GSTR-9 is the GST annual return that every registered taxpayer must file consolidating all monthly/quarterly returns for the year. GSTR-9C is a reconciliation statement—certified by a Chartered Accountant—required only when turnover exceeds ₹5 crore. CA firms must guide clients on both, with very different preparation approaches.

Quick Comparison: GSTR-9 vs GSTR-9C

ParameterGSTR-9GSTR-9C
Full nameAnnual ReturnReconciliation Statement & Certification
Who must fileAll GST-registered taxpayers (except exemptions)Taxpayers with turnover > ₹5 crore
Prepared byTaxpayer / CA / Tax ProfessionalChartered Accountant (mandatory certification)
PurposeConsolidate all supplies, tax paid, ITC claimedReconcile audited financials with GSTR-9 data
Due date FY 2025-2631 December 202631 December 2026 (same)
Penalty for non-filing₹200/day (₹100 CGST + ₹100 SGST)₹200/day (linked with GSTR-9)
Filed onGST portal independentlyGST portal after GSTR-9 is submitted

Who Is Exempt from GSTR-9?

The following taxpayers are not required to file GSTR-9:

  • Taxpayers registered under the Composition Scheme (they file GSTR-9A instead, currently suspended)
  • Casual taxable persons
  • Non-resident taxable persons
  • Persons paying tax under Section 10 (Composition)
  • Input Service Distributors
  • OIDAR service providers

What Goes Into GSTR-9?

GSTR-9 has 6 parts covering the entire financial year:

PartWhat It Covers
Part IBasic registration details
Part II (Tables 4–5)Details of outward supplies (taxable, exempt, nil-rated, non-GST)
Part III (Tables 6–8)ITC details — availed, reversed, ineligible
Part IV (Tables 9–10)Tax paid as declared in returns vs. actual tax payable
Part V (Tables 11–13)Transactions from previous year declared/amended in current year
Part VI (Tables 14–18)Other information — HSN summary, late fees, demands, refunds

What Goes Into GSTR-9C?

GSTR-9C reconciles the figures in GSTR-9 with the audited financial statements. It has two parts:

  • Part A – Reconciliation Statement: Compares turnover as per books vs. GST returns; reconciles ITC per books vs. ITC in returns; identifies unreconciled differences.
  • Part B – Certification: Chartered Accountant certifies that the reconciliation is accurate and based on audited accounts. The CA signs with DSC.

Common Reconciliation Differences CA Firms Encounter

Difference AreaCommon ReasonAction Required
Turnover mismatchAdvances, credit notes not reflected in returnsAmend returns or explain in 9C
ITC excess claimedGSTR-2B auto-population vs. books differenceReverse excess ITC in next return
Tax paid differenceCash payments vs. ITC utilisation timingReconcile ledger entries
Exempt/nil-rated supplyNot reported correctly in monthly returnsCorrect in GSTR-9 Part II

GSTR-9C Turnover Threshold — History and Current Rule

The GSTR-9C threshold has changed multiple times:

  • FY 2017-18 to 2019-20: ₹2 crore
  • FY 2020-21 onwards: ₹5 crore (currently in force)

For FY 2025-26, GSTR-9C is mandatory for taxpayers with aggregate annual turnover exceeding ₹5 crore in any state/UT.

TaxZeo's GST compliance tracker auto-flags clients who cross the ₹5 crore threshold and need GSTR-9C, so your team never misses a reconciliation assignment.

Try TaxZeo Free

Frequently Asked Questions

Can GSTR-9C be filed without GSTR-9?

No. GSTR-9C can only be filed after GSTR-9 has been submitted (not necessarily filed) for the same financial year. The system links both filings. Always ensure GSTR-9 is in submitted status before uploading GSTR-9C.

What is the penalty for late filing of GSTR-9?

Late fee is ₹200 per day (₹100 CGST + ₹100 SGST), subject to a maximum of 0.25% of turnover in the state/UT. Note: there is no specific late fee provision for GSTR-9C separately—it flows from the GSTR-9 late fee.

Is self-certification allowed for GSTR-9C?

Yes, from FY 2020-21 onwards, the taxpayer can self-certify GSTR-9C without a CA's certification, provided they have accounts audited under the GST Act. However, for most clients, CA certification remains standard practice for accuracy and audit protection.

Does a composition taxpayer file GSTR-9 or GSTR-9C?

Composition scheme taxpayers were required to file GSTR-9A (the composition annual return), but GSTR-9A has been suspended since FY 2019-20. As of now, composition dealers with turnover above ₹2 crore file CMP-08 quarterly and are exempt from GSTR-9/9C.