Understanding the Difference Between GSTR-9 and 9C

What is GSTR 9 and 9C?

GSTR-9 is the annual GST return that registered taxpayers must file to summarize their entire year’s business transactions. It consolidates all supplies made, input tax credits claimed, and taxes paid during the financial year. This return helps reconcile monthly or quarterly filings.

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. This form ensures the figures reported in the annual return align with the business’s official books of accounts.

GSTR 9 and 9C Applicability

The applicability of these forms depends on specific criteria related to turnover and business type:

GSTR-9 Applicability

• 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 audit under the Companies Act, 2013
• Taxpayers who have claimed input tax credit 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:

For GSTR-9:

• No specific turnover limit for filing
• All registered taxpayers 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?

Let’s know who the authorized personnel are for filing annual GST returns and certification requirements.

GSTR-9 Filing Authority

• The registered taxpayers
• Authorized representatives with proper authorization
• Tax practitioners with valid authorization
• Company secretaries, chartered accountants, or cost accountants with appropriate power of attorney

GSTR-9C Certification Authority

GSTR-9C can only be certified by:

• Chartered Accountants (CAs)
• Cost Accountants (CMAs)
• Both must be members in practice and hold valid certificates of practice.

The professional certifying GSTR-9C must ensure proper reconciliation between the annual return and audited financial statements.

GSTR 9 and 9C Due Date and Late Fees

For GSTR 9 and 9C due date for filing is December 31st of the subsequent financial year.

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 see understand the difference: 

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.

GST Compliance: Common Challenges & Pro Tips

Let’s explore the complexities of GST compliance to be aware of and avoid costly pitfalls.

1. Books vs Returns Reconciliation

The Challenge: Significant differences often emerge between your accounting records and GST return figures, creating compliance gaps and potential audit triggers.

Impact: Discrepancies can lead to notices, penalties, and extended audit processes that disrupt business operations.

2. HSN Code Classification Errors

The Challenge: Incorrect Harmonized System of Nomenclature (HSN) code selection leads to wrong tax rates and compliance issues.

Impact: Misclassification can result in differential tax demands, interest charges, and reputation damage with tax authorities.

3. Input Tax Credit Complications

The Challenge: Managing ITC reversals, adjustments, and ensuring proper documentation for claims becomes increasingly complex with business growth.

Impact: Incorrect ITC handling can trigger recovery demands and block future credit availability.

4. Turnover Calculation Accuracy

The Challenge: Determining accurate turnover figures while accounting for exemptions, adjustments, and various transaction types.

Impact: Incorrect turnover reporting affects tax liability calculations and compliance thresholds.

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.

Frequently Asked Questions (FAQs)

1. Who is required to file GSTR-9?

All registered taxpayers under GST, excluding composition dealers, Input Service Distributors (ISDs), non-resident taxable persons, and casual taxable persons, must file GSTR-9 annually.

2. Who needs to file GSTR-9C?

Taxpayers whose aggregate turnover exceeds Rs 5 crore in a financial year are required to file GSTR-9C along with GSTR-9.

3. What are the due dates for filing GSTR-9 and GSTR-9C?

Both GSTR-9 and GSTR-9C must be filed by December 31st of the year following the relevant financial year, unless extended by the government.

4. What are the late fees for not filing GSTR-9 on time?

The late fee for GSTR-9 is Rs 200 per day of delay (Rs 100 under CGST and Rs 100 under SGST), subject to a maximum of 0.25% of the taxpayer’s turnover in the respective state or union territory.

5. Is there a late fee for GSTR-9C?

While there is no specific late fee prescribed for GSTR-9C, failure to file it along with GSTR-9 can attract a general penalty under Section 125 of the CGST Act, which may extend up to ₹25,000.

6. Can a taxpayer revise GSTR-9 or GSTR-9C after filing?

No, once filed, GSTR-9 and GSTR-9C cannot be revised. Therefore, it’s crucial to ensure accuracy before submission.