12/7/2019 Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

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Easy Guide to GSTR 9C (GST Audit Form)

Online Return Filing Process

 Updated on November 28, 2019 (https://blog.saginfotech.com/gstr-9c-online-return-filing)  Subodh

Kumawat (https://blog.saginfotech.com/author/subodh)  GST Articles
(https://blog.saginfotech.com/category/gst-india/gst-articles)

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What is GSTR 9C (GST Audit Form)?

GSTR 9C is an annual audit form for all the taxpayers having the turnover above 2 crores in a
particular financial year. Along with the GSTR 9C audit form, the taxpayer will also have to fill up
the reconciliation statement along with the certification of an audit.

Under this, the authorities have also introduced the format of GSTR 9C in the notification No.
49/ 2018 – Central tax dated September 13, 2018.

SAG Infotech is here to provide all the relevant details of GSTR 9 and 9C form and step by step
procedure to file them along with the screenshots. The GSTR 9C form has a reconciliation
statement for reconciling turnover, input tax credits and tax payments. The taxpayers can also
view and download (https://blog.saginfotech.com/wp-content/uploads/2018/09/gstr-9c-

format.pdf) the GSTR 9C form in PDF format.

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Latest Updates of GSTR 9C Form

Who is Required to File GSTR 9C
Significance of GSTR 9C Audit Form
GSTR 9C Due Dates Extension & Penalty Norms
How to File the GSTR 9C Form?
General Queries on GSTR 9C Form
GSTR 9C Filing By Gen GST Software

Simplify GSTR 9C Filing by CBIC

Some exemptions has been done in this form listed below:

1. Part of turnover adjustments necessary in Table 5B to 5N is now not mandatory and all
the adjustment now necessary to be described in Table 5O;
2. Table 12B, 12C and 14 (ITC reconciliation) are now not mandatory;
3. Few changes done in the Declaration part also.

What is GSTR 9C Annual GST Audit Form?

As per the rules, all the taxpayer will have to file an annual return form with GSTR 9
(https://blog.saginfotech.com/gstr-9-online-return-filing) but now in an addition to the current
rule, Section 35 of CGST Act, 2017, all those taxpayers having turnover exceeding 2 crores in a
financial year will have to submit audited annual accounts along with a reconciliation statement
in GSTR 9C form.

Who is Required to File the GSTR 9C (GST Audit Form)?

All those taxpayers having the turnover above 2 crores in a financial year are required to file
GSTR 9C form along with the reconciliation statement and certification of an audit.

Latest News/Updates of GSTR 9C Form



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The given notification asserts that the amendments and relevant changes have been
done in the GSTR 9 and GSTR 9C which is given in the Notification No. 56/2019 dated
14.11.2019. Also, the said changes will be reflected in the application software and the
offline tools by 10th Dec. 2019.

Significance of GSTR 9C Audit Form

GSTR-9C is a reconciliation statement which must be certified by a Chartered Accountant or a

CMA. Taxpayers whose aggregate turnover in a financial year exceeds Rs 2 Crores need to file
GSTR-9C. The GSTR-9C must be digitally signed by the GST Auditor and must report all
discrepancies or liabilities in filing any of the GST returns during the financial year. All additional
liabilities arising out of the reconciliation exercise and GST audit must be reported and certified
by a CS in GSTR-9C. The GSTR-9c is the only yardstick or indicator for GST Authorities to
measure the correctness of GST returns filed by taxpayers during a given financial year.

Due Date Extension for Filing GSTR 9C Audit Form

Under GST?

Once again, the Indian government has extended the due date of GSTR 9C (Reconciliation
Statement) form for both financial year (Read Press Release (https://blog.saginfotech.com/wp-
content/uploads/2019/11/gstr-9-9c-due-date-extended.pdf))

Financial Year 2017-18 – 31st December 2019

Financial Year 2018-19 – 31st March 2020

Note: “Central Board of Indirect Taxes & Customs (CBIC) notified the amendments regarding
the simplification of GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) which
inter-alia allow the taxpayers to not to provide split of input tax credit availed on inputs, input
services and capital goods and to not to provide HSN level information of outputs or inputs, etc.
for the financial year 2017-18 and 2018-19.”


