GSTR-9C Reconciliation Statement
GSTR-9C is the statement that reconciles your GST annual return with your audited financial statements. You need it once aggregate turnover for the year crosses ₹5 crore. Since FY 2020-21 you certify it yourself, and it is due with GSTR-9 by 31 December.
What it is
GSTR-9C is a reconciliation statement. It puts two sets of numbers side by side: what you reported on the GST portal for the year, and what your audited books say. Where they differ, it says why. And where a difference means tax was short-paid, it shows the extra amount due.
The requirement sits in Section 44 of the CGST Act, 2017 read with Rule 80(3) of the CGST Rules. Up to FY 2019-20, a chartered accountant or cost accountant had to audit and certify the statement under Section 35(5). The Finance Act, 2021 removed that audit from 1 August 2021, and Notification 30/2021-Central Tax (30 July 2021) made GSTR-9C self-certified by the taxpayer from FY 2020-21 onwards. It is filed on the GST portal along with the annual return in GSTR-9.
Who it applies to
Turnover above ₹5 crore in the year
Any regular taxpayer filing GSTR-9 whose aggregate turnover for the financial year exceeds ₹5 crore. Up to ₹5 crore, GSTR-9C is not required.
Every GSTIN under the same PAN
Aggregate turnover is counted across all your GST registrations in India on the same PAN. Say a Faridabad auto-parts maker also holds a small depot registration in Uttar Pradesh. If the combined turnover crosses ₹5 crore, both GSTINs file GSTR-9C.
Companies, LLPs, firms and proprietors
The test is turnover, not the type of entity. A proprietor with ₹6 crore of sales files GSTR-9C just as a private limited company does.
Why it matters
It answers the officer’s questions upfront
GSTR-9C shows the department every gap between your books and your returns, with your explanation beside it. A clear statement answers questions before they turn into notices.
It closes the year cleanly
Short-paid tax found during reconciliation can be paid through DRC-03 with interest, on your own terms, before anyone raises a demand.
It stops the late fee clock
The annual return is not complete until GSTR-9C is filed where it is required. Late fee keeps running until both forms are in.
Documents required
From your books
- Audited financial statements for the year (balance sheet, profit and loss, notes)
- Trial balance and ledgers for sales, purchases and expenses
- Details of credit notes, debit notes and year-end adjustments
- Schedule of advances received and unbilled revenue
From the GST portal
- GSTR-1 and GSTR-3B for all twelve months
- GSTR-2B statements for the year
- Electronic cash and credit ledgers
- Draft or filed GSTR-9
For signing
- Valid digital signature certificate of the authorised signatory, where the entity signs with DSC
- List of GSTINs on the same PAN
- Tax audit report, if one was prepared
Common reconciliation differences
Part A of GSTR-9C reconciles four things: gross turnover, taxable turnover, tax paid and input tax credit. Part B is the self-certification. Most differences fall into a few familiar groups.
| Difference | Why it arises | What follows |
|---|---|---|
| Unbilled revenue | Income booked in the accounts before the GST invoice is raised | Explained as a timing difference; GST falls due when the invoice is issued |
| Unadjusted advances | Advance received this year, supply made next year | Checked against the tax already paid on the advance, where applicable |
| Credit notes | Credit note accounted in one year, reported in GST in another | Matched across the two years |
| Deemed supplies | Stock transfers between your own GSTINs, which the books may not treat as sales | Added to GST turnover, not to accounting turnover |
| Input tax credit | Credit claimed in GSTR-3B differs from ITC on expenses in the books | Excess credit reversed through DRC-03 with interest |
Here is the catch: a difference is not a problem in itself. An unexplained one is. Take a Faridabad civil contractor who books March work as unbilled revenue and raises the invoice in April. The accounts show higher turnover than the returns for that year, and GSTR-9C is where that timing gap gets its one-line explanation. If a query comes later anyway, our GST notice reply team works from the same papers.
How it works
Check whether you cross ₹5 crore
We total turnover across every GSTIN on your PAN for the year and confirm whether GSTR-9C applies, and for which registrations.
Match the books with the returns
We line up the audited accounts against GSTR-1, GSTR-3B and GSTR-2B, month by month. Every difference goes on a list with its reason. In practice, most of the time goes here, not in the form itself.
Pay any shortfall through DRC-03
If the reconciliation shows short-paid tax or excess credit, we compute it with interest and you pay it before filing.
Finalise GSTR-9 alongside
GSTR-9C is filed with the annual return, so we prepare both together. See our GSTR-9 annual return service for that side of the work.
Self-certify and file on the GST portal
The authorised signatory certifies Part B, and we upload the statement with the audited financials before 31 December.
Timelines
File by 31 December
GSTR-9C is due with GSTR-9 on or before 31 December following the financial year. For FY 2025-26, that is 31 December 2026, unless the government extends it.
