12 Most Frequently Asked Questions About GSTR-9C Annual Reconciliation

As per the recent update given by the Government on May 5th, 2020, the extended due date for filing Annual Return GST Forms GSTR-9 & GSTR-9C for FY-2018-19, is SEPTEMBER 30th, 2020. 

Since the due date of filing the form is nearing you must be aware of even the minor details of the forms GSTR-9 & GSTR-9C.

However, GSTR-9C is a more complicated form than GSTR-9, and so, we have brought to you this FAQ Guide to understand the know the provisions of Form GSTR-9C.

We have answered 12 most frequently asked questions in detail for a firm & practical understanding of the concept.

1. What is the meaning of the Annual Reconciliation Statement in GST & what is its purpose?

The Annual Reconciliation Statement under GST is the matching or reconciling of the data of-

a. Annual Returns as per Form GSTR-9 AND

b. Audited Accounts (Financial Statement) of a taxpayer

In other words, Annual Reconciliation means tallying the details you declared in your Annual GST Return with your Audited Books of Accounts.

This will help to ensure the following-

  1. The accurate amount of tax is paid
  2. The accurate amount of ITC is claimed
  3. The turnover declaration is precise
  4. Any other errors & Discrepancies are avoided
  5. And, the GST aspect of the business is clear & accurate 

Purpose- The purpose of Annual Reconciliation is to ensure accuracy in GST compliance of a business in the FY, identify & rectify any errors or mistakes that may arise while reconciling.

A taxpayer must declare the same details in their Annual Returns as they maintain in their Books of Accounts.  Here, GSTHero india’s best GST Software can help you to reduce your manual work and saves time.

Also Read:- Know the difference between GSTR 4 and GSTR 9- For Composition Dealer

2. What is Form GSTR-9C? 

Form GSTR-9C is one of the annual return forms that businesses need to furnish at the end of the FY or on any date as specified by the government.

This form is a Reconciliation Statement between the annual return GSTR-9 AND the Audited Financial Account Statement.

This form will identify any differences in the details of the two documents mentioned above, they ought to match completely. In case of any differences, the taxpayers will be obliged to reason it & take actions if required any.

This form will ensure, that taxpayers declare the same details in their Annual Returns, as they maintain in their personal Books of Accounts. 

You will be required to get your Accounts audited by a CA before filing form GTR-9C.

A Chartered Accountant or a Cost Accountant will then, prepare your Form GSTR-9C & digitally sign it. You must only upload this prepared form in the GST Portal.

Although, you will have to take any actions as suggested by the CA while filing Form GSTR-9C on the GST Portal, such as discharging any additional tax liabilities.

3. What type of Taxpayers need to file form GSTR-9C?

All Normal Taxpayers, who file form GSTR-9 and have an annual aggregate turnover of more than Rs. 2 Crores (Now raised to Rs. 5 Crores) must file form GTR-9C.

4. What is the Format of the Form GSTR-9C?

Following are the details you need to declare in Form GSTR-9C-

Part A: Reconciliation Statement

Part- I Basic Details

In this part, you need to fill, the Financial Year, GSTIN, Legal Name, Trade Name, & Turnover (to see if you are liable to audit)

Part-II Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (GSTR9)

  • Table 5 (A-R) Reconciliation of Gross Turnover
  • Table 6 (A-C) Reasons for Un-Reconciled difference in Annual Gross Turnover
  • Table 7 (A-G) Reconciliation of Taxable Turnover
  • Table 8 (A-C) Reasons for Un-Reconciled difference in taxable turnover

Part-III Reconciliation of tax paid

  • Table 9 (A-R) Reconciliation of rate wise liability and amount payable thereon
  • Table 10 (A-C) Reasons for un-reconciled payment of amount
  • Table 11 Additional amount payable but not paid (due to reasons specified under Tables 6,8 and 10 above)

Part-IV Reconciliation of Input Tax Credit (ITC)

  • Table 12 (A-F) Reconciliation of Net Input Tax Credit (ITC)
  • Table 13 (A-C) Reasons for un-reconciled difference in ITC
  • Table 14 (A-T) Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on expenses as per audited Annual Financial Statement or books of account
  • Table 15 (A-C) Reasons for un-reconciled difference in ITC
  • Table 16 Tax payable on the un-reconciled difference in ITC (due to reasons specified in 13 and 15 above)

Part-V Auditor’s recommendation on additional Liability due to non-reconciliation

Part B: Certification

To be filled & signed by the Auditor or a CA and filed by the taxpayer along with the reconciliation statement.

