What is GSTR 9C (GST Audit Form)?
GSTR 9C is an annual audit form for all the taxpayers having the turnover above 2 crores in a particular financial year. Along with the GSTR 9C audit form, the taxpayer will also have to fill up the reconciliation statement along with the certification of an audit.
Under this, the authorities have also introduced the format of GSTR 9C in the notification No. 49/ 2018 – Central tax dated September 13, 2018.
SAG Infotech is here to provide all the relevant details of GSTR 9 and 9C form and step by step procedure to file them along with the screenshots. The GSTR 9C form has a reconciliation statement for reconciling turnover, input tax credits and tax payments. The taxpayers can also view and download the GSTR 9C form in PDF format.
39th GST Council Meeting Update
“GST council relieved the MSMEs to furnish reconciliation statement in the form GSTR 9C for FY 2018-19 for aggregate turnover of INR 5 crore.”
“Reconciliation Statement and annual return for financial year 2018-19 due date extended till 30th June 2020”. Note: The last is extended by government of India till 30th September 2020
“Annual return and the Reconciliation Statement for financial year 2017-18 and 2018-19 late filing penalty waived off for the taxpayers having turnover lower than Rs. 2 crores. Read Official Press Release“
|Sales||GSTR 9||GSTR 9C|
|Up to 2 Cr||Optional||N/A|
|More than 2Cr. – 5 Cr||Filling is mandatory||Optional (Benefit Given)|
|More than 5Cr||Filling is mandatory||Filling is mandatory|
While doing the GSTR 9C audit, the following points have to be verified
Reconciling GSTR 3B vs. GSTR 1 vs. GSTR 9 vs. Books Reconciling GSTR 3B vs. GSTR 2A vs. GSTR 9 vs. Books Is there any delay in filing GSTR 3B.?
If yes, whether interest paid or not.? Whether the taxpayer claimed any ineligible credit.?
In the case of common input, whether Rule 42 and 43 are followed or not.?
In case the taxpayer is supplying exempted goods, then whether ITC on purchase of goods or services for such supply was reversed or not In the case of FY 2017-18, whether the reverse charge was paid till 13-10-2017 under section 9(4) or not Is there any reverse charge invoice in GSTR 2A(besides this, books also to be verified to know whether any supply was there on which GST has to be paid under reverse charge) and whether the taxpayer had paid the same or not
In case of any mistake in GST returns, whether the same are rectified by amendment or not.?
If rectified, then in which month and scope of interest on the same Is there any other income in income tax return other than those specified in GST returns.?
If yes, then taxability of such income in GST Is there any demand raised against the taxpayer.?
If yes, then whether the same was solved or still pending and the effect of such order on GST returns Is there any consideration received for the disposal of business assets.?
If yes, then the taxability of such supply else then the applicability of schedule I.
Whether any advances received?
If yes and if the intended supply is service, then taxability of such advance.
In case, GST was paid in the month of service provided then interest in delay between the months of advance received and GST paid. Verifying the valuation rules wherever applicable
Simplify GSTR 9C Filing by CBIC
Some exemptions has been done in this form listed below:
Part of turnover adjustments necessary in Table 5B to 5N is now not mandatory and all the adjustment now necessary to be described in Table 5O;
Table 12B, 12C and 14 (ITC reconciliation) are now not mandatory;
Few changes are done in the Declaration part also.
What is GSTR 9C Annual GST Audit Form?
As per the rules, all the taxpayer will have to file an annual return form with GSTR 9 but now in an addition to the current rule, Section 35 of CGST Act, 2017, all those taxpayers having turnover exceeding 2 crores in a financial year will have to submit audited annual accounts along with a reconciliation statement in GSTR 9C form.
Who is Required to File the GSTR 9C (GST Audit Form)?
All those taxpayers having the turnover above 2 crores in a financial year are required to file GSTR 9C form along with the reconciliation statement and certification of an audit.
Latest News/Updates of GSTR 9C Form
“Election Commission as per the Model Code of Conduct and Government obtaining due clearances extended the due date for furnishing Annual Return in GSTR-9 and GSTR 9C for 2018-19 from 30.09.2020 to 31.10.2020”. Read notification no. 69/2020
CBIC officially announced the due date extension of GSTR 9C from till 30th September 2020 for FY 2018-19
“The institute of cost accounts of India has requested to the ministry of finance for not increasing the threshold limit of GST Annual Return & Audit form.”
“The council extends the due date of GSTR 9 and GSTR 9C till 30th June 2020 from 31st March 2020 for the FY 2018-19. Also, the annual return filing turnover limit extended to 5 crores from 2 crores.”
