A Comparative Overview of GSTR-9 and GSTR-9C
This article clarifies the distinctions between GSTR-9, the annual GST return, and GSTR-9C, the GST reconciliation statement. It highlights their differing natures, filing requirements, applicable entities, due dates, and associated penalties. The comparison aims to resolve common taxpayer confusions regarding these essential GST compliance forms.
Since the introduction of GSTR-9 and GSTR-9C forms by the CBIC, taxpayers have frequently encountered uncertainty regarding their filing obligations and the data requirements for each. This article aims to clarify these points by offering a concise comparison between GSTR-9 and GSTR-9C.
Comparison Table for GSTR-9 and GSTR-9C
| Comparison Aspect | GSTR-9: Yearly Return | GSTR-9C: Reconciliation Report |
|---|---|---|
| Nature | Provides comprehensive information; a summary of all GST returns filed. | An analytical report on GST returns that requires self-certification by the Chief Financial Officer (CFO) or Finance Head. |
| Who must file | Any GST-registered taxpayer. | GST-registered taxpayers with an aggregate annual turnover exceeding Rs 5 crore. |
| Not applicable to | - Dealers under the composition scheme- Casual taxable individuals (CTP)- Non-resident taxable individuals (NRTP)- Input Service Distributors (ISD)- Holders of Unique Identification Numbers (UIN)- Providers of Online Information and Database Access Retrieval (OIDAR) services- Entities subject to Tax Collected at Source (TCS) or Tax Deducted at Source (TDS) provisions. | Individuals listed under the GSTR-9 column, along with registered persons whose aggregate turnover for a financial year is below Rs. 5 crore. |
| Optional for | Optional for businesses with an annual turnover under Rs 2 crore (effective from FY 2017-18). | Optional for businesses with an annual turnover under Rs 5 crore. |
| Due date for filing* | December 31st of the subsequent financial year*. | December 31st of the subsequent financial year, to be filed concurrently with or subsequent to GSTR-9*. |
| Late fees & penalty | Applicable from Financial Year 2022-23 onwards: |
- For businesses with a turnover up to Rs 5 crore: A fee of Rs 50 (Rs 25 each for CGST and SGST Acts). The maximum late fee is capped at 0.04% of the state/UT turnover (0.02% each for CGST and SGST Acts).
- For businesses with a turnover exceeding Rs 5 crore but less than Rs 20 crore: A fee of Rs 100 (Rs 50 each for CGST and SGST Acts). The maximum late fee is capped at 0.04% of the state/UT turnover (0.02% each for CGST and SGST Acts).
- For businesses with a turnover exceeding Rs 20 crore: A fee of Rs 200 (Rs 100 each for CGST and SGST Acts). The maximum late fee is capped at 0.50% of the state/UT turnover (0.25% each for CGST and SGST Acts). | There are no specific provisions for GSTR-9C late fees; therefore, a general penalty of Rs 25,000 applies. | | Filing of the return | Submitted via the official GST portal or a designated facilitation centre. | Submitted via the official GST portal or a designated facilitation centre, either concurrently with or following the GSTR-9 filing. | | Format of the return | A consolidated summary of the following details:
- Turnover
- Input Tax Credit (ITC) and taxes paid
- Late fees settled for GST returns filed during the financial year
- Amendments made between April and November 30th of the subsequent financial year.
Additionally, where relevant, the following details must be declared:
- Demands or refunds
- Supplies received from composition dealers
- Job work activities
- Goods dispatched on an approval basis
- Harmonized System of Nomenclature (HSN) wise summary of sales and purchases
- Any late fees due. | Part A outlines the reconciliation required for turnover, taxes paid, and Input Tax Credit (ITC). It also includes a report on the auditor's recommendation for any additional tax liabilities. Part B involves self-certification by the Chief Financial Officer (CFO) or Finance Head. | | Who must certify/ attest | Certification by a Chartered Accountant (CA) or Cost and Management Accountant (CMA) is not mandatory; however, the taxpayer must attest it with a digital signature. | The Chief Financial Officer (CFO) or Finance Head is required to certify this document using a digital signature. | | Annexures | No annexures are required to be attached. | An annexure containing the audited financial statement is mandatory. |
The Budget 2023 introduced an amendment restricting taxpayers from filing GSTR-9 more than three years after its original due date has expired. This amendment is awaiting notification by the CBIC.
*These dates are subject to any extensions notified by the CBIC.
For late fees applicable up to FY 2021-22: A daily late fee of Rs 200 was imposed, with a maximum limit set at 0.50% (0.25% each under CGST and SGST) of the total turnover within the respective State/Union Territory, applicable until March 31, 2023.
Through notification 07/2023 dated March 31, 2023, the CBIC announced a waiver of late fees exceeding Rs 20,000 (Rs 10,000 each under CGST and SGST laws) for delayed GSTR-9 filings pertaining to the financial years 2017-18 through 2021-22, provided they were filed between April 1, 2023, and June 30, 2023.