GSTR 9C – Reconciliation Statement and Certification [GST Audit Form]

The due date to file the annual GST return form GSTR 9 is not far. Many taxpayers who are required to file the annual return under the GST regime, are also required to submit the audit form(s) GSTR 9C along with it. The government, in its notification no. 49/2018, dated 13th September 2018, announced the release of the new annual return form GSTR 9 and the annual audit form GSTR 9C. In this guide, we will discuss GSTR 9C in detail.

What is GSTR 9C?

GSTR 9C is an annual audit report to be submitted by taxpayers. It is a reconciliation statement between the information filed in the annual return GSTR 9 with the audited annual financial statements of the taxpayer. It must be prepared and certified by a Chartered Accountant. Just like you file a tax audit report under the Income Tax Act, you must file GSTR 9C as an audit report under the CGST Act, 2017.

[Read more: How to file the annual return GSTR 9?]

Am I Required to File GSTR 9C?

As per section 35(5) of the CGST Act, 2017, if your annual turnover exceeds Rs 2 crores, you need to get your accounts audited by a Charted Accountant and file GSTR 9C on the GST Common Portal or SahiGST’s cloud-based filing platform. You will require an audit for all the GSTINs obtained under your PAN. E.g., if an entity has obtained 10 GSTINs under its PAN, then it needs to file ten GSTR 9C forms if the turnover exceeds the said threshold.

Due Date to File GSTR 9C

The due date to file GSTR 9C for the FY 2017-18 is December 31, 2018. The due date to file your annual return is also the same. Hence, it is recommended that you file your annual GST return in advance in order to have enough time in hand for auditing your financial statements and file GSTR 9C before the expiry of the due date.

Format of GSTR 9C and the Process to fill it

The annual GST audit report can be broadly divided into 2 parts:

  • Part A: Reconciliation Statement
  • Part B: Certification

Part A: Reconciliation Statement

This part of the form can be further divided into 6 parts:

Part I: Basic Details

This is the first sub-section of the reconciliation statement in GSTR 9C. Here, you need to provide the following details:

  • Financial Year: The financial year for which the form is being filed. GST was implemented on July 1, 2017. Hence, December 31, 2018 is the due date for the first audit report as well as the annual return. Here, the period for which GSTR 9C must be filed is July 1, 2017 to March 31, 2018.
  • GSTIN : GSTIN of the taxpayer
  • Legal name: Legal name of the registered taxpayer will be auto-populated in the form
  • Trade name: Trade name of the registered taxpayer/ business (if any)
  • Are you liable to audit under any Act?: Needs to be answered as either “Yes” or “No”

Part II: Reconciliation of turnover declared in audited annual financial statement with turnover declared in annual return (GSTR 9)

This is the second section of the reconciliation statement in GSTR 9C and is meant for the reconciliation of gross and taxable turnover.

  • There are 4 tables given in this section to facilitate the same.
  • Reconciliation of your annual gross turnover and taxable turnover should be done here and any un-reconciled data should be reported with the reason for the same.

Part III: Reconciliation of tax paid

This section of the form is meant for the reconciliation of your total tax liability as per your declarations in the reconciliation statement with the amount of tax actually paid as per your GSTR 9.

  • Here, taxpayers tax liability must be reconciled rate-wise, i.e. as per the tax slabs under GST.
  • Un-reconciled information must be reported with the reasons for the same.
  • If taxpayers have any additional tax liability as per the reconciliation statement, it must be reported here with the reason for non-payment of such tax.

Part IV: Reconciliation of Input Tax Credit (ITC)

This is the fourth part of the statement of reconciliation.

  • Taxpayers net input tax credit for the relevant financial year needs to be reconciled here by the auditor.
  • The amount of input tax credit declared in the annual return must be reconciled with the input tax credit availed on expenses as per taxpayer audited annual financial statement or books of account.
  • Any un-reconciled data must be reported with proper reason.
  • Tax payable on un-reconciled data regarding input tax credit must also be reported here.

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

This is the second last part of the reconciliation statement in GSTR 9C.

  • Here, the auditor/ CA must report the total tax liability resulting from un-reconciled turnover.
  • Auditor/ CA must do so rate-wise and also report any interest, late fee or penalty applicable to the taxpayer.
  • Any erroneous refund issued to taxpayer must also be identified and reported here.

Verification

After filling up the reconciliation statement, the auditor needs to sign the verification statement.

Part B: Certification

After the reconciliation part is complete, GST auditor needs to certify here that the financial documents have been audited.

  • Taxpayers can get the certification done by the CA who has conducted the audit as well as drawn the reconciliation statement.
  • The CA who draws the reconciliation statement can still do the certification even if any other authorised CA had conducted the audit.

How can SahiGST help you?

When it comes to filing any GST return, SahiGST’s world-class cloud-based platform can help you. SahiGST is an authorised GSP which offers a robust tax filing platform fully capable of handling even the last day rush to give you a smooth and streamlined experience making the filing process a breeze for you.

Other than tax filing, SahiGST also offers everything you require to comply with the GST laws right from filing to reconciliation of returns at one place.

[Find out: Advantages of using SahiGST]

Filing GSTR 9C online

At the moment, GSTR 9C cannot be filed since the facility to file it has not been made available on the GST common portal. The government will very soon make the facility available to the CAs, post which it will also be available on SahiGST. Stay tuned with us, and we will notify you when the facility to file GSTR 9C is ready.

We hope that this guide answers all the questions you have about the audit form GSTR 9C.

Format of GSTR 9C

Part A: Reconciliation Statement

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Part B: Certification