GSTR 9C: Reconciliation Statement & Certification- Filing, Format & Rules

GSTR-9C is the GST reconciliation Statement for a particular FY to be filed by taxpayers on or before 31st December after being certified by CAs. It must be filed along with the GSTR-9(Annual Returns) and the Audited Financial Statements on the GST Portal or be filed through the facilitation centre.

In this article, we discuss the following:

• What is GSTR-9C?
• Who must prepare and submit GSTR-9C?
• What is the due date for submission of GSTR-9C?
• What’s the relevance or importance of GSTR-9C?
• What are the contents of the GSTR-9C?

1. What is GSTR-9C?

GSTR-9C is a statement of reconciliation between:

• the Annual returns in GSTR-9 filed for an FY, first being 2017-18 and
• the figures as per Audited Annual Financial statements of the taxpayer.

It is certified by the CA. It can be considered to be similar to that of a tax audit report furnished under the Income tax act. It will consist of gross and taxable turnover as per the Books reconciled with the respective figures as per the consolidation of all the GST returns for an FY. Hence, any differences arising from this reconciliation exercise will be reported here along with the reasons for the same.

The certified statement shall be issued  for every GSTIN. Hence, for a PAN there can be several reports of GSTR-9C.

2. Who must prepare & submit GSTR-9C?

GSTR-9C must be prepared and certified by the Chartered Accountant or Cost Accountant. It must be filed on the GST portal or through facilitation centre by the taxpayer along with other documents such as the copy of the Audited Accounts and Annual returns in GSTR-9.

This statement is applicable to all those taxpayers who must get their Annual Accounts audited under the GST laws. Audit applies to those registered persons whose Annual aggregate turnover exceeds Rs 2 crores in that FY, here being FY 2017-18.

3.What is the due date for GSTR-9C?

The competent authority has decided to extend the due date for filing FORM GSTR-9, FORM GSTR-9A and FORM GSTR-9C till 31st March, 2019. FORM GSTR-9 and FORM GSTR-9A have been notified vide notification No. 39/2018-Central Tax, dated 04.09.2018while FORM GSTR-9C has been notified vide notification no. 49/2018-Central Tax, dated 13.09.2018 as part of the CGST Rules.

4. What’s the importance of GSTR-9C?

A Chartered accountant or cost accountant must prepare this GST Reconciliation statement. Any differences between the details reported in all the GST returns and the Audited Accounts must be reported by the CA therein with the reasons for the differences. Also, this statement acts as a base for the GST authorities to verify the correctness of the GST returns filed by the taxpayers. This is because the CA has to certify any additional liability arising out of the reconciliation exercise and GST audit in GSTR-9C.

5. What are the contents of the GSTR-9C?

The GSTR-9C consists of two main parts:

Part-A: Reconciliation Statement
Part-B: Certification

Part-A: Reconciliation Statement

The figures in the audited financial statements are at PAN level. Hence, the turnover, Tax paid and ITC earned on a particular GSTIN( or State/UT) must be pulled out from the audited accounts of the organisation as a whole.

The Reconciliation Statement is divided into five parts as follows:

Part-I: Basic details: Consists of FY, GSTIN, Legal Name and Trade Name. The taxpayer must also mention if he is subject to audit under any other law

Part-II: Reconciliation of turnover declared in the Audited Annual Financial Statement with turnover declared in Annual Return (GSTR-9)-
This involves reporting the gross and taxable turnover declared in the Annual return with the Audited Financial Statements. One must note that mostly the Audited Financial statement is at a PAN level. This might require the break up of the audited financial statement at GSTIN level for reporting in GSTR-9C.

Part-III: Reconciliation of tax paid-
This section requires GST rate-wise reporting of the tax liability that arose in FY 2017-18 as per the accounts and paid as reported in the GSTR-9 respectively with the differences thereof. Further, it requires the taxpayers to state the additional liability due to unreconciled differences noticed upon reconciliation.

Part-IV: Reconciliation of Input Tax Credit (ITC)-
This part consists the reconciliation of input tax credit availed and utilised by taxpayers as reported in GSTR-9 and as reported in the Audited Financial Statement. Further, it needs a reporting of Expenses booked as per the Audited Accounts, with a breakup of eligible and ineligible ITC and reconciliation of the eligible ITC with that amount claimed as per GSTR-9. This declaration will be after considering the reversals of ITC claimed, if any.

Part-V: Auditor’s recommendation on additional Liability due to non-reconciliation-
Here, the Auditor must report any tax liability identified through the reconciliation exercise and GST audit, pending for payment by the taxpayer. This can be non-reconciliation of turnover or ITC on account of :

• Amount paid for supplies not included in the Annual Returns(GSTR-9)
• Erroneous Refund to be paid back
• Other Outstanding demands to be settled

Lastly, the instructions to the format of GSTR-9C specify that an option will be given to taxpayers to settle taxes as recommended by the auditor at the end of the reconciliation statement.

Part-B: Certification

The GSTR-9C can be certified by the same CA who conducted the GST audit or it can be also certified by any other CA who did not conduct the GST Audit for that particular GSTIN.

The difference between both is that in case the CA certifying the GSTR-9C did not conduct the GST audit, he must have based an opinion on the Books of Accounts audited by another CA in the reconciliation statement. The format for certification report will vary depending on who the certifier is.

*Latest Update as on 8th December 2018: Due date for filing GSTR-9, GSTR-9A and GSTR-9C is extended till 31st March 2019 by CBIC for FY 2017-18