Understanding GSTR-9: The Annual GST Return
GSTR-9 is an annual return form that taxpayers registered under the Goods and Services Tax (GST) in India are required to file. It consolidates the details of outward and inward supplies made during a financial year, based on the monthly or quarterly returns filed by the taxpayer (GSTR-1, GSTR-3B, etc.).
Key Features of GSTR-9:
- Applicability: Mandatory for all taxpayers registered under GST, except Casual taxable persons, ISD, Non-resident taxable persons, and taxpayers under the composition scheme (who file GSTR-9A).
- Details Covered: Input Tax Credit (ITC) availed and reversed, taxes paid, supplies made, amendments, demands, and refunds.
- Structure: Six parts covering basic details, supplies, ITC, taxes paid, and other information.
- Due Date: Generally 31st December of the subsequent financial year.
- Penalties: ₹200 per day, capped at 0.25% of turnover.
Key Differences Between GSTR-9 and GSTR-9C:
| Aspect | GSTR-9 | GSTR-9C |
|---|---|---|
| Definition | Annual return summarizing GST details for the financial year. | Reconciliation statement comparing audited financials with GST returns. |
| Applicability | Mandatory for all registered taxpayers except exempted persons. | Mandatory for taxpayers with annual turnover > ₹5 crore. |
| Purpose | To consolidate and summarize all outward supplies, ITC, and tax payments for the year. | To reconcile differences between financial books and GST returns and certify them. |
| Data Scope | Details from GSTR-1, GSTR-3B, and GSTR-2A. | Audited financial statements compared with GSTR-9. |
| Reconciliation | Self-reconciliation of data by the taxpayer. | Detailed reconciliation audited by a professional. |
| Focus Areas | Summary of taxable turnover, ITC claimed, taxes paid, and adjustments. | Discrepancies in turnover, tax liability, and ITC between books and GST returns. |
| Additional Tax Payment | Taxes cannot be paid through GSTR-9. Payment is made via DRC-03. | Additional tax liabilities identified must also be paid via DRC-03. |
| Applicability to Filing | Applicable to all taxpayers filing GST except composition scheme dealers (GSTR-9A) or casual taxable persons. | Applicable only for taxpayers exceeding ₹5 crore turnover. |
Exempted Persons from GSTR-9 and GSTR-9C
| Category | Exempted from GSTR-9 | Exempted from GSTR-9C | Reason for Exemption |
|---|---|---|---|
| Composition Scheme Taxpayers | Yes (they file GSTR-9A instead). | Yes | Composition dealers file a simplified return. |
| Casual Taxable Persons | Yes | Yes | They are temporary GST registrants. |
| Non-Resident Taxable Persons | Yes | Yes | They file GSTR-5 instead of regular returns. |
| Input Service Distributors (ISD) | Yes | Yes | ISDs distribute ITC and do not make outward taxable supplies. |
| Tax Deductors under GST (TDS) | Yes (they file GSTR-7 instead). | Yes | TDS deductors are not regular taxpayers and file GSTR-7. |
| E-Commerce Operators Collecting TCS | Yes (they file GSTR-8 instead). | Yes | E-commerce operators file GSTR-8 for TCS collected. |
| Turnover Below ₹2 Crore | Yes (if notified by the government; optional). | Yes | For small taxpayers, compliance burden is reduced. |
| Turnover Below ₹5 Crore | No | Yes | GSTR-9C is applicable only if turnover exceeds ₹5 crore. |
Detailed Explanation of GSTR-9 Sections
| Table No. | Description | Details Required | Example | Reason & Mandatory/Optional Fields |
|---|---|---|---|---|
| Part I | Basic Details | Taxpayer's basic information like GSTIN, legal name, trade name, and financial year. | GSTIN: 22ABCDE1234FZ1, Legal Name: XYZ Pvt. Ltd., Trade Name: XYZ Electronics, FY: 2023-24 | Reason: To identify the taxpayer and associate the return with the correct GSTIN. Mandatory: GSTIN, Financial Year, Legal Name Optional: Trade Name |
| Part II | Details of Outward and Inward Supplies (As declared in GSTR-1 & GSTR-3B) | Taxable supplies, zero-rated supplies, deemed exports, advances, and adjustments made. | Taxable Supplies: ₹10,00,000, Zero-Rated: ₹2,00,000, Advances: ₹50,000 | Reason: To ensure tax liability is correctly captured. Mandatory: Taxable Supplies, Advances, Zero-Rated Supplies Optional: Deemed Exports, Adjustments |
