Before Filing GSTR 9 and 9C

You need to ensure compliance before the pre-filing of GSTR 9 and 9C:

Monthly/Quarterly Return Verification

• Ensure all GSTR-1 (outward supplies) returns are filed accurately and on time.
• Complete GSTR-3B (summary return) filings with proper tax liability calculations.
• Cross-verify data consistency between GSTR-1 and GSTR-3B to avoid mismatches.

Input Tax Credit Management

• Complete all pending input tax credit (ITC) claims before filing annual returns.
• Verify ITC eligibility against purchase invoices and ensure proper documentation.
• Address any blocked or restricted credits that may impact your final liability.

Tax Payment Reconciliation

• Resolve any inconsistencies between the tax calculated and the tax paid.
• Clear pending dues or excess payments through proper adjustment mechanisms.
• Maintain accurate cash ledger balances to avoid payment-related complications.

How to File GSTR-9 and GSTR-9C?

Filing GSTR-9 and 9C can be performed via the GST portal:

• Log in to the GST portal and go to Returns → Annual Return.
• Select the relevant financial year and review auto-populated data from GSTR-1 and GSTR-3B.
• Verify details, make necessary disclosures, pay any pending tax, and submit GSTR-9 using DSC or EVC.
• Reconcile GSTR-9 with audited financial statements for GSTR-9C.
• Get GSTR-9C certified by a CA or CMA and upload it along with audited statements on the GST portal using DSC.

Pro Tips

• Maintain proper records: Your invoices and vouchers are your first line of defense in any GST audit.
• Regular reconciliation: Monthly reconciliation saves you from year-end panic and costly surprises.
• System integration: Reliable accounting software doesn’t just generate reports – it protects your business reputation.
• Professional assistance: GSTR-9C is complex enough to justify expert help – don’t let pride cost you compliance.

Ready to transform your GST compliance from a burden into a competitive advantage? Contact RegisterKaro for a free consultation and let our expert optimize your tax process.

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