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GSTR-9 Annual Return & GSTR-9C Reconciliation Statement

GSTR-9 annual return filing and GSTR-9C self-certified reconciliation statement preparation — mandatory under Section 44 of the CGST Act, 2017 for taxpayers above ₹2 crore and ₹5 crore turnover respectively.

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STARTING FROM₹14,999
TYPICAL TIMELINE21 days
DOCS REQUIRED3 documents
APPLICABLE TOCompany, LLP, Firm, Individual

Regulatory Framework

Section 44(1) CGST Act 2017 (annual return by 31 December for all registered persons except ISD, non-resident taxable persons, casual taxable persons, TDS/TCS deductors); Rule 80 CGST Rules 2017 (FORM GSTR-9 — six parts covering outward supplies, inward supplies, ITC, tax paid, prior year adjustments, and HSN summary); Rule 80(3) CGST Rules 2017 (GSTR-9C reconciliation statement mandatory above ₹5 crore aggregate annual turnover); CBIC Notification No. 22/2021-Central Tax dated 01.06.2021 (removed CA/Cost Accountant certification requirement for GSTR-9C from FY 2020-21 — replaced by self-certification); Section 47(2) CGST Act 2017 (late fee ₹200/day — ₹100 CGST + ₹100 SGST — capped at 0.25% of turnover in the State/UT); CBIC Circular No. 170/02/2022-GST dated 06.07.2022 (clarified optional tables in GSTR-9 including Tables 6B-8A and Tables 15-19); Rule 142(2) CGST Rules read with Section 74(5) (DRC-03 voluntary payment for ITC reversal identified during annual return preparation to avoid demand notices and penalties).

Overview

Every registered taxpayer with aggregate annual turnover exceeding ₹2 crore is required to file GSTR-9 under Section 44 of the CGST Act, 2017. Taxpayers with turnover above ₹5 crore must additionally file GSTR-9C — a reconciliation statement (now self-certified, replacing CA-certified audit requirement from FY 2020-21 per CBIC Notification 22/2021-Central Tax). GSTR-9 consolidates all monthly/quarterly return data for the financial year and requires reconciliation of outward supplies, inward supplies, ITC claimed, and tax paid. GSTR-9C reconciles the figures in GSTR-9 with the audited annual financial statements. We handle end-to-end preparation, ITC reconciliation between GSTR-2B and books, DRC-03 voluntary payments for reversals identified, and timely filing to avoid the ₹200/day late fee under Section 47.

How It Works

  1. 1

    Data Collection & Document Verification

    Gather all GST returns filed during the year (GSTR-1, GSTR-3B, GSTR-2B month-wise), annual audited financial statements, purchase register, sales register, and ITC ledger. Verify completeness and identify months with amendments or missed filings.

    Government3–5 days
  2. 2

    ITC Reconciliation — GSTR-2B vs Books

    Reconcile ITC as per GSTR-2B with ITC claimed in GSTR-3B and as per books of account. Identify ineligible credits under Section 17(5), credits not yet claimed, and excess credits requiring reversal. Prepare DRC-03 calculation for voluntary payment if needed.

    Government5–7 days
  3. 3

    Preparation of GSTR-9 & GSTR-9C

    Prepare GSTR-9 (all six parts per Rule 80, including optional tables wherever data is available). For taxpayers above ₹5 crore, prepare GSTR-9C reconciliation between GSTR-9 and audited financials, with explanations for all differences.

    Government5–7 days
  4. 4

    Review & Self-Certification

    Partner CA reviews GSTR-9 and GSTR-9C draft. Client reviews reconciliation differences and reasons. Self-certification of GSTR-9C by the authorised signatory (per CBIC Notification 22/2021). DRC-03 filed for any voluntary reversals.

    Government2–3 days
  5. 5

    Filing on GST Portal

    File GSTR-9 and GSTR-9C on the GST Portal (gst.gov.in) before 31 December. Confirm Acknowledgement Reference Number (ARN). Share filed copies and summary with client. Advise on any post-filing compliance actions.

