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
| Parameter | GSTR-9 | GSTR-9C |
|---|---|---|
| Full name | Annual Return | Reconciliation Statement & Certification |
| Who must file | All GST-registered taxpayers (except exemptions) | Taxpayers with turnover > ₹5 crore |
| Prepared by | Taxpayer / CA / Tax Professional | Chartered Accountant (mandatory certification) |
| Purpose | Consolidate all supplies, tax paid, ITC claimed | Reconcile audited financials with GSTR-9 data |
| Due date FY 2025-26 | 31 December 2026 | 31 December 2026 (same) |
| Penalty for non-filing | ₹200/day (₹100 CGST + ₹100 SGST) | ₹200/day (linked with GSTR-9) |
| Filed on | GST portal independently | GST 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:
| Part | What It Covers |
|---|---|
| Part I | Basic 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 Area | Common Reason | Action Required |
|---|---|---|
| Turnover mismatch | Advances, credit notes not reflected in returns | Amend returns or explain in 9C |
| ITC excess claimed | GSTR-2B auto-population vs. books difference | Reverse excess ITC in next return |
| Tax paid difference | Cash payments vs. ITC utilisation timing | Reconcile ledger entries |
| Exempt/nil-rated supply | Not reported correctly in monthly returns | Correct 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 FreeFrequently 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.