| Part III | Details of Input Tax Credit (ITC) | ITC claimed on imports, inward supplies, RCM, and other ITC adjustments. | Imports ITC: ₹1,00,000, RCM ITC: ₹50,000, Inward Supplies ITC: ₹5,00,000 | Reason: To ensure the ITC claimed aligns with inward supplies and GST rules. Mandatory: Imports ITC, RCM ITC, Inward Supplies ITC Optional: ITC Adjustments |
| Part IV | Details of Tax Paid as Declared in Returns Filed During the Year | CGST, SGST/UTGST, IGST, and Cess paid and payable during the financial year. | CGST Paid: ₹1,00,000, SGST Paid: ₹1,00,000, IGST Paid: ₹2,00,000, Cess: ₹10,000 | Reason: To confirm the tax payment details and reconcile with GSTR-3B. Mandatory: CGST, SGST, IGST, Cess Paid Optional: Tax Payable |
| Part V | Details of Transactions of Previous FY Declared in Returns of Current FY | Supplies and ITC reported in the returns filed after the due date of the previous financial year. | Previous FY Supplies: ₹50,000, ITC Claimed: ₹20,000 | Reason: To capture corrections or delayed declarations for previous financial year. Mandatory: Previous FY Supplies, ITC Claimed Optional: N/A |
| Part VI | Other Information | Late fees, refunds, demands, and HSN summary for outward and inward supplies. | Late Fee CGST: ₹2,000, Refund Claimed: ₹1,00,000, HSN: 8517 | Reason: To account for compliance-related penalties, refunds, and proper classification of supplies. Mandatory: Late Fee Amounts, Refund Claimed, HSN Codes Optional: UQC, Quantity |
Purpose of GSTR-9 and Its Functionalities
| Section | Details | Examples/Remarks |
|---|---|---|
| Purpose of GSTR-9 | To provide a comprehensive annual summary of GST transactions, reconciling monthly/quarterly returns with annual tax liability. | Ensures accuracy in turnover, ITC, and tax payment details. |
What You Can Do in GSTR-9
| Functionality | Details | Examples/Remarks |
|---|---|---|
| Reconcile Data Across Returns | Consolidate details from GSTR-1 and GSTR-3B to ensure data accuracy. | Compare turnover, taxes, and ITC reported in monthly returns with annual totals. |
| Identify Discrepancies | Detect mismatches or errors in reported data and rectify them before submission. | Example: Turnover mismatch between GSTR-1 and GSTR-3B. |
| Correct Previous Year Transactions | Report transactions of the previous financial year declared in the current financial year. | Include missed invoices or ITC adjustments from the previous FY. |
| Validate Input Tax Credit (ITC) | Verify ITC claimed and reversed during the financial year, ensuring compliance with rules. | Example: Reversal of ITC on exempt supplies (Rule 42/43). |
| Report Exempt, Non-GST, and Zero-Rated Supplies | Summarize turnover related to exempted, nil-rated, non-GST, and zero-rated supplies. | Example: Zero-Rated Turnover = ₹10,00,000; Exempt Supplies = ₹5,00,000. |
| Reconcile Tax Paid | Match taxes paid (CGST, SGST, IGST, and Cess) with liabilities declared in returns. | Example: IGST Paid = ₹1,00,000; CGST Paid = ₹50,000. |
| Summarize HSN Code-Wise Details | Provide classification of goods/services based on HSN codes for outward and inward supplies. | Example: HSN Code 8517 (Mobile Phones), Taxable Value: ₹10,00,000. |
| Track Refunds and Demands | Report refunds claimed (approved, rejected, or pending) and tax demands raised during the financial year. | Refund Claimed = ₹50,000; Refund Sanctioned = ₹45,000. |
| Late Fees and Penalties | Disclose late fees paid for delayed filings, if applicable. | Example: Late Fees Paid = ₹2,000 (CGST) + ₹2,000 (SGST). |
| Ensure GST Compliance | Validate compliance with GST rules and regulations to avoid future penalties or disputes. | Example: Full reconciliation ensures clean tax records and eases audits. |
What You Cannot Do in GSTR-9
| Restriction | Details | Examples/Remarks |
|---|---|---|
| Make New Claims | Cannot claim additional ITC or liabilities not declared in monthly returns. | ITC must be corrected in GSTR-3B before filing GSTR-9. |
| Revise Filed Data | Once GSTR-9 is filed, it cannot be revised. | Example: Errors in GSTR-9 cannot be corrected after submission. |
| Report Missing Data | Cannot report unreported transactions (supplies or ITC) in GSTR-9. | Missed invoices must be corrected in GSTR-3B before filing GSTR-9. |
Benefits of Filing GSTR-9
- Transparency: Ensures all tax-related data is systematically reported for the financial year.