5. Are there any prerequisites for filing Form GSTR-9C?

You must consider the following pre-requisites before filing form GTR-9C-

  • The Taxpayer must be registered under GST  
  • The Taxpayer must their GSTR-9 Form for the said Tax period.
  • Taxpayers must get their Accounts audited as prescribed by the Government.
  • The annual aggregate turnover of the Taxpayer must be at least Rs. 5 Crores

Know about GSTR 4 Annual Return- Meaning, Applicability, Due Dates

6. What other documents do I need to declare while filing form GSTR-9C?

You must declare & attach the following documents while filing form GSTR-9C –

  • Signed Audit File in JSON format.
  • Balance sheet in PDF (or JPEG form)
  • Profit & Loss Statement/ Income &
  • Expenditure Account in PDF (or JPEG)

7. How to File form GSTR-9C? or What is the complete process of filing form GSTR-9C?

Here is a step-wise guide on how you can file form GTR-9C, ON & OFF the GST Portal-

1. Taxpayer-

  • Download the filed form GSTR-9 annual return
  • Download Form GSTR-9C Tables Derived from Form GSTR-9
  • Get your Financial Accounts Audited & Signed 
  • Share all the above-mentioned documents with the CA/Auditor along with Profit & Loss Statement, Balance Sheet & all other relevant documents.

2. The Auditor

  • Download the Offline Utility Tool of GSTR-9C from the Portal
  • Install emSigner
  • Fill the GSTR-9C Offline Utility Excel Worksheet (using the documents provided by the taxpayer)
  • Generate the PDF & JSON file of the final filled form.
  • Affix the DSC to the JSON
  • Share the JSON with the taxpayer

3. Taxpayer-

  • Upload the JSON file on the Portal
  • Review it thoroughly, check for any change or errors, and consult with the Auditor as well in case he needs to make any changes.
  • Upon final confirmation, file the form GSTR-9C & download the filed form for your reference & further use. 

Note- In case of errors you need to share the error file with the Auditor who will make the amendments.

Note- If you have additional tax liabilities, use form GST DRC-03 to offset them.

8. As a taxpayer, am I allowed to make any changes to the documents issued by the Auditor? What will be the consequences if I did?

No, you must not make any changes to any documents prepared by the Auditor or CA. You can inform your Auditor and ask them to make the changes & revert the file back.

If you make any change yourself the signature will be considered invalid & you will not be able to use that document for filing.

9. What needs to be done from the Taxpayer’s end & the Auditor’s end in case of any errors while uploading form GSTR-9C?

In case an error arises to the taxpayer while uploading the JSON & filing form GSTR-9C, he must download the JSON error file & share it with the auditor for corrections.

The Auditor must make the corrections, sign the file again & revert it to the taxpayer. 

10. How can I track the status of Form GSTR-9C?

You can track the status of your filed Form GSTR-9C by following the steps below-

Login to GST Portal > Navigate to Services > Returns > View e-filed returns option.

11. Can I make any changes after filing the Form GSTR-9C?

No, there is no such provisions given out yet regarding amendments or rectifications of Form GSTR-9C, after it is filed. 

Hence taxpayers are advised to ensure accuracy by reviewing & revising the form thoroughly before filing it.

Also Read:- What is GST Input Tax credit -ITC with example and rules

12. The Auditor has recommended discharging the additional tax liability, how can I do that?

If you are liable to pay additional liabilities, you can release them through Form GST DRC-03.

The GSTR-9C page has an option to navigate you to form GST DRC-03 or you can also follow the steps below to access the Form-

Login to GST Portal > Services > User Services > My Applications > Application Type – Intimation of Voluntary Payment – DRC – 03 > NEW APPLICATION

You can discharge all the additional tax liabilities using this form

Compiled by- GSTHero– Making GST Simple! GSTHero is the best GST filing, e-Way Bill Generation & E-Invoicing Software in India. GSTHero is a government authorized GST Suvidha Provider.

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Disclaimer: The information contained in the above article are solely for informational purpose after exercising due care. However, it does not constitute professional advice or a formal recommendation. The author does not own any responsibility for any loss or damage caused to any person, directly or indirectly, for any action taken on the basis of the above article.

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