GSTR 9C: Eligibility, Documents Required & Filing Procedure

GST or Goods and Services Tax introduces a boosting impact on the economic growth of India. Over time, India has implemented this to help the country thrive and keep itself protected under the laws. GSTR 9C is one such instance that was introduced on September 13, 2018. However, it has to be filed by taxpayers only under certain conditions.

This article gives an in-depth idea of it along with how to fill GSTR 9C accurately and related guidelines. Now, let’s look at these facts to understand their significance.

GSTR 9C is an annual audit form applicable for every taxpayer who surpasses a turnover of ₹5 crores within a particular financial year. The taxpayer also has to fill up a reconciliation statement along with the GSTR 9C audit form.

Moreover, the authorities of the GST Council have also introduced the format in Notification No. 49/2018 under Central-tax dated September 13, 2018.

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According to the recommendations of the 43rd GST Council, taxpayers holding an aggregate turnover of ₹5 crores may self-certify their GSTR 9C for the financial years 2020 and 2021. However, businesses acquiring a turnover of more than ₹5 crores are mandatory to file a Form GSTR 9C along with a reconciliation statement and certification of an audit within a financial year.

For every taxpayer having a turnover of between ₹2 crores to ₹5 crores, it is optional to file a GSTR 9C form. This also means taxpayers holding a turnover of less than ₹2 crores are not applicable for filing a return.

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To file a GSTR 9C form, there is a certain eligibility factor taxpayers must keep in mind. Every taxpayer whose aggregate turnover in a financial year exceeds ₹ 5 crores is eligible to file for a GSTR 9C.

However, one must file the same through the GST portal or at a facilitation centre. In addition, when filing the GSTR 9C, a taxpayer must attach necessary documents which include the annual returns and also a copy of the audited accounts.

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There is an investigation of records, returns, and audits for all the additional documents maintained through enrolled individuals under the audits of GST. This audit monitors the accuracy of given turnovers, and taxes that are filed if the refund is available. Also, it certifies if there is a claimed ITC, and validates other additional things that are essential for investigation through the expert authority.

The types of GST audits under GSTR 9C are as follows:

• Turnover-Based GST Audit: Aggregate turnover is an essential parameter to decide the eligibility of a supplier for availing benefits. Chartered Accountants implement this type of audit. They execute an audit if a turnover surpasses an amount of ₹ 5 crores under the CGST Act.
• Normal Audit Under GS: Generally, the commissioner of CGST or SGST, or any officer with the commissioner's permission executes a normal audit. These types of audits will be executed within a notice of 15 days before the commissioner.
• Special GST Audit: Special GST audits are executed by CA or Chartered Accountants appointed by a commissioner. To implement the audit, these professionals have to get an order from the Deputy or Assistant Commissioner along with the permission of the commissioner.

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To file a GST audit form, an individual has to pass through two major sections of this form. These sections are as follows:

• Part A: Reconciliation Statement
• Part-B: Auditor Certification

Now, let’s understand these sections one by one.

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Part 1: Basic Details

This part has 4 major sections. They are as follows:

• Fiscal year
• GSTIN of taxpayers
• Legal name and trade name of the registered authority
• Answer if the taxable individual is liable for audit

Part 2: Reconciliation of Turnover

This part consists of a reconciliation of turnover that declares evaluating an entity’s audited Annual Financial statement and the turnover declaration of GSTR 9 or Annual Return.

Part 3: Reconciliation of Tax Payment

This part refers to the details regarding the reconciliation of the rate-wise amount and liability.

Part 4: Reconciliation of ITC (Input Tax Credit)

This part contains the reconciliation of the net ITC or Input Tax Credit as per the accounting books and the amount of Input Tax Credit mentioned in the Annual Return.

Part 5: Additional Liabilities Due to Non-Reconciliation

This segment incorporates the auditor's suggestions regarding those additional liabilities that a taxpayer releases due to non-reconciliation of ITC or turnover.

This section is basically a certificate that has to be furnished by a Chartered accountant or CA. Generally, this part comes only after the GSTR 9 audit. However, it includes two crucial components. These are as follows:

• Certification for GSTR 9C where individuals have to undergo their execution of audits.
• Audits are entrusted on the basis mentioned by the auditor.

After understanding the formats of a GST audit return, it is beneficial to know how to file it properly. To help we have provided a detailed step-by-step filing process for GSTR 9C below

Taxpayers have to go through some steps to file GSTR 9C JSON files offline through the GST portal. These steps are as follows:

Step 1: Visit the GST portal and log in using a proper username and password.

Step 2: Download the Annual Return form.

Step 3: Now, download the GSTR 9C tables extracted from GSTR 9.

Also, one must also download the 'GSTR 9C Offline Tool’ to access this form through offline utility.

Step 4: To download the offline tool, click on "Offline Tools" and then select "GSTR 9C Offline Tool”.

To prepare the GSTR 9C through the offline tool, one must follow the steps below.

Step 5: Open the Offline Utility Worksheet of GSTR 9C and fill in with relevant information into the tables of the worksheet.

Step 6: Generate the preview of this return form of GSTR 9C to view the draft version of this return.

Step 7: Upon doing this, a JSON file will be generated.

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To Upload GSTR 9C JSON File on the GST Portal

Step 8: Once the JSON file is generated, login to the GST portal through the GSTR 9C Offline Utility.

Step 9: Upon logging in, go to "Annual Return" select 'Accurate Financial Years', and click on "Search".

Step 10: When the next page will open, click on “Prepare Offline” and select “Upload”.

If there is any requirement to make changes in the GSTR 9C form, a taxable individual has to perform it before selecting “Proceed to File”. Once these changes are made, the JSON file will be generated again. Then one has to upload it once again through GSTR 9C Offline Utility.