Close the audit by October
The statement reconciles with audited figures. Leave the audit to December and the reconciliation gets squeezed into a few days. A tax audit report, where applicable, helps too.
Pay shortfalls before you file
Additional tax found in reconciliation is paid through DRC-03, with interest at 18% a year under Section 50 from the original due date.
What happens if you file late
Late fee runs until both forms are filed
Under Section 47(2), late fee applies until the complete annual return is furnished. Circular 246/03/2025-GST (30 January 2025) confirms that where GSTR-9C is required, GSTR-9 alone does not stop the fee.
The fee depends on your turnover
From FY 2022-23 (Notification 07/2023-Central Tax): ₹100 a day, capped at 0.04% of turnover in the State, for ₹5–20 crore; ₹200 a day, capped at 0.5%, above ₹20 crore. These are CGST plus SGST combined.
Unexplained gaps draw notices
An officer can issue an ASMT-10 scrutiny notice asking you to explain them. A general penalty of up to ₹25,000 under Section 125 can also apply where no specific penalty is provided.
Frequently asked questions
Who has to file GSTR-9C?
Every registered person filing GSTR-9 whose aggregate turnover for the financial year exceeds ₹5 crore. Aggregate turnover is counted on your PAN across all GSTINs in India, so each registration under that PAN files its own statement once the total crosses the limit. Composition taxpayers file GSTR-9A, not GSTR-9C. If your turnover is ₹5 crore or less, GSTR-9C does not apply, and only GSTR-9 matters.
Does a chartered accountant still need to certify GSTR-9C?
No, not since FY 2020-21. The Finance Act, 2021 removed the GST audit under Section 35(5) from 1 August 2021, and Notification 30/2021-Central Tax made the statement self-certified by the taxpayer. The authorised signatory signs Part B. The working itself still needs an accountant’s eye, because every figure comes from audited accounts and has to match the returns. You sign; we do the working.
What is the due date for GSTR-9C?
31 December following the end of the financial year, the same date as GSTR-9. For FY 2025-26, the due date is 31 December 2026, unless the government issues an extension. GSTR-9C is filed along with the annual return, so plan both together. Closing the statutory audit by September or October leaves enough time to reconcile, pay any shortfall and file without a rush.
What is the late fee for filing GSTR-9C late?
Late fee is charged on the annual return under Section 47(2), and it runs until both GSTR-9 and GSTR-9C are filed. From FY 2022-23, it is ₹100 a day, capped at 0.04% of State turnover, for ₹5–20 crore, and ₹200 a day, capped at 0.5%, above ₹20 crore. These figures combine CGST and SGST. Filing both forms on time keeps the fee at zero.
Can I file GSTR-9 now and GSTR-9C later?
You can, but the late fee does not stop. Circular 246/03/2025-GST clarified that the annual return is complete only when GSTR-9C is also furnished, where it is required. The one-time waiver under Notification 08/2025-Central Tax covered years up to FY 2022-23 and needed filing by 31 March 2025, so it has ended. File both together and the question never comes up.
What if the reconciliation shows I paid less tax?
You pay the shortfall through Form DRC-03 on the GST portal, with interest at 18% a year under Section 50, and report it in the statement. Paying voluntarily before filing is far better than waiting for a demand notice. The same applies to excess input tax credit, which is reversed with interest. Once paid, the gap is explained and closed on your own record.
Which figures does GSTR-9C reconcile?
Part A reconciles four sets of figures: gross turnover, taxable turnover, tax paid and input tax credit, each between the audited accounts and the GST returns. Part B is the taxpayer’s self-certification. Typical gaps are unbilled revenue, unadjusted advances, credit notes across years and deemed supplies between your own GSTINs. Each difference is listed with its reason, which makes the statement easy for an officer to follow.
Can GSTR-9C be revised after filing?
No, the GST portal has no option to revise GSTR-9C once it is filed. If you later find an error that means tax was short-paid, you can still pay it through DRC-03 with interest. That is why we review the statement line by line before you sign. A careful review before 31 December avoids a correction exercise later.
Is there a government fee for filing GSTR-9C?
No, there is no filing fee for GSTR-9C on the GST portal. The only government amounts are any late fee under Section 47(2) and any shortfall in tax with interest found during reconciliation. A business with ₹5–20 crore turnover that files a week late pays ₹700 in late fee, for example. Filed on time with a clean reconciliation, the statutory cost is nil.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
There is no filing fee for GSTR-9C. Late fee on the annual return, from FY 2022-23:
| Aggregate turnover | Late fee per day (CGST + SGST) | Maximum |
|---|---|---|
| Above ₹5 crore up to ₹20 crore | ₹100 | 0.04% of turnover in the State |
| Above ₹20 crore | ₹200 | 0.5% of turnover in the State |
Any tax shortfall is paid through DRC-03 with interest at 18% a year.
Ready to begin?
Send us your audited accounts and GST login access, and we will have your GSTR-9C reconciled and filed before 31 December.