GSTR-9 & GSTR-9C Annual Return and Audit Explained

Under the Goods and Services Tax (GST) law, GSTR‑9 and GSTR‑9C are critical annual
compliance returns that consolidate, reconcile, and validate the data reported in
monthly/quarterly GST returns. Every business registered under GST must evaluate its
turnover‑based applicability and ensure timely filing to avoid heavy late fees, interest,
and scrutiny from tax authorities.
This article is prepared for publication on taxcellent.in and explains the mandatory
applicability of GSTR‑9 & GSTR‑9C for all GST‑registered businesses, due dates,
penalties, and FAQs in a simple and practical manner.

What is GSTR‑9 (GST Annual Return)?
GSTR‑9 is an annual return that provides a consolidated summary of all GST
transactions reported during a financial year. It is prepared based on data already filed
in GSTR‑1, GSTR‑3B, and GSTR‑2B and includes outward supplies, inward supplies, ITC
availed, ITC reversed, tax paid, refunds, and demands.

Legal Provision
GSTR‑9 is prescribed under Section 44 of the CGST Act, read with Rule 80(1) of the
CGST Rules.

What is GSTR‑9C (Reconciliation Statement)?
GSTR‑9C is a reconciliation statement that reconciles:
• Figures reported in GSTR‑9 (Annual Return), and
• Figures as per audited financial statements
It highlights differences in turnover, tax liability, and Input Tax Credit (ITC). GST audit by
CA/CMA has been removed, and GSTR‑9C is now self‑certified by the taxpayer.

Applicability of GSTR‑9 & GSTR‑9C (Turnover‑Based)
Applicability depends on aggregate turnover calculated PAN‑India.

Mandatory Filing Criteria
• Aggregate Turnover up to ₹2 Crore
o GSTR‑9: Exempt / Optional
o GSTR‑9C: Not Applicable
• Aggregate Turnover above ₹2 Crore and up to ₹5 Crore
o GSTR‑9: Mandatory
o GSTR‑9C: Not Applicable
• Aggregate Turnover above ₹5 Crore
o GSTR‑9: Mandatory
o GSTR‑9C: Mandatory (Self‑Certified)
Important: Annual return must be filed GSTIN‑wise, even if multiple registrations exist
under the same PAN.

Who is NOT Required to File GSTR‑9 / GSTR‑9C?

The following persons are exempt:
• Composition taxpayers (file GSTR‑4 instead)
• Casual taxable persons
• Non‑resident taxable persons
• Input Service Distributors (ISD)
• Persons deducting TDS under GST (Section 51)
• Persons collecting TCS under GST (Section 52) .

Due Date for GSTR‑9 & GSTR‑9C
The standard due date is:
• 31st December of the year following the relevant financial year

For FY 2024‑25, the due date is 31st December 2025, unless extended by notification.

Late Fees & Penalties
Failure to file GSTR‑9 or GSTR‑9C attracts statutory late fees:

Late Fee for GSTR‑9
• ₹200 per day (₹100 CGST + ₹100 SGST)
• Maximum cap: 0.25% of turnover per Act (0.5% combined).

Interest
• 18% per annum on any unpaid tax liability.

Key Points Every Business Must Remember
• Filing is mandatory even if registration was cancelled during the year
• Nil transactions may still require Nil GSTR‑9
• GSTR‑9 cannot be revised once filed
• All GSTR‑1 and GSTR‑3B must be filed before annual return is enabled.

Frequently Asked Questions (FAQs)

Q1. Is GSTR‑9 mandatory for all GST‑registered businesses?
GSTR‑9 is mandatory if aggregate turnover exceeds ₹2 crore. Businesses up to ₹2 crore
are exempted as per the notification.
Q2. Is GSTR‑9C mandatory even after GST audit is removed?
Yes. GST audit by CA/CMA is removed, but GSTR‑9C remains mandatory for
turnover above ₹5 crore on a self‑certification basis.
Q3. What is aggregate turnover for GSTR‑9C?
Aggregate turnover includes taxable, exempt, zero‑rated, and export supplies across
India under the same PAN, excluding GST taxes.
Q4. Can GSTR‑9 or 9C be revised after filing?
No. Once filed, annual returns cannot be revised.
Q5. Is GSTR‑9 required for cancelled GST registrations?
Yes. If registration was active even for one day during the financial year, GSTR‑9 is
required.

Conclusion
GSTR‑9 and GSTR‑9C are non‑negotiable annual GST compliances that play a vital
role in reconciling books of accounts with GST returns. Businesses must evaluate
turnover thresholds carefully and ensure timely filing to avoid penalties and
departmental scrutiny.
For expert assistance in GSTR‑9 & GSTR‑9C preparation, reconciliation, and filing,
contact Taxcellent – your trusted GST compliance partner.