Example: Provides a clear summary of turnover, ITC, and tax payments. - Error Rectification: Offers an opportunity to reconcile and correct mismatches before submission.
Example: Adjust mismatched turnover or ITC between GSTR-1 and GSTR-3B. - Compliance Proof: Acts as proof of compliance with GST laws and provides ease during audits.
Example: Filing GSTR-9 ensures adherence to GST regulations. - Financial Insight: Provides a consolidated view of the taxpayer’s annual transactions, helping in business analysis.
Example: Annual sales turnover = ₹5,00,00,000; Tax liability = ₹50,00,000.
Key Notes
- Voluntary Filing for Exempted Persons: Some exempted taxpayers may still choose to file GSTR-9 voluntarily for record-keeping and compliance.
- Simplified Returns for Special Categories: Composition taxpayers, ISDs, TDS deductors, and e-commerce operators have their own returns (GSTR-9A, GSTR-7, GSTR-8).
- Threshold for GSTR-9C: GSTR-9C is mandatory only for taxpayers with an annual turnover exceeding ₹5 crore.
GSTR-9C: Reconciliation Statement
| Table No. | Section | Details Required | Example | Reason & Mandatory/Optional Fields |
|---|---|---|---|---|
| Part A | Reconciliation of Turnover | Turnover as per audited financial statements vs. turnover declared in GST returns (GSTR-9). | Turnover as per books: ₹10,00,00,000; Turnover as per GSTR-9: ₹9,80,00,000. | Reason: To ensure the declared turnover in GST returns matches the audited financial statements. Mandatory: Audited Turnover, Declared Turnover Optional: Adjustments like unbilled revenue, advances, etc. |
| Part A | Reconciliation of Taxable Turnover | Taxable turnover (after exemptions and adjustments) vs. declared taxable value in GST returns. | Taxable Turnover as per books: ₹7,00,00,000; Declared Taxable Turnover: ₹6,80,00,000. | Reason: To verify taxable value is accurately reported and exemptions are properly applied. Mandatory: Taxable Turnover, Exempt Supplies, Non-GST Turnover Optional: Adjustments like exempt/non-GST supplies. |
| Part A | Reconciliation of Tax Paid | Taxes paid in GST returns vs. actual tax liability (based on reconciled turnover). | CGST Paid: ₹50,00,000; SGST Paid: ₹50,00,000; Additional Tax Liability: ₹2,00,000. | Reason: To ensure the correct taxes have been paid. Mandatory: Taxes Paid, Taxes Payable Optional: Adjustments for additional tax liabilities. |
| Part A | Reconciliation of ITC Claimed | ITC claimed in GST returns vs. ITC as per audited financial statements. | ITC Claimed in GST: ₹1,20,00,000; ITC as per books: ₹1,22,00,000. | Reason: To verify ITC claimed is correct and aligns with GST rules. Mandatory: ITC Claimed, ITC as per Books Optional: Adjustments for eligible/ineligible ITC and reversals. |
| Part A | ITC Reversals and Ineligible ITC | ITC reversed (as per Rule 42/43 or other rules) and ineligible ITC. | ITC Reversed: ₹2,00,000 (Rule 42); Ineligible ITC: ₹50,000. | Reason: To account for ITC reversals or ineligibility under GST rules. Mandatory: Reversed ITC, Ineligible ITC Optional: Reasons for reversal. |
| Part A | Additional Tax Liability | Additional tax payable identified during reconciliation. | Additional IGST: ₹50,000; CGST: ₹25,000; SGST: ₹25,000. | Reason: To disclose discrepancies and pay outstanding taxes. Mandatory: Additional Tax Liability Optional: Reasons for discrepancies. |
Additional Notes for GSTR-9C
- Purpose: Provides a detailed reconciliation of financial data with GST returns and highlights additional liabilities.
