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

Ribhu Sharma
GSTR 9C Online Return Filing

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 News/Updates of GSTR 9C Form

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

GST Burden Reduced for FY 2023-24

SalesGSTR 9GSTR 9C
Up to 2 CrOptionalN/A
More than 2Cr. – 5 CrFilling is mandatoryOptional (Benefit Given)
More than 5CrFilling is mandatoryFilling is mandatory

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

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    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:

    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

    Credentials Needed to be Filed through the Assessee

    The assessee needs the mentioned documents:

    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:

    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

    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:

    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:

    Easy to File GSTR-9C Form

    Items Included While Calculating Turnover for GST Audit:

    Items Excluded While Calculating Turnover for GST Audit:

    How to File the GST Audit Form GSTR 9C – Step by Step:

    GSTR 9C Part-A: Reconciliation Statement Format

    Part 1: Basic Details has the following four sections: Financial Year for which return is being filed.

    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)

    Part 3: Reconciliation of tax paid

    Part 4: Reconciliation of ITC (Input Tax Credit)

    Part 5: Auditor’s recommendation on additional Liability due to non-reconciliation

    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.

    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

    Q.1 Is the Audit of Accounts maintained by the registered taxable person required to be got done by a Chartered Accountant/Cost Accountant under GST?

    As per the GST law, it is mandatory for all the Registered person to get their accounts audited by a chartered accountant or a cost accountant whose aggregate turnover during a financial year exceeds the threshold limit of Rs. 5 Crore. Whence, no such audit is required to be got done by the Chartered or Cost accountant in cases other than mentioned above.

    Q.2 – Does ‘aggregate turnover’ deals with topics such as stock transfers/ cross charges effected between branches located in two different states?

    Aggregate Turnover has been defined in Section 2(6) of CGST/ SGST Act and the definition of aggregate turnover includes ‘inter-state supplies of a person having the same PAN’. Thus, we see that stock transfers/ cross-charges of services provided from a branch, located in one state to a branch located in another state is included in the definition of Aggregate turnover of the related branch supplying goods/ services.

    Q.3 – Does the term ‘aggregate turnover,’ includes stock transfers which are effective within the States having same GSTIN for determining the threshold limits?

    The term ‘aggregate turnover’ is not supposed to be included in stock transfers effective within the same state having single GSTIN for the purpose of determining the threshold limit. However, in cases where more than one GSTIN has been allotted for the different branches located in the same state, such branch transfers shall be included for computing threshold limit of Rs. 5 crore to get to the conclusion that whether there is any requirement for audit or not.

    Q.4 – Will a Registered Taxpayer who has exclusively exempted supply of goods or services exceeding Rs. 2 crores, would require to fill the GSTR 9C form?

    As ‘aggregate turnover’ has been defined under the GST Act, it includes ‘exempt supplies’. Thus, even in the case of a registered person under GST who provides exempted supplies, will have to file Form GSTR 9C.

    Q.5 Does the Form GSTR 9C be required to be filed by a person against each registration obtained by him in respect of each of the States?

    Provision is that Section 35(5) of SGST Act requires Audit to be conducted in addition to Section 35(5) of CGST Act. Thus, to maintain Compliance audit is required to be conducted state wise as per Section 35(5) of SGST Act. Thus, if we consider an example like if a person is having registration in Karnataka and Tamil Nadu, then he is required to be audited for his accounts under KGST Act, 17 and TNGST Act, 17. The GSTR 9C form is required to be filed under Rule 80(3) of KGST Rules, 2017 and the TNGST Rules. Thus, it is evident that a person registered in more than one state is supposed to file form GSTR 9C registration wise for each and every state.

    Q.6 – Is it required for a Chartered Accountant to be got registered as a GST practitioner to get certified the Form GSTR 9C?

    A GST practitioner gets authorization for the practice of the below-mentioned rules as per Section 48 of the CGST/ SGST Act under Rule 83(8) of the CGST/ SGST Act:

    • a) furnishing the details of outward and inward supplies
    • b) to furnish monthly, quarterly, annual or final return
    • c) Can make deposits to get amount credited into the electronic cash ledger
    • d) he could file a claim for any sort of refund
    • e) filing application for getting the registration amended or getting the registration canceled

    The GST Act/ Rules does not give the ‘Power to Audit’ to a GST practitioner as per section 35(5). ‘Power to Audit’ is only granted to Chartered Accountants or Cost Accountants. Thus, it is not required for a Chartered Accountant to get registered as a GST practitioner for certifying Form GSTR 9C.

    Q.7 – What are the documents to be enclosed along with GSTR 9C?