“GSTR 9 & 9C filing for FY 2018-19 has live on the GST portal but in table 8A of GSTR 9 auto populate ITC as per GSTR 2A function is not working.”
GSTN recently stated the figures of eligible large taxpayers filing the annual return form GSTR 9 annual audit and form GSTR 9C coming to average 91% and 92% respectively till 12th February 2020.
The GSTN recently issued a clarification in the Auditor’s Certificate issued in Part-B(ii) of GSTR-9C (Reconciliation Statement). As per the statement issued it mentioned, “A minor issue has come to notice in auditor’s certificate issued in Part-B(ii). The issue will be fixed shortly. In the meantime, where Part-B(ii) of the certificate is not applicable i.e. auditor preparing GSTR-9C has also conducted an audit of the business and the same number is applicable, they may continue with statement preparation and filing
The given notification asserts that the amendments and relevant changes have been done in the GSTR 9 and GSTR 9C which is given in the Notification No. 56/2019 dated 14.11.2019. Also, the said changes will be reflected in the application software and the offline tools by 21st Dec. 2019.
Significance of GSTR 9C Audit Form
GSTR-9C is a reconciliation statement which must be certified by a Chartered Accountant or a CMA. Taxpayers whose aggregate turnover in a financial year exceeds Rs 2 Crores need to file GSTR-9C. The GSTR-9C must be digitally signed by the GST Auditor and must report all discrepancies or liabilities in filing any of the GST returns during the financial year. All additional liabilities arising out of the reconciliation exercise and GST audit must be reported and certified by a CS in GSTR-9C. The GSTR-9c is the only yardstick or indicator for GST Authorities to measure the correctness of GST returns filed by taxpayers during a given financial year.
Due Date Extension for Filing GSTR 9C Audit Form Under GST?
Once again, the Indian government has extended the due date of GSTR 9C (Reconciliation Statement) form for the FY 2018-19:
Financial Year 2018-19 – 31st October 2020
Financial Year 2017-18
Group 1: Chandigarh, Delhi, Gujarat, Haryana, Jammu and Kashmir, Ladakh, Punjab, Rajasthan, Tamil Nadu, Uttarakhand- 5th February 2020
Group 2: Andaman and Nicobar Islands, Andhra Pradesh, Arunachal Pradesh, Assam, Bihar, Chhattisgarh, Dadra and Nagar Haveli and Daman and Diu, Goa, Himachal Pradesh, Jharkhand, Karnataka, Kerala, Lakshadweep, Madhya Pradesh, Maharashtra, Manipur, Meghalaya, Mizoram, Nagaland, Odisha, Puducherry, Sikkim, Telangana, Tripura, Uttar Pradesh, (Corrigendum) West Bengal, Other Territory- 7th February 2020
Note: “Central Board of Indirect Taxes & Customs (CBIC) notified the amendments regarding the simplification of GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) which inter-alia allow the taxpayers to not to provide split of input tax credit availed on inputs, input services and capital goods and to not to provide HSN level information of outputs or inputs, etc. for the financial year 2017-18 and 2018-19.”
GSTR 9C Audit Form Penalty Norms If Miss the Last Date
As per the penalty provisions of GSTR 9C audit return form, the taxpayer has to pay Rs. 200 per day as a penalty in which Rs. 100 consist of SGST and Rs. 100 for CGST. Also, it is to be noted that the total penalty cannot exceed 0.50% of the total turnover on which the said penalty is being levied.
Updates in GSTR 9C Reconciliation Form By GST Council 31st Meeting
FORM GSTR-1 & FORM GSTR-3B returns are required to be filed before the filing of FORM GSTR-9 & FORM GSTR-9C
FORM GSTR-9 & FORM GSTR-9C cannot be used for availing ITC
FORM GSTR-9C would include verification by the taxpayer who had uploaded reconciliation statement
Where to Download GSTR 9C Offline Utility?
The government has released the file an annual return form with GSTR 9 which can be filed up by the taxpayers and then uploaded to the portal. The offline utility is given in a zip folder which has to be downloaded:
To download the offline utility for the GSTR 9C first visit the gst.gov.in portal
Opt on the download tab on the main menu
Now click on the offline tools in the option and it will redirect to download page
Click on download option and extract the file
Where to Find GSTR 9C Online Filing Option on Portal?