- Applicability: Mandatory for taxpayers with an annual turnover exceeding ₹5 crore.
- Penalties for Non-Filing: Failure to file GSTR-9C can lead to penalties under GST laws and scrutiny by tax authorities.
Do's and Don'ts of GSTR-9C Preparation and Filing
| Category | What to Do (Do's) | What Not to Do (Don'ts) |
|---|---|---|
| Preparation |
1. Gather audited financial statements and GST returns (GSTR-1, GSTR-3B, GSTR-9). 2. Ensure turnover, taxable value, and ITC match across all filings. 3. Use accurate adjustments for unbilled revenue, advances, and exempt supplies. |
1. Don’t start preparing GSTR-9C without reconciling financial statements and GST returns. 2. Don’t assume the data in monthly/quarterly returns is error-free; always verify. 3. Don’t use approximations or estimates for reconciliation; always use precise data. |
| Reconciliation |
4. Reconcile tax liability and payments declared in GSTR-3B with the books of accounts. 5. Highlight and disclose any differences in turnover, taxable value, or ITC claimed. |
4. Don’t overlook discrepancies between financial records and GST returns. 5. Don’t hide discrepancies or leave them unresolved; it can lead to penalties during audits. |
| Input Tax Credit (ITC) |
6. Reconcile ITC claimed in GST returns with ITC as per financial books. 7. Disclose any additional ITC identified or ineligible ITC reversed. |
6. Don’t ignore reversals of ITC as required by Rule 42/43 or other ineligible ITC. 7. Don’t claim ITC without verifying eligibility under GST rules. |
| Certification |
8. Get the reconciliation certified by a Chartered Accountant (CA) or Cost Accountant. 9. Include a detailed explanation of discrepancies identified during reconciliation. |
8. Don’t attempt to file GSTR-9C without professional certification; it’s mandatory. 9. Don’t submit GSTR-9C with incomplete or vague auditor comments. |
| Additional Tax Liability |
10. Use DRC-03 to pay additional tax liability identified during reconciliation. 11. Ensure payment of any interest on missed tax liability. |
10. Don’t report additional tax liability directly in GSTR-9C; it must be paid separately. 11. Don’t forget to calculate and pay interest for delayed tax payment. |
| Filing Process |
12. Cross-check all data and ensure the reconciliation statement is error-free before filing. 13. File GSTR-9C before the due date (generally 31st December of the following financial year). |
12. Don’t rush the filing process; errors in GSTR-9C can lead to legal consequences. 13. Don’t miss the deadline for filing GSTR-9C to avoid penalties. |
| General | 14. Keep a record of all reconciliations, adjustments, and DRC-03 payments for future audits. | 14. Don’t discard reconciliation documents, as they are crucial during assessments or audits. |
Updates to GSTR-9 and GSTR-9C for FY 2023-24
1. GSTR-9 Updates
| Table/Section | Description | Update |
|---|---|---|
| Table 4 | Details of outward supplies, inward supplies under reverse charge, and advances received. | A new row G1 has been added after row G for reporting supplies under Section 9(5) by e-commerce operators (ECO). The subtotal in row H now includes values from rows A to G1. |
| Table 5 | Details of outward supplies not liable to GST. | A new row C1 has been added after row C for suppliers reporting Section 9(5) supplies. The total turnover calculation in row N has been adjusted to exclude the impact of ECO supplies reported in row 4G1. |
| Table 6 | Input Tax Credit (ITC) details. | Validation checks ensuring that CGST and SGST amounts are equal in rows 6K and 6L have been removed, simplifying the reporting process. |