    • Under section 35(5), it is stated that a copy of audited accounts and other such documents in the prescribed manner along with the reconciliation statement (Form GSTR 9C) to be submitted.
    • The ‘Prescription’ which is mentioned in the Act should be provided as mentioned in the term ‘as may be prescribed’. Only the audited annual accounts have been prescribed in Rule 80(3) in the name of documents.
    • Talking about Part B of GSTR 9C, it is required by the GST Auditor to get a copy of audit report of the entity enclosed where the audit of the entity has been conducted by another person under a statute other than the GST Act.
    • In the mentioned case, the documents which has been declared by the statute, which would further be considered as audited financial statements, must be annexed to the audit report.

    Q.8 – Should the Form GSTR 9 and Form GSTR 9C get filed separately?

    As per Section 44(2) of the CGST/ SGST Act 2017, a Registered person is required to file his Annual return in Form GSTR 9 along with this he has to provide a reconciliation statement through Form GSTR 9C. Thus we see, Form GSTR 9C is required to be filed along with Form GSTR 9 where the turnover exceeds Rs. 2 crores.

    Q.9 – Is there any time limit to file Form GSTR 9C?

    The Section 44(2) states that the reconciliation statement is required to be provided in Form GSTR 9C along with the Form GSTR 9. Section 44(1), on the other hand, declares the due dates. As per this section, the due date for filing the annual return is on or before the thirty-first day of December following the end of the FY for which the Annual return is prepared. Thus, the conclusion could be drawn that the due date for filing reconciliation statement in Form GSTR 9C is on or before the thirty-first day of December following the end of the financial year for which the reconciliation statement is being prepared.

    Q.10 – Could the late fee be waived off in Genuine and special cases?

    The Government has the right to get a part or full of the late fee, mentioned in section 47, waived through notification, for such section of taxpayers and under such mitigating and specified circumstances. All this could be done on the recommendation of the Council. However, no such notification is evident to till date issued by the Central Government/ State Government.

    Q.11 – Is Audit, mentioned under Section 35(5), be applicable to the Non-Filers or unregistered Persons who are liable to get registered?

    • As per Section 35(5) of the CGST Act, only a Registered person is required to get his accounts audited by a CA or CWA. Again, a non-filer is a Registered Person according to Section 25 of the CGST Act, thus he must get audit conducted under Section 35(5) of the said Act. Considering practically, such a person would never had filed his returns and hence, Form 9 & 9C wouldn’t be possible in his case and no audit for him is required.
    • Understanding clearly, an unregistered person who is eligible for registration under Section 25 of the CGST is a taxable person. Here, the unregistered Person is not a Registered Person as per Section 2(94) of the CGST Act 2017. Hence, following Section 35(5) of the Act, audit is not required.

    Q.12 – Mention the records which are required to be reconciled in Form GSTR-9C?

    The records to be reconciled in GSTR-9C are:

    • Books of accounts of the registered person – If a registered person has multiple registrations, The required information could be derived from the Audited financials of the entity.
    • Annual Return of Registered Person in Form GSTR 9.

    Q.13 – What are the contents of Form GSTR 9C?

    Form GSTR 9C consists of 2 parts. Part-A consists of Reconciliation statement and Part B is Certificate to be issued by GST Auditor.

    Q.14 – What are the details which are to be provided in SI. No.5B (Unbilled revenue at the beginning of Financial Year)?

    The unbilled revenue at the beginning of Financial Year are required to be added in Clause 5B. The unbilled revenue recorded on the basis of the accrual system of Accounts in the Books of accounts for the earlier financial year for which the invoice is issued under GST law, is required to be declared here. Understanding more clearly, the value of such Revenue which has been recognized as income during a financial year on which GST is liable to be paid, is required to be mentioned in SI. No.5B

    Q.15 – Mention the adjustments to be included/excluded from SI. No.5C of Form GSTR-9C?

    The advances which are received could be of various purposes. Therefore, the Advances on which GST is liable should only be considered for the adjustment. The illustrations of advances to be included/excluded are as follows:

    Include for Adjustment

    1. Advance received in respect of services for which the supply has not been made as on 31st March 2018 Revenue not recognized in books, but offered to tax for GST
    2. Advance received for Goods before 15th Nov 2017 and the supply of goods not complete as on 31st March 2018 Revenue not recognized in books, but offered to tax for GST

    Do NOT include for Adjustment

    Sl. No. Particular’s Reason
    1. Advance received for EXEMPTED services as on 31St March 2018 GST is not applicable
    2. Advance received for Goods after 15th Nov 2017 GST is not applicable
    3. Financial Advances received which are not adjustable against any services NOT a GST Transaction

    How to File GSTR 9C By Gen GST Software

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