Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

What is GSTR 9C (GST Audit Form)?

GSTR 9C is an annual audit form for all the taxpayers having the turnover above 5 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.

• Latest Updates of GSTR 9C Form
• GST Audit Types with Auditable Documents
• Who is Required to File GSTR 9C
• Significance of GSTR 9C Audit Form
• GSTR 9C Due Dates Extension & Penalty Norms
• How to File the GSTR 9C Form?
• General Queries on GSTR 9C Form
• GSTR 9C Filing By Gen GST Software

Latest News/Updates of GSTR 9C Form

• “In the GST 55th Council meeting, a waiver of the late fee for the delayed furnishing of Form GSTR-9 and GSTR-9C for the FY 2017-18 to 2022-23 was announced.” View more
• GSTN advisory for GSTR-9/9C: Starting October 15, 2024, ITC for domestic supplies will be automatically transferred from Table 3(I) of GSTR-2B to Table 8A of GSTR-9. View more
• 53rd GST Council Meeting: “The Council recommended that filing of annual return in form GSTR-9/9A for the FY 2023-24 may be exempted for taxpayers having aggregate annual turnover upto two crore rupees.”

SAG Infotech is here to provide all the relevant details of the GSTR 9 and 9C forms and a step-by-step procedures 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.

53rd GST Council Meeting Updates for Annual Return Form

• The 53rd GST Council has announced the relaxations provided in FY 2023-24 for FORM GSTR-9 and FORM GSTR-9C. This includes the exemption from filing the annual return for taxpayers with an aggregate annual turnover of up to two crore rupees. The Council has made these changes to ease the compliance burden on smaller taxpayers.

GST Burden Reduced for FY 2023-24

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

File GSTR 9C Audit Form Via Gen GST Software, Get Demo!

Simplify GSTR 9C Filing by CBIC

Some exemptions have been done in this form listed below:

1. Part of the turnover adjustments necessary in Table 5B to 5N is now not mandatory and all the adjustments now necessary to be described in Table 5O;
2. Tables 12B, 12C and 14 (ITC reconciliation) are now not mandatory;
3. A few changes are done in the Declaration part also.

GST Audit Types with Auditable Accounts and Documents

The audit beneath the GST consists of the investigation of the records, returns, and audit for all the additional documents that are maintained through the enrolled individual beneath GST. The audit checks the correctness of the mentioned turnover, taxes which are furnished if the refund is availed and if there is any ITC claimed and validates the additional things that are essentially required to get investigated through the expert authority.

How Many Types of GST Audits are There?

Turnover-Based GST Audit: CA or the cost accountant used to implement it and the CA is arranged by the assessee they shall execute the audit if the turnover of the assessee is more than Rs 5 cr under the CGST act, then he shall need to get his accounts audited through the same people.

Normal Audit Under GST: It gets executed through the commissioner of the CGST/SGST or any Officer who has been permitted by the commissioner. The audit in these types of cases will get executed by giving 15 days’ notice before the commissioner.

Special GST Audit: The audit beneath this shall be taken by the CA or the cost accountant who gets appointed through the commissioner. To execute the audit the professional needs to get the order of the Deputy or Assistant Commissioner and indeed the permission of the commissioner.

Qualification of Auditor

Only the CA or the cost accountant can take out the GST audit beneath section 35 of the GST act.

Important Note:

• An internal auditor shall not bring out the GST Audit
• Any individual who uses GST shall not be a GST auditor under the GST Act
• The GST power is provided to the CA or Cost Accountant or they are an employee of any firm of Chartered Accountant or Cost Accountant
• The CA or Cost Accountant must not be enrolled under the GST practitioner if they are provided with the audit report

GST Auditor Appointment

GST auditor will be appointed at the start of the fiscal year and towards the company, a GST auditor will be appointed through the proprietor or any partner or the board of directors could appoint them.

GST Auditor Review the Following Accounts

There are various accounts that must be reviewed by the GST auditor

• Register of Stocks
• Ledger of expenses
• Register of Purchases
• Register of Sale
• If there’s any Input Tax Credit that is claimed or practised
• Output Tax which is payable and if paid
• When under the guidelines of the act and there was an e-way bill that was generated
• E-invoice and if IRN is generated and is has a record
• additional accounts which are communicated by the GST Department for the financial year.

Credentials Needed to be Filed through the Assessee

The assessee needs the mentioned documents:

• PAN-based Audited Financial Statements
• Yearly return mentioned in Form GSTR-9 and it must be for every GSTIN.
• Form GSTR-9C which consists of a certified reconciliation statement and it shows the reconciled value of supplies and declaration of tax amounts in Form GSTR-9 that will be compared to audited financials in part A and this must consist of Part B which will be the audit report.

What is GSTR 9C Annual GST Audit Form?

As per the rules, all the taxpayers 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 a 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.

File GSTR-9 Via GST Software

Significance of GSTR 9C Audit Form

GSTR-9C is a reconciliation statement that must be certified by a Chartered Accountant or a CMA. Taxpayers whose aggregate turnover in a financial year exceeds Rs 5 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 for Filing GSTR 9C Audit Form Under GST

The Indian government has disclosed the due date of the GSTR 9C (Reconciliation Statement) form for the FY 2023-24:

• Financial Year 2023-24 – 31st December 2024
• Financial Year 2022-23 – 31st December 2023
• Financial Year 2021-22 – 31st December 2022
• Financial Year 2020-21(Revised) – 28th February 2022
• Financial Year 2019-20 – 31st March 2021 (Revised from 28th February 2021). Read Also

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 the GSTR 9C audit return form, the registered taxpayer has to pay Rs. 200 per day as a penalty of which Rs. 100 consists 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 the penalty is being levied.
• Taxpayers with a turnover up to Rs. 5 crores will have to pay SGST and CGST of Rs.50 per day as a penalty from the financial year 2022-23 onwards. In the case of turnover exceeding Rs.5 crore, the late fee would be Rs.100, which includes Rs. 50 for SGST and Rs.50 for CGST. read more

Where to Download GSTR 9C Offline Utility?

The government has released the file an annual return form with GSTR 9C 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 the download page
• Click on the download option and extract the file

Where to Find GSTR 9C Online Filing Option on Portal?

Also, there is now an available GSTR 9C online utility. To start filing the GSTR 9C reconciliation audit report, perform the 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

Easy to File GSTR-9C Form

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-9C 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 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

General Queries on GSTR 9C Form

How to File GSTR 9C By Gen GST Software