| Table 7 | Details of ITC reversals and ineligible ITC. | Similar to Table 6, the validation check for CGST and SGST parity has been removed from this table as well. |
| Table 8 | Other ITC-related information, primarily matching ITC vis-à-vis GSTR-2B. | From FY 2023-24 onwards, Table 8A will be auto-populated with data from GSTR-2B, and the corresponding heading for 8A has been updated. The heading for Table 8B has also been updated to reflect changes in reporting. |
| Tables 12 & 13 | Reversal of ITC availed in the previous financial year and ITC availed for the previous financial year. | Filing these tables is now optional, providing flexibility to taxpayers in reporting these figures. |
| Table 15 | Details of demands and refunds. | Filing this table is now optional, simplifying the form for businesses with minimal entries in this category. |
| Tables 17 & 18 | HSN-wise summary of outward and inward supplies. | For businesses with an annual turnover above ₹5 crore, reporting at the 6-digit HSN code level is mandatory. For those with turnover up to ₹5 crore, reporting at the 4-digit level for B2B supplies is now mandatory. |
2. GSTR-9C Updates
| Table/Section | Description | Update |
|---|---|---|
| Table 5 | Reconciliation of gross turnover. | Businesses can now match their total turnover as per books with Form GSTR-9 by reporting figures directly in Table 5O, simplifying the reconciliation process. |
| Table 14 | Reconciliation of ITC declared in GSTR-9 with ITC availed as per audited financial statements. | Reporting expense-wise ITC availed as per books is now optional, reducing the reporting burden on businesses with fewer ITC figures to report. |
3. General Updates
- Auto-Population of ITC Data: Starting from FY 2023-24, the GST system will automatically populate details of eligible ITC related to domestic supplies (excluding ITC on reverse charge and imports) in Table 8A of GSTR-9, sourced from Table 3(I) of GSTR-2B. This feature aims to streamline the filing process by reducing manual input and improving accuracy in ITC reporting.
- Offline Utility Tool: The Goods and Services Tax Network (GSTN) has launched an updated offline utility tool for filing GSTR-9 and GSTR-9C for FY 2023-24. This tool includes several key updates and enhancements aimed at improving the filing process, such as the addition of new rows for reporting e-commerce supplies under Section 9(5) and the removal of certain validation checks.
These updates reflect the government's efforts to simplify GST compliance and provide greater flexibility to taxpayers. Taxpayers are encouraged to familiarize themselves with these changes to ensure accurate and timely filing of their annual returns and reconciliation statements.
Advisory on Difference in Values of Table 8A and 8C of Annual Returns FY 2023-24
Date: December 9th, 2024
As per the Notification No. 12/2024 Central Tax dated 10th July 2024 read with Notification No. 20/2024-Central Tax Dated 8th October 2024, the total credit available for inward supplies shall be auto-populated in Table 8A of Form GSTR-9 from GSTR-2B for FY 2023-24. In Table 8C of Form GSTR-9, the total value of ITC on inward supplies received during the FY but availed in the next FY up to a specified period must be filled manually.
Various tickets have been raised regarding potential mismatches between Table 8A and 8C of Form GSTR-9 for FY 2023-24. It is important to note that while Table 8A now draws data from GSTR-2B, earlier it was sourced from GSTR-2A. This change may lead to inflated values for FY 2022-23 data and lower-than-expected values for FY 2023-24 in Table 8A, causing mismatches.