Also, there is now available GSTR 9C online utility. To start filing the GSTR 9C reconciliation audit report, perform given steps:
First of all, login with username id & password on www.gst.gov.in
After that, the dashboard will open, click on the ‘Annual Return’ tab
Now click on the financial year for the desired period to file the return, click on the FY 2017-18
An option like ‘Initiate e-filing’ will appear on the screen, click on that
But as soon as you will select the filing option, you will be asked for filing GSTR 9 form before you can file reconciliation form. Know more
Items Included While Calculating Turnover for GST Audit:
All taxable supplies, including intra-state and inter-state apart from the ones which attract a reverse charge, will be included.
Supplies involved between two business verticals
Goods or supplies that are sent/received by the job worker on principal to principal basis.
All export/zero-rated supplies
Supplies made by agent/job work on behalf of the principal
All exempt supplies
All taxes apart from the ones covered under GST. For example entertainment tax paid against the sale of tickets
Items Excluded While Calculating Turnover for GST Audit:
All inward supplies against which tax is paid under reverse charge.
All kinds of taxes and cess part of Goods and Service Tax like SGST, CGST or IGST, etc.
Goods that are received back or supplied to a Job Worker
Activities that are not part of goods or services under schedule III of the CGST Act
How to File the GST Audit Form GSTR 9C – Step by Step:
The GSTR-9 has two major parts:
Part-A: Reconciliation Statement
GSTR 9C Part-B: Certification
GSTR 9C Part-A: Reconciliation Statement Format
Part 1: Basic Details has the following four sections: Financial Year for which return is being filed.
1. Financial Year
2. GSTIN of the taxpayer
3A. Legal Name of the registered person
3B. Trade Name (if any) of the registered business
4. If the taxpayer is liable for any audit under this act?
Note: For FY 2017-18, it will contain details for July 2017 to March 2018 period.
Part 2: Reconciliation of turnover declared in the audited Annual Financial Statement with turnover declared in Annual Return (GSTR9)
5. Reconciliation of Gross Turnover
5A. Turnover (including exports) as per audited financial statements for the State / UT (For multi-GSTIN units under same PAN the turnover shall be derived from the audited Annual Financial Statement): The turnover as per the audited Annual Financial Statement shall be declared here. There may be cases where multiple GSTINs (State-wise) registrations exist on the same PAN. This is common for persons/entities with a presence over multiple States. Such persons/entities will have to internally derive their GSTIN wise turnover and declare the same here. This shall include export turnover (if any). It may be noted that reference to audited Annual Financial Statement includes reference to books of accounts in case of persons/entities having a presence over multiple States.
5B. Unbilled revenue at the beginning of Financial Year (+): Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of accounting in the last financial year and was carried forward to the current financial year shall be declared here. In other words, when GST is payable during the financial year on such revenue (which was recognized earlier), the value of such revenue shall be declared here.
C. Unadjusted advances at the end of the Financial Year (+): Value of all advances for which GST has been paid but the same has not been recognized as revenue in the audited Annual Financial Statement shall be declared here.
D. Deemed Supply under Schedule I (+): an Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017 shall be declared here. Any deemed supply which is already part of the turnover in the audited Annual Financial Statement is not required to be included here.
E. Credit Notes issued after the end of the financial year but reflected in the annual return (+): an Aggregate value of credit notes which were issued after 31st of March for any supply accounted in the current financial year but such credit notes were reflected in the annual return (GSTR-9)shall be declared here.
F. Trade Discounts accounted for in the audited Annual (+) Financial Statement but are not permissible under GST: Trade discounts which are accounted for in the audited Annual Financial Statement but on which GST was leviable(being not permissible) shall be declared here.
G. Turnover from April 2017 to June 2017 (-): Turnover included in the audited Annual Financial Statement for April 2017 to June 2017 shall be declared here
H. Unbilled revenue at the end of Financial Year (-): Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of accounting during the current financial year but GST was not payable on such revenue in the same financial year shall be declared here.
I. Unadjusted Advances at the beginning of the Financial Year (-): Value of all advances for which GST has not been paid but the same has been recognized as revenue in the audited Annual Financial Statement shall be declared here.
J. Credit notes accounted for in the audited Annual Financial Statement but is not permissible under GST (-): an Aggregate value of credit notes which have been accounted for in the audited Annual Financial Statement but were not admissible under Section 34 of the CGST Act shall be declared here
K. Adjustments on account of supply of goods by SEZ units to DTA Units (-): an Aggregate value of all goods supplied by SEZs to DTA units for which the DTA units have filed the bill of entry shall be declared here.Easy Guide to GSTR 9C GST Audit Form with Online Return Filing Process
L. Turnover for the period under composition scheme (-): There may be cases where registered persons might have opted out of the composition scheme during the current financial year. Their turnover as per the audited Annual Financial Statement would include turnover both as for composition taxpayer as well as the normal taxpayer. Therefore, the turnover for which GST was paid under the composition scheme shall be declared here.