    Government1 day

Frequently Asked Questions

Who must file GSTR-9 and GSTR-9C?
Every registered taxpayer with aggregate annual turnover exceeding ₹2 crore must file GSTR-9 under Section 44 of the CGST Act, 2017 by 31 December following the financial year. Taxpayers with turnover above ₹5 crore must additionally file GSTR-9C (self-certified reconciliation statement under Rule 80(3) since FY 2020-21 per CBIC Notification 22/2021). Composition dealers file GSTR-9A. Input service distributors, non-resident taxable persons, casual taxable persons, and TDS/TCS deductors under Sections 51/52 are exempt from GSTR-9.
What is the due date for filing GSTR-9?
The due date under Section 44 of the CGST Act, 2017 is 31 December of the year following the relevant financial year (e.g., GSTR-9 for FY 2024-25 is due by 31 December 2025). CBIC may extend the deadline by notification for specific financial years.
Is GSTR-9C still required to be certified by a Chartered Accountant?
No. CBIC Notification No. 22/2021-Central Tax dated 01.06.2021 amended Rule 80(3) of the CGST Rules, 2017 to remove the requirement of CA or Cost Accountant certification for GSTR-9C from FY 2020-21 onwards. GSTR-9C is now self-certified by the taxpayer or their authorised signatory. The filing obligation for taxpayers above ₹5 crore remains unchanged — only the certification requirement was removed.
What is the late fee for delayed GSTR-9 filing?
Under Section 47(2) of the CGST Act, 2017, the late fee for delayed GSTR-9 filing is ₹200 per day of delay (₹100 CGST + ₹100 SGST), subject to a maximum cap of 0.25% of the aggregate turnover in the relevant State/UT for that financial year. CBIC has periodically issued amnesty notifications with reduced late fees for past years.
What is the difference between GSTR-9 and GSTR-9C?
GSTR-9 is the annual return consolidating all monthly/quarterly return data (outward supplies, ITC, tax paid) for the financial year — mandatory for taxpayers above ₹2 crore. GSTR-9C is a reconciliation statement that reconciles the GSTR-9 figures with the audited annual financial statements — mandatory for taxpayers above ₹5 crore under Rule 80(3) of the CGST Rules, 2017. GSTR-9C requires self-certification by the taxpayer from FY 2020-21 onwards per CBIC Notification 22/2021.
What is GSTR-2B and why is it important for GSTR-9?
GSTR-2B is an auto-populated monthly ITC statement generated from outward supply filings (GSTR-1/IFF) of a taxpayer's suppliers. It represents the maximum eligible ITC for each month. During GSTR-9 preparation, ITC in GSTR-2B is reconciled with ITC claimed in GSTR-3B and as per books of account to identify excess credits, missed credits, or ineligible credits. This reconciliation is critical to avoid Section 73/74 demand notices during post-filing audits.
What is DRC-03 and when is it used in the GSTR-9 process?
FORM DRC-03 under Rule 142(2) of the CGST Rules is used for voluntary payment of tax. During GSTR-9 preparation, if excess ITC is identified that was claimed in GSTR-3B but is not eligible (not in GSTR-2B or ineligible under Section 17(5)), the taxpayer voluntarily reverses it by paying via DRC-03. This reduces the risk of a demand notice under Section 73 or 74 and avoids the 15%–25% penalty applicable when a demand is raised.
Which tables in GSTR-9 are optional?
CBIC Circular No. 170/02/2022-GST dated 06.07.2022 clarified that multiple tables in GSTR-9 are optional from FY 2021-22 onwards, including Tables 6B to 8A (ITC details and reversals) and Tables 15 and 16 (inward supplies from composition dealers and deemed supply). However, Tables 4 and 5 (outward supplies), Table 9 (tax paid), and Table 17 (HSN-wise outward supply summary for turnover above ₹5 crore) remain mandatory.

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