GSTR-9C - GST Reconciliation Statement
It’s been more than a year since GST was implemented in India and whose imposition has brought along with it lots of compliances in the form of return filing. The Government has introduced filing of annual return forms like GSTR-9, 9C along with monthly/quarterly GST returns.
GSTR-9C is a reconciliation statement between:
- The GSTR-9 (GST Annual Return) filed for an FY and
- The figures as per audited annual financial statements of the taxpayer.
GSTR-9C must be certified by a Chartered Accountant or a Cost Accountant. It is to be filed for each GSTIN separately. It must be filed on the GST portal or through facilitation centre along with a copy of audited accounts at the time of or after filing GSTR-9.
Basically, GSTR-9C contains the reconciliation of gross and taxable turnover, ITC and taxes paid as per books of accounts with the figures reported in GSTR-9 annual return for an FY. If any difference arises in reconciliation then same shall be reported here along with the reason for such a difference.
GSTR-9C is applicable for all those taxpayers who need to get their accounts audited under the GST law. And the requirement of audit applies on those registered persons whose aggregate turnover exceeds Rs. 2 Crores during the financial year.
That is every registered person whose aggregate turnover exceeds Rs. 2 Crores during the financial year needs to undertake the following:-
- Get his accounts audited as per Section 35(5) of the GST Act.
- Furnish a copy of such audited annual accounts.
- File electronically a reconciliation statement in Form GSTR-9C.
The GSTR-9C must be filed on or before 31st December of the year subsequent to the financial year under audit. It can be filed along with GSTR-9 or after filing GSTR-9 for the financial year whose deadline is also 31st December.
That is for the FY 2017-2018, the due date for filing GSTR-9C will be 31st December 2018.
Who will prepare and certify GSTR-9C?
GSTR-9C must be prepared and certified by a Chartered Accountant or Cost accountant. If any difference arises after the reconciliation between annual GST return (GSTR-9) filed during the financial year and the annual audited accounts must be reported by CA along with the reason of such difference.
GSTR-9C has been divided into two main sections which are further sub-divided into parts:
- Reconciliation Statement
Reconciliation statement is divided into 5 parts:
Part-1: Basic details
Under this, details like financial year, GSTIN, legal and trade name needs to be mentioned along with whether the taxpayer is liable for audit under any other act.
Part-2: Reconciliation of turnover declared in an audited annual financial statement with turnover declared in annual return (GSTR-9)
This includes reporting of gross and taxable turnover declared in the Audited Financial Statement and Annual Return (GSTR-9) along with reasons for the un-reconciled difference in gross and taxable turnover.
Part-3: Reconciliation of taxes paid
This involves reporting of rate-wise GST liability that arises during the financial year as per the audited accounts and tax paid as reported in GSTR-9 along with the differences. Further, additional liability needs to be reported if any arises at the time of reconciliation.
Part-4: Reconciliation of Input Tax Credit (ITC)
Under this part, reconciliation of ITC availed as per audited financial statements and ITC claimed in annual return (GSTR-9) needs to be mentioned along with reasons of difference if any.
Further, expense wise reconciliation of ITC declared in Annual Return (GSTR-9) with ITC availed on expenses as per audited Annual Financial Statement or books of account needs to be reported where the total amount of expense, total ITC on such expense and amount of eligible ITC availed on it must be reported.
Part-5: Auditor’s recommendation on additional liabilities created due to non- reconciliation
In this auditor must report any tax liability identified during the reconciliation exercise, pending for payment by the taxpayer.
The certification is divided into two sections. In first section, certification is required in case where the reconciliation statement is drawn up by the person who had conducted the GST audit. However, in another section certification is required in case where the reconciliation statement is drawn up by a person other than the person who had conducted the audit of the accounts.
There is no specific provision for late fees and penalty in case of delay in filing of GSTR-9C. Hence, the general penalty shall be applicable in case of late filing i.e., Rs. 25,000.