However, if the JSON file reflects any error while uploading, a taxpayer can download that Error Report, perform required corrections and upload the updated version of a JSON file. After that one can proceed toward the next steps to initiate his/her filing process.

Step 11: After uploading the JSON file on this GST portal, a taxpayer has to provide the financial statements such as a balance sheet, profit, and loss statement, or other relevant documents after the verification.

However, it is essential to note that these documents must be in PDF format while uploading. The file size should not cross the limit of 5 MB and there should be only 2 files uploaded in each section.

Step 12: While uploading these necessary documents, click on “Save” after uploading each document. It will show a status as “Processed”.

Otherwise, an error message will occur displaying the users to select “PROCEED TO FILE” if one does not save that document after uploading.

However, the “Proceed to File” option will enable only after you upload certain documents successfully. These include:

• Generated JSON file
• Profit and Loss Account in PDF format
• Balance Sheet in PDF format

Step 13: Now, after enabling this “PROCEED TO FILE” option, one can get a preview by selecting “Preview Draft GSTR 9C (Preview)”to view the draft.

Step 14: After selecting ‘Proceed’ for filing, the page will redirect to the ‘Verification Page’ in which every given detail will be confirmed.

Step 15: Once the verification is complete, it will enable the "File GSTR 9C" option which is the final step towards filing a GST form once a user proceeds to it.

Step 16: After completing this filing process, a taxpayer can track it from the "Services" tab of the GST portal.

Step 17: Now, select “Returns” from its dropdown list and click on “View Filed Returns” to get a view of that form.

Having discussed the filing procedure through these steps, there is another crucial thing to keep in mind. Let’s find out which are the compulsory documents for filing a GST-9C return.

An assessee requires to have these mandatory credentials for filing a form of GSTR 9C mentioned below:

• Copy of balance sheet
• Copy of audited accounts
• Copy of the annual report
• Cash flow statement
• Documents of Profit and Loss account or Income or Expenditure account
• The annual audited report is when the audit of an individual has been executed under the legal supervision of a professional.

Now, let’s look at the most important thing while filing a GSTR 9C which is, about the due date. As a taxpayer, it is equally necessary to monitor due dates beside a filing process or necessary credentials to avoid unnecessary interests.

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Due dates are crucial for registered businesses and professionals to file GST returns to avoid any late fees and interests as per the laws of GST. However, taxpayers have to file this return form of GSTR 9C either at the time of filing or after filing a GSTR 9.

The Government of India has declared the due dates for a GSTR 9C or Reconciliation Statement for the FY 2022-23 to be within 31st December of the next financial year. That is to say, if a taxpayer misses out on 31st December of 2023 for FY 2022-23, then he or she has to bear the consequences.

The Council of GST implements rules and regulations to introduce a uniform taxation system and restrict tax evasion in the country. This is why the GST Council has initiated new additions or constitutional amendments with time. These recent amendments include:

5th July 2022

According to an amendment, the Central Board of Indirect Taxes & Customs (CBIC) has freed registered taxpayers of GST who have an annual aggregate turnover of up to ₹2 crores in FY 21-22 from filing a GSTR 9 form.

Now, let’s find out what the penalties are for not filing a GSTR 9C form on time as applicable for taxable individuals.

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As there is a deadline for filing a form of GSTR 9C regulated under GST guidelines, taxpayers need to do this on or before 31st December of the following year. However, if any taxpayer delays filing then there will be consequences under the laws of GST. The rules to protect this law are as follows:

• A taxpayer is responsible for paying a penalty of ₹ 200 (₹100 for CGST and ₹100 for SGST) for each day after missing a due date under the penalty clause of a GSTR 9C audit form.
• A maximum late fee cannot exceed an amount of 0.5% of the entire turnover on which the GST has been filed. For instance, if a business has an annual turnover of ₹ 50,000,000 then the late fee cannot be above ₹ 250,000.

The government can decide whether to waive a portion of the late fee amount.  However, it is only applicable to a section of taxpayers, depending on special grounds. This process goes through a notification based on the recommendation of the GST Council. However, the State or Central Government cannot waive such notifications to date.

Thus, it is essential to keep a track of your due date while there is a turnover above ₹ 5 crores. It will assure that you do not have to bear any penalty or other hassles.

As per the regulations of GST, every taxpayer must prepare and self-certify a GSTR 9C. However, there are some essential things to keep in check while filing a GSTR 9C. These things are as follows:

• Taxpayers should file this GST return through the GST portal or a facilitation centre.
• A taxpayer must have the necessary credentials such as a copy of Audited Accounts and Annual Return in a GSTR 9C form. This is suitable for every taxpayer who has done their audit of Annual Accounts under GST laws.
• An audit is applicable for those individuals whose annual aggregate surpasses ₹ 5 crores for that financial year.
• According to CBIC’s CGST Notification No. 30/2021 of 30th July 2021, every foreign company involved in the airline business or abiding by the provisions of the Companies Act 2013 are not applicable for filing a GSTR 9C.
• Non-Resident OIDAR services providers in India to non-registered persons are not liable for filing a return form of GSTR 9C.

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As a form of GSTR 9C that includes the gross and taxable turnover of a taxpayer, it provides the differences between details mentioned in GST returns and the Audited Accounts.

• This statement functions as base information for GST authorities to verify the accuracy of the GST returns filed by businesses or other entities.
• The taxpayers must always self-certify a form of GSTR 9C.

However, besides verification of compliance with the regulations under the GST regime, a GST audit educates a registered taxpayer on the importance of being more compliant with this procedure and the law.

Understanding all these aspects of filing a GSTR 9C is crucial for every concerned individual to monitor their businesses. Thus, refer to the above information to know when to file it, how and the consequence of not filing it.