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GSTR 9C Audit Form Penalty Norms If Miss the Last

Date

As per the penalty provisions of GSTR 9C audit return form, the taxpayer has to pay Rs.
200 per day as a penalty in which Rs. 100 consist of SGST and Rs. 100 for CGST. Also, it
is to be noted that the total penalty cannot exceed 0.25% of the total turnover on which
the said penalty is being levied.

Updates in GSTR 9C Reconciliation Form By GST

Council 31st Meeting

FORM GSTR-1 & FORM GSTR-3B returns are required to be filed before the filing of
FORM GSTR-9 & FORM GSTR-9C
FORM GSTR-9 & FORM GSTR-9C cannot be used for availing ITC
FORM GSTR-9C would include verification by the taxpayer who had uploaded
reconciliation statement

Where to Download GSTR 9C Offline Utility?

The government has released the file an annual return form with GSTR 9 which can be filed up
by the taxpayers and then uploaded to the portal. The offline utility is given in a zip folder which
has to be downloaded:

To download the offline utility for the GSTR 9C first visit the gst.gov.in portal
Opt on the download tab on the main menu
Now click on the offline tools in the option and it will redirect to download page

Click on download option and extract the file

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Where to Find GSTR 9C Online Filing Option on Portal?

Also, there is now available GSTR 9C online utility. To start filing the GSTR 9C reconciliation
audit report, perform given steps:

First of all, login with username id & password on www.gst.gov.in

After that, the dashboard will open, click on the ‘Annual Return’ tab
Now click on the financial year for the desired period to file the return, click on the FY
2017-18
An option like ‘Initiate e-filing’ will appear on the screen, click on that
But as soon as you will select the filing option, you will be asked for filing GSTR 9 form
before you can file reconciliation form. Know more (https://blog.saginfotech.com/gst-
portal-online-filing-gstr-9c)

Items Included While Calculating Turnover for GST

Audit:

All taxable supplies, including intra-state and inter-state apart from the ones which attract
a reverse charge, will be included.
Supplies involved between two business verticals
Goods or supplies that are sent/received by the job worker on principal to principal basis.
All export/zero-rated supplies
Supplies made by agent/job work on behalf of the principal
All exempt supplies
All taxes apart from the ones covered under GST. For example entertainment tax paid

against the sale of tickets

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Items Excluded While Calculating Turnover for GST

Audit:

All inward supplies against which tax is paid under reverse charge.
All kinds of taxes and cess part of Goods and Service Tax like SGST, CGST or IGST, etc.
Goods that are received back or supplied to a Job Worker
Activities that are not part of goods or services under schedule III of the CGST Act

How to File the GST Audit Form GSTR 9C – Step by

Step:

The GSTR-9 has two major parts:

Part-A: Reconciliation Statement
GSTR 9C Part-B: Certification

GSTR 9C Part-A: Reconciliation Statement Format

Part 1: Basic Details has the following four sections: Financial Year for which return is being
filed.

1. Financial Year
2. GSTIN of the taxpayer
3A. Legal Name of the registered person
3B. Trade Name (if any) of the registered business
4. If the taxpayer is liable for any audit under this act?