M. Adjustments in a turnover under section 15 and rules thereunder (+/- ): There may be cases where the taxable value and the invoice value differ due to valuation principles under section 15 of the CGST Act, 2017 and rules thereunder. Therefore, any difference between the turnover reported in the Annual Return (GSTR 9) and turnover reported in the audited Annual Financial Statement due to the difference in valuation of supplies shall be declared here.
N. Adjustments in turnover due to foreign exchange fluctuations (+/- ): Any difference between the turnover reported in the Annual Return (GSTR9) and turnover reported in the audited Annual Financial Statement due to foreign exchange fluctuations shall be declared here
O. Adjustments in turnover due to reasons not listed above (+/-): Any difference between the turnover reported in the Annual Return (GSTR9) and turnover reported in the audited Annual Financial Statement due to reasons not listed above shall be declared here.
P. Annual turnover after adjustments as above
Q. Turnover as declared in Annual Return (GSTR9): Annual turnover as declared in the Annual Return (GSTR 9) shall be declared here. This turnover may be derived from Sr. No. 5N, 10 and 11 of Annual Return (GSTR 9)
R. Un-Reconciled turnover (Q – P) AT1
6. Reasons for Un – Reconciled difference in Annual Gross Turnover
Reasons for non-reconciliation between the annual turnover declared in the audited Annual Financial Statement and turnover as declared in the Annual Return (GSTR 9) shall be specified here.
7. Reconciliation of Taxable Turnover
The table provides for the reconciliation of taxable turnover from the audited annual turnover after adjustments with the taxable turnover declared in annual return (GSTR-9).
A. Annual turnover after adjustments (from 5P above): Annual turnover as derived in Table 5P above would be auto-populated here.
B. Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover: Value of exempted, nil rated, non-GST and no-supply turnover shall be declared here. This shall be reported net of credit notes, debit notes and amendments if any.
C. Zero-rated supplies without payment of tax: Value of zero-rated supplies (including supplies to SEZs) on which tax is not paid shall be declared here. This shall be reported net of credit notes, debit notes and amendments if any.
D. Supplies on which tax is to be paid by the recipient on reverse charge basis: Value of reverse charge supplies on which tax is to be paid by the recipient shall be declared here. This shall be reported net of credit notes, debit notes and amendments if any
E. Taxable turnover as per adjustments above (A-B-C-D): The taxable turnover is derived as the difference between the annual turnover after adjustments declared in Table 7A above and the sum of all supplies (exempted, non-GST, reverse charge etc.) declared in Table 7B, 7C and 7D above.
F. Taxable turnover as per liability declared in Annual Return (GSTR9): Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall be declared here.
G. Unreconciled taxable turnover (F-E)
8. Reasons for Un – Reconciled difference in taxable turnover
Reasons for non-reconciliation between adjusted annual taxable turnover as derived from Table 7E above and the taxable turnover declared in Table 7F shall be specified here.
Part 3: Reconciliation of tax paid
9. Reconciliation of rate wise liability and amount payable thereon
The table provides for the reconciliation of tax paid as per reconciliation statement and amount of tax paid as declared in Annual Return (GSTR 9). Under the head labelled ―RC‖, supplies where the tax was paid on reverse charge basis by the recipient (i.e. the person for whom reconciliation statement has been prepared ) shall be declared with GSTR 9 file an annual return form with GSTR 9
P. Total amount to be paid as per tables above: The total amount to be paid as per liability declared in Table 9A to 9O is auto-populated here
Q. The total amount paid as declared in Annual Return (GSTR 9): The amount payable as declared in Table 9 of the Annual Return (GSTR9) shall be declared here. It should also contain any differential tax paid on Table 10 or 11 of the Annual Return (GSTR9)
- 10. Reasons for un-reconciled payment of amount: Reasons for non-reconciliation between payable / liability declared in Table 9P above and the amount payable in Table 9Q shall be specified Part-B: Certification.
- 11. Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10 above): Any amount which is payable due to reasons specified under Table 6, 8 and 10 above shall be declared here.
Part 4: Reconciliation of ITC (Input Tax Credit)
- 12. Reconciliation of Net ITC (Input Tax Credit)
- A. ITC availed as per audited Annual Financial Statement for the State/ UT (For multi-GSTIN units under same PAN this should be derived from books of accounts): ITC availed (after reversals) as per the audited Annual Financial Statement shall be declared here. There may be cases where multiple GSTINs (Statewise) registrations exist on the same PAN. This is common for persons/entities with a presence over multiple States. Such persons/entities will have to internally derive their ITC for each individual GSTIN and declare the same here. It may be noted that reference to audited Annual Financial Statement includes the reference to books of accounts in case of persons/entities having the presence over multiple States.