Below are some common scenarios and their suggested reporting:
| Sr. No. | Issue | Reporting in GSTR-9 |
|---|---|---|
| 1 | Invoice having the date of FY 2023-24 but reported by the supplier in GSTR-1 after the due date of March 2024. This amount is not auto-populated in Table 8A. | Report such ITC in Table 8C and Table 13, as this is the ITC of FY 2023-24. This aligns with the instructions for Table 8C and Table 13 of GSTR-9. |
| 2 | ITC for FY 2023-24 claimed but reversed due to non-payment to the supplier within 180 days. This ITC is reclaimed in FY 2024-25 after payment. | Such reclaimed ITC should be reported in Table 6H of GSTR-9 for FY 2024-25 and not in Table 8C or Table 13 of FY 2023-24. This is per the instructions for Table 13 in GSTR-9. |
| 3 | ITC for an invoice of FY 2023-24 reversed in GSTR-3B as per Circular 170 guidelines and reclaimed in FY 2024-25. | Report this reclaimed ITC in Table 8C and Table 13 of GSTR-9, as it pertains to FY 2023-24. |
| 4 | Invoice of FY 2022-23 appearing in Table 8A of GSTR-9 for FY 2023-24 because the supplier reported it late. | Do not report this in Table 8C or Table 13 for FY 2023-24, as it pertains to FY 2022-23. This is per Instruction No. 2A for GSTR-9, which specifies that Tables 4, 5, 6, and 7 should contain current FY data only. |
| 5 | Reclaimed ITC for an invoice of FY 2023-24, claimed, reversed, and reclaimed in the same year. | Such ITC should be reported only in Table 6B or Table 6H, but not in both. Do not report it in Table 7 as a reversal. This follows the CBIC press release dated July 3, 2019. |
Key Points to Remember
- Auto-population in Table 8A now comes from GSTR-2B, which may lead to differences compared to earlier years.
- Ensure accurate manual reporting in Table 8C for ITC availed in subsequent financial years.
- Follow the latest instructions for GSTR-9 tables to avoid misreporting.
- Keep track of invoices across financial years to ensure proper ITC claims and reversals.
FAQs on GSTR-9 and GSTR-9C for FY 2023-24
What is the purpose of GSTR-9?
GSTR-9 is an annual GST return that consolidates the details of outward and inward supplies, ITC, and taxes paid during the financial year. It helps ensure accurate reconciliation of monthly/quarterly returns with annual records.
Who is exempt from filing GSTR-9?
Taxpayers such as composition dealers (who file GSTR-9A), casual taxable persons, non-resident taxable persons, and ISDs are exempt from filing GSTR-9.
What is GSTR-9C?
GSTR-9C is a reconciliation statement that matches the data in GSTR-9 with audited financial statements. It is mandatory for taxpayers with a turnover exceeding ₹5 crore.
What are the penalties for not filing GSTR-9 or GSTR-9C?
Late filing of GSTR-9 attracts a penalty of ₹200 per day, subject to a maximum of 0.25% of turnover. For GSTR-9C, failure to file can lead to penalties under GST laws and increased scrutiny.
What updates have been made to Table 4 of GSTR-9?
A new row (G1) has been added for reporting supplies under Section 9(5) by e-commerce operators, and the subtotal in row H now includes values from rows A to G1.
Are Tables 12, 13, and 15 mandatory in GSTR-9?
No, these tables are now optional, providing flexibility for taxpayers who do not have significant data to report in these sections.
Can I claim additional ITC in GSTR-9 or GSTR-9C?
No, additional ITC cannot be claimed in GSTR-9 or GSTR-9C. Any ITC adjustments must be made in GSTR-3B before filing the annual returns.
What happens if discrepancies are found during reconciliation?
Discrepancies should be disclosed in GSTR-9C, and any additional tax liabilities identified must be paid using Form DRC-03.
What is the deadline for filing GSTR-9 and GSTR-9C for FY 2023-24?
The due date for filing GSTR-9 and GSTR-9C is generally 31st December of the following financial year unless extended by the government.
What are the HSN code requirements for FY 2023-24?
- Businesses with turnover > ₹5 crore must report HSN codes at the 6-digit level.
- Businesses with turnover ≤ ₹5 crore must report HSN codes at the 4-digit level for B2B supplies.
- Businesses with turnover ≤ ₹5 crore must report HSN codes at the 4-digit level for B2B supplies.
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