Note: For FY 2017-18, it will contain details for July 2017 to March 2018 period.
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Part 2: Reconciliation of turnover declared in the audited Annual Financial Statement with
turnover declared in Annual Return (GSTR9)

5. Reconciliation of Gross Turnover

5A. Turnover (including exports) as per audited financial statements for the State /
UT (For multi-GSTIN units under same PAN the turnover shall be derived from the
audited Annual Financial Statement): The turnover as per the audited Annual
Financial Statement shall be declared here. There may be cases where multiple
GSTINs (State-wise) registrations exist on the same PAN. This is common for
persons/entities with a presence over multiple States. Such persons/entities will
have to internally derive their GSTIN wise turnover and declare the same here. This
shall include export turnover (if any). It may be noted that reference to audited
Annual Financial Statement includes reference to books of accounts in case of
persons/entities having a presence over multiple States.
5B. Unbilled revenue at the beginning of Financial Year (+): Unbilled revenue which
was recorded in the books of accounts on the basis of accrual system of accounting
in the last financial year and was carried forward to the current financial year shall
be declared here. In other words, when GST is payable during the financial year on
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such revenue (which was recognized earlier), the value of such revenue shall be
declared here.
C. Unadjusted advances at the end of the Financial Year (+): Value of all advances
for which GST has been paid but the same has not been recognized as revenue in
the audited Annual Financial Statement shall be declared here.
D. Deemed Supply under Schedule I (+): an Aggregate value of deemed supplies
under Schedule I of the CGST Act, 2017 shall be declared here. Any deemed
supply which is already part of the turnover in the audited Annual Financial
Statement is not required to be included here.
E. Credit Notes issued after the end of the financial year but reflected in the annual
return (+): an Aggregate value of credit notes which were issued after 31st of March
for any supply accounted in the current financial year but such credit notes were
reflected in the annual return (GSTR-9)shall be declared here.
F. Trade Discounts accounted for in the audited Annual (+) Financial Statement but
are not permissible under GST: Trade discounts which are accounted for in the
audited Annual Financial Statement but on which GST was leviable(being not
permissible) shall be declared here.
G. Turnover from April 2017 to June 2017 (-): Turnover included in the audited
Annual Financial Statement for April 2017 to June 2017 shall be declared here
H. Unbilled revenue at the end of Financial Year (-): Unbilled revenue which was
recorded in the books of accounts on the basis of accrual system of accounting
during the current financial year but GST was not payable on such revenue in the
same financial year shall be declared here.
I. Unadjusted Advances at the beginning of the Financial Year (-): Value of all
advances for which GST has not been paid but the same has been recognized as
revenue in the audited Annual Financial Statement shall be declared here.

 J. Credit notes accounted for in the audited Annual Financial Statement but is not
permissible under GST (-): an Aggregate value of credit notes which have been

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accounted for in the audited Annual Financial Statement but were not admissible
under Section 34 of the CGST Act shall be declared here
K. Adjustments on account of supply of goods by SEZ units to DTA Units (-): an
Aggregate value of all goods supplied by SEZs to DTA units for which the DTA units
have filed the bill of entry shall be declared here.Easy Guide to GSTR 9C GST
Audit Form with Online Return Filing Process
L. Turnover for the period under composition scheme (-): There may be cases
where registered persons might have opted out of the composition scheme during
the current financial year. Their turnover as per the audited Annual Financial
Statement would include turnover both as for composition taxpayer as well as the
normal taxpayer. Therefore, the turnover for which GST was paid under the
composition scheme shall be declared here.
M. Adjustments in a turnover under section 15 and rules thereunder (+/- ): There
may be cases where the taxable value and the invoice value differ due to valuation
principles under section 15 of the CGST Act, 2017 and rules thereunder. Therefore,
any difference between the turnover reported in the Annual Return (GSTR 9) and
turnover reported in the audited Annual Financial Statement due to the difference in
valuation of supplies shall be declared here.
N. Adjustments in turnover due to foreign exchange fluctuations (+/- ): Any
difference between the turnover reported in the Annual Return (GSTR9) and
turnover reported in the audited Annual Financial Statement due to foreign
exchange fluctuations shall be declared here
O. Adjustments in turnover due to reasons not listed above (+/-): Any difference
between the turnover reported in the Annual Return (GSTR9) and turnover reported
in the audited Annual Financial Statement due to reasons not listed above shall be
declared here.