- B. ITC booked in earlier Financial Years claimed in current Financial Year (+): Any ITC which was booked in the audited Annual Financial Statement of an earlier financial year(s)but availed in the ITC ledger in the financial year for which the reconciliation statement is being filed for shall be declared here. This shall include transitional credit which was booked in earlier years but availed during Financial Year 2017-18.
- C. ITC booked in current Financial Year to be claimed in subsequent Financial Years (-): Any ITC which has been booked in the audited Annual Financial Statement of the current financial year but the same has not been credited to the ITC ledger for the said financial year shall be declared here.
- D. ITC availed as per audited financial statements or books of account: ITC availed as per audited Annual Financial Statement or books of accounts as derived from values declared in Table 12A, 12B and 12C above will be auto-populated here.
- E. ITC claimed in Annual Return (GSTR 9): Net ITC available for utilization as declared in Table 7J of Annual Return (GSTR9) shall be declared here.
- 13. Reasons for un-reconciled difference in ITC
- Reasons for non-reconciliation of ITC as per audited Annual Financial Statement or books of account (Table 12D) and the net ITC (Table12E) availed in the Annual Return (GSTR9) shall be specified here.
- 14. Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account.
- This table is for the reconciliation of ITC declared in the Annual Return (GSTR9) against the expenses booked in the audited Annual Financial Statement or books of account. The various sub-heads specified under this table are general expenses in the audited Annual Financial Statement or books of account on which ITC may or may not be available. Further, this is only an indicative list of heads under which expenses are generally booked. Taxpayers may add or delete any of these heads but all heads of expenses on which GST has been paid/was payable are to be declared here.
- A. Purchases
- B. Freight / Carriage
- C. Power and Fuel
- D. Imported goods (Including received from SEZs)
- E. Rent and Insurance F Goods lost, stolen, destroyed, written off or disposed of by way of gift or free samples
- G. Royalties
- H. Employees’ Cost (Salaries, wages, Bonus etc.)
- I. Conveyance charges
- J. Bank Charges
- K. Entertainment charges
- L. Stationery Expenses (including postage etc.)
- M. Repair and Maintenance
- N. Other Miscellaneous expenses
- O. Capital goods
- P. Any other expense 1
- Q. Any other expense 2
- R. Total amount of eligible ITC availed: Total ITC declared in Table 14A to 14Q above shall be auto-populated here.
- S. ITC claimed in Annual Return (GSTR9): Net ITC availed as declared in the Annual Return (GSTR9) shall be declared here. Table 7J of the Annual Return (GSTR9) may be used for filing this Table.
- T. Un-reconciled ITC | ITC 2
- 15. Reasons for the un-reconciled the difference in ITC: Reasons for non-reconciliation between ITC availed on the various expenses declared in Table 14R and ITC declared in Table 14S shall be specified here.
- 16. Tax payable on the un-reconciled difference in ITC (due to reasons specified in 13 and 15 above): Any amount which is payable due to reasons specified in Table 13 and 15 above shall be declared here.
Part 5: Auditor’s recommendation on additional Liability due to non-reconciliation
- Part V consists of the auditor’s recommendation on the additional liability to be discharged by the taxpayer due to non-reconciliation of turnover or non-reconciliation of the input tax credit. The auditor shall also recommend if there is any other amount to be paid for supplies not included in the Annual Return. Any refund which has been erroneously taken and shall be paid back to the Government shall also be declared in this table. Lastly, any other outstanding demands which are recommended to be settled by the auditor shall be declared in this Table.
GSTR 9C Part-B: Certification
A certification part is also done once after the GSTR 9 audit is conducted by the person responsible for the audit. The form has two major parts including
1 – Certification in cases where the reconciliation statement (Form GSTR 9C) is drawn up by the person who had conducted the audit.
- A – Balance sheet date
- B – P&L Account including dates
- C – Cash flow statement including dates
2 – Based on audit the auditor mentioned:
Proper maintenance of books status
Or not maintained
3(A) – Based on any observations done by the auditor, reporting any differences:
3(B) – Further reporting
4 – Documents required under section 35(5) of CGST and reconciliation statement required which are to furnished under section 44(2) of CGST Act annexed in form no. GSTR 9C
5 – All the details and transactional information stated in GSTR form 9C are validated in this point.
Credentials With Signature, Name of the signatory, Membership no. and Date