 P. Annual turnover after adjustments as above

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Q. Turnover as declared in Annual Return (GSTR9): Annual turnover as declared in

the Annual Return (GSTR 9) shall be declared here. This turnover may be derived
from Sr. No. 5N, 10 and 11 of Annual Return (GSTR 9)
R. Un-Reconciled turnover (Q – P) AT1

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
6. Reasons for Un – Reconciled difference in Annual Gross Turnover

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Reasons for non-reconciliation between the annual turnover declared in the audited
Annual Financial Statement and turnover as declared in the Annual Return (GSTR
9) shall be specified here.

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7. Reconciliation of Taxable Turnover

The table provides for the reconciliation of taxable turnover from the audited annual
turnover after adjustments with the taxable turnover declared in annual return
(GSTR-9).
A. Annual turnover after adjustments (from 5P above): Annual turnover as derived
in Table 5P above would be auto-populated here.
B. Value of Exempted, Nil Rated, Non-GST supplies, No-Supply turnover: Value of
exempted, nil rated, non-GST and no-supply turnover shall be declared here. This
shall be reported net of credit notes, debit notes and amendments if any.
C. Zero-rated supplies without payment of tax: Value of zero-rated supplies
(including supplies to SEZs) on which tax is not paid shall be declared here. This
shall be reported net of credit notes, debit notes and amendments if any.
D. Supplies on which tax is to be paid by the recipient on reverse charge basis:
Value of reverse charge supplies on which tax is to be paid by the recipient shall be
declared here. This shall be reported net of credit notes, debit notes and
amendments if any
E. Taxable turnover as per adjustments above (A-B-C-D): The taxable turnover is

 derived as the difference between the annual turnover after adjustments declared in

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Table 7A above and the sum of all supplies (exempted, non-GST, reverse charge
etc.) declared in Table 7B, 7C and 7D above.
F. Taxable turnover as per liability declared in Annual Return (GSTR9): Taxable
turnover as declared in Table 4N of the Annual Return (GSTR9) shall be declared
here.
G. Unreconciled taxable turnover (F-E)

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8. Reasons for Un – Reconciled difference in taxable turnover

Reasons for non-reconciliation between adjusted annual taxable turnover as
derived from Table 7E above and the taxable turnover declared in Table 7F shall be
specified here.

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Part 3: Reconciliation of tax paid

9. Reconciliation of rate wise liability and amount payable thereon

The table provides for the reconciliation of tax paid as per reconciliation statement
and amount of tax paid as declared in Annual Return (GSTR 9). Under the head
labelled ―RCǁ, supplies where the tax was paid on reverse charge basis by the
recipient (i.e. the person for whom reconciliation statement has been prepared )
shall be declared with GSTR 9 file an annual return form with GSTR 9
P. Total amount to be paid as per tables above: The total amount to be paid as per
liability declared in Table 9A to 9O is auto-populated here
Q. The total amount paid as declared in Annual Return (GSTR 9): The amount
payable as declared in Table 9 of the Annual Return (GSTR9) shall be declared
here. It should also contain any differential tax paid on Table 10 or 11 of the Annual
Return (GSTR9)

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10. Reasons for un-reconciled payment of amount: Reasons for non-reconciliation

 between payable / liability declared in Table 9P above and the amount payable in Table
9Q shall be specified Part-B: Certification.

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11. Additional amount payable but not paid (due to reasons specified under Tables 6,8
and 10 above): Any amount which is payable due to reasons specified under Table 6, 8
and 10 above shall be declared here.

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Part 4: Reconciliation of ITC (Input Tax Credit)

12. Reconciliation of Net ITC (Input Tax Credit)

A. ITC availed as per audited Annual Financial Statement for the State/ UT (For
multi-GSTIN units under same PAN this should be derived from books of accounts):
ITC availed (after reversals) as per the audited Annual Financial Statement shall be
declared here. There may be cases where multiple GSTINs (Statewise)
registrations exist on the same PAN. This is common for persons/entities with a
presence over multiple States. Such persons/entities will have to internally derive
their ITC for each individual GSTIN and declare the same here. It may be noted
that reference to audited Annual Financial Statement includes the reference to
books of accounts in case of persons/entities having the presence over multiple
States.
B. ITC booked in earlier Financial Years claimed in current Financial Year (+): Any
ITC which was booked in the audited Annual Financial Statement of an earlier
financial year(s)but availed in the ITC ledger in the financial year for which the
reconciliation statement is being filed for shall be declared here. This shall include
transitional credit which was booked in earlier years but availed during Financial
Year 2017-18.
C. ITC booked in current Financial Year to be claimed in subsequent Financial
Years (-): Any ITC which has been booked in the audited Annual Financial
Statement of the current financial year but the same has not been credited to the
ITC ledger for the said financial year shall be declared here.
D. ITC availed as per audited financial statements or books of account: ITC availed
as per audited Annual Financial Statement or books of accounts as derived from
values declared in Table 12A, 12B and 12C above will be auto-populated here.
E. ITC claimed in Annual Return (GSTR 9): Net ITC available for utilization as
 declared in Table 7J of Annual Return (GSTR9) shall be declared here.

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13. Reasons for un-reconciled difference in ITC

Reasons for non-reconciliation of ITC as per audited Annual Financial Statement or
books of account (Table 12D) and the net ITC (Table12E) availed in the Annual
Return (GSTR9) shall be specified here.

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14. Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on
expenses as per audited Annual Financial Statement or books of account.
This table is for the reconciliation of ITC declared in the Annual Return (GSTR9)
 against the expenses booked in the audited Annual Financial Statement or books of
account. The various sub-heads specified under this table are general expenses in

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the audited Annual Financial Statement or books of account on which ITC may or
may not be available. Further, this is only an indicative list of heads under which
expenses are generally booked. Taxpayers may add or delete any of these heads
but all heads of expenses on which GST has been paid/was payable are to be
declared here.
A. Purchases
B. Freight / Carriage
C. Power and Fuel
D. Imported goods (Including received from SEZs)
E. Rent and Insurance F Goods lost, stolen, destroyed, written off or disposed of by
way of gift or free samples
G. Royalties
H. Employees’ Cost (Salaries, wages, Bonus etc.)
I. Conveyance charges
J. Bank Charges
K. Entertainment charges
L. Stationery Expenses (including postage etc.)
M. Repair and Maintenance
N. Other Miscellaneous expenses
O. Capital goods
P. Any other expense 1
Q. Any other expense 2
R. Total amount of eligible ITC availed: Total ITC declared in Table 14A to 14Q
above shall be auto-populated here.
S. ITC claimed in Annual Return (GSTR9): Net ITC availed as declared in the
Annual Return (GSTR9) shall be declared here. Table 7J of the Annual Return

 (GSTR9) may be used for filing this Table.

T. Un-reconciled ITC | ITC 2

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15. Reasons for the un-reconciled the difference in ITC: Reasons for non-reconciliation
between ITC availed on the various expenses declared in Table 14R and ITC declared in
Table 14S shall be specified here.

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16. Tax payable on the un-reconciled difference in ITC (due to reasons specified in 13
and 15 above): Any amount which is payable due to reasons specified in Table 13 and 15
above shall be declared here.

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Part 5: Auditor’s recommendation on additional Liability due to non-reconciliation



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Part V consists of the auditor’s recommendation on the additional liability to be

discharged by the taxpayer due to non-reconciliation of turnover or non-reconciliation of
the input tax credit. The auditor shall also recommend if there is any other amount to be
paid for supplies not included in the Annual Return. Any refund which has been
erroneously taken and shall be paid back to the Government shall also be declared in this
table. Lastly, any other outstanding demands which are recommended to be settled by
the auditor shall be declared in this Table.

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GSTR 9C Part-B: Certification

A certification part is also done once after the GSTR 9 audit is conducted by the person
responsible for the audit. The form has two major parts including

1 – Certification in cases where the reconciliation statement (Form GSTR 9C) is drawn up by

the person who had conducted the audit.

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A – Balance sheet date

B – P&L Account including dates
C – Cash flow statement including dates

2 – Based on audit the auditor mentioned:

Proper maintenance of books status

Or not maintained

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3(A) – Based on any observations done by the auditor, reporting any differences:

 3(B) – Further reporting

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4 – Documents required under section 35(5) of CGST and reconciliation statement required
which are to furnished under section 44(2) of CGST Act annexed in form no. GSTR 9C

5 – All the details and transactional information stated in GSTR form 9C are validated in this
point.

Credentials With Signature, Name of the signatory, Membership no. and Date

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General Queries on GSTR 9C Form

Q.1 Is the Audit of Accounts maintained by the registered taxable

person required to be got done by a Chartered Accountant/Cost

Accountant under GST?

As per the GST law, it is mandatory for all the Registered person to get their accounts audited
by a chartered accountant or a cost accountant whose aggregate turnover during a financial
year exceeds the threshold limit of Rs. 2 Crore. Whence, no such audit is required to be got
done by the Chartered or Cost accountant in cases other than mentioned above.

Q.2 – Does ‘aggregate turnover’ deals with topics such as stock

transfers/ cross charges effected between branches located in two

different states?


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Aggregate Turnover has been defined in Section 2(6) of CGST/ SGST Act and the definition of
aggregate turnover includes ‘inter-state supplies of a person having the same PAN’. Thus, we
see that stock transfers/ cross-charges of services provided from a branch, located in one state
to a branch located in another state is included in the definition of Aggregate turnover of the
related branch supplying goods/ services.

Q.3 – Does the term ‘aggregate turnover,’ includes stock transfers

which are effective within the States having same GSTIN for

determining the threshold limits?

The term ‘aggregate turnover’ is not supposed to be included in stock transfers effective within
the same state having single GSTIN for the purpose of determining the threshold limit. However,
in cases where more than one GSTIN has been allotted for the different branches located in the
same state, such branch transfers shall be included for computing threshold limit of Rs. 2 crore
to get to the conclusion that whether there is any requirement for audit or not.

Q.4 – Will a Registered Taxpayer who has exclusively exempted

supply of goods or services exceeding Rs. 2 crores, would require

to fill the GSTR 9C form?

As ‘aggregate turnover’ has been defined under the GST Act, it includes ‘exempt supplies’.
Thus, even in the case of a registered person under GST who provides exempted supplies, will
have to file Form GSTR 9C.

Q.5 Does the Form GSTR 9C be required to be filed by a person

against each registration obtained by him in respect of each of the

States?

Provision is that Section 35(5) of SGST Act requires Audit to be conducted in addition to
Section 35(5) of CGST Act. Thus, to maintain Compliance audit is required to be conducted
state wise as per Section 35(5) of SGST Act. Thus, if we consider an example like if a person is
 having registration in Karnataka and Tamil Nadu, then he is required to be audited for his
accounts under KGST Act, 17 and TNGST Act, 17. The GSTR 9C form is required to be filed

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under Rule 80(3) of KGST Rules, 2017 and the TNGST Rules. Thus, it is evident that a person
registered in more than one state is supposed to file form GSTR 9C registration wise for each
and every state.

Q.6 – Is it required for a Chartered Accountant to be got registered

as a GST practitioner to get certified the Form GSTR 9C?

A GST practitioner gets authorization for the practice of the below-mentioned rules as per
Section 48 of the CGST/ SGST Act under Rule 83(8) of the CGST/ SGST Act:

a) furnishing the details of outward and inward supplies

b) to furnish monthly, quarterly, annual or final return
c) Can make deposits to get amount credited into the electronic cash ledger
d) he could file a claim for any sort of refund
e) filing application for getting the registration amended or getting the registration
canceled

The GST Act/ Rules does not give the ‘Power to Audit’ to a GST practitioner as per section
35(5). ‘Power to Audit’ is only granted to Chartered Accountants or Cost Accountants. Thus, it is
not required for a Chartered Accountant to get registered as a GST practitioner for certifying
Form GSTR 9C.

Q.7 – What are the documents to be enclosed along with GSTR 9C?

Under section 35(5), it is stated that a copy of audited accounts and other such
documents in the prescribed manner along with the reconciliation statement (Form GSTR
9C) to be submitted.
The ‘Prescription’ which is mentioned in the Act should be provided as mentioned in the
term ‘as may be prescribed’. Only the audited annual accounts have been prescribed in
Rule 80(3) in the name of documents.

Talking about Part B of GSTR 9C, it is required by the GST Auditor to get a copy of audit
report of the entity enclosed where the audit of the entity has been conducted by another
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person under a statute other than the GST Act.

In the mentioned case, the documents which has been declared by the statute, which
would further be considered as audited financial statements, must be annexed to the
audit report.

Q.8 – Should the Form GSTR 9 and Form GSTR 9C get filed

separately?

As per Section 44(2) of the CGST/ SGST Act 2017, a Registered person is required to file his
Annual return in Form GSTR 9 along with this he has to provide a reconciliation statement
through Form GSTR 9C. Thus we see, Form GSTR 9C is required to be filed along with Form
GSTR 9 where the turnover exceeds Rs. 2 crores.

Q.9 – Is there any time limit to file Form GSTR 9C?

The Section 44(2) states that the reconciliation statement is required to be provided in Form
GSTR 9C along with the Form GSTR 9. Section 44(1), on the other hand, declares the due
dates. As per this section, the due date for filing the annual return is on or before the thirty-first
day of December following the end of the FY for which the Annual return is prepared. Thus, the
conclusion could be drawn that the due date for filing reconciliation statement in Form GSTR 9C
is on or before the thirty-first day of December following the end of the financial year for which
the reconciliation statement is being prepared.

Q.10 – Could the late fee be waived off in Genuine and special

cases?

The Government has the right to get a part or full of the late fee, mentioned in section 47,
waived through notification, for such section of taxpayers and under such mitigating and
specified circumstances. All this could be done on the recommendation of the Council.
However, no such notification is evident to till date issued by the Central Government/ State
Government.


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Q.11 – Is Audit, mentioned under Section 35(5), be applicable to the

Non-Filers or unregistered Persons who are liable to get

registered?

As per Section 35(5) of the CGST Act, only a Registered person is required to get his
accounts audited by a CA or CWA. Again, a non-filer is a Registered Person according to
Section 25 of the CGST Act, thus he must get audit conducted under Section 35(5) of the
said Act. Considering practically, such a person would never had filed his returns and
hence, Form 9 & 9C wouldn’t be possible in his case and no audit for him is required.
Understanding clearly, an unregistered person who is eligible for registration under
Section 25 of the CGST is a taxable person. Here, the unregistered Person is not a
Registered Person as per Section 2(94) of the CGST Act 2017. Hence, following Section
35(5) of the Act, audit is not required.

Q.12 – Mention the records which are required to be reconciled in

Form GSTR-9C?

The records to be reconciled in GSTR-9C are:

Books of accounts of the registered person – If a registered person has multiple

registrations, The required information could be derived from the Audited financials of the
entity.
Annual Return of Registered Person in Form GSTR 9.

Q.13 – What are the contents of Form GSTR 9C?

Form GSTR 9C consists of 2 parts. Part-A consists of Reconciliation statement and Part B is

Certificate to be issued by GST Auditor.

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Q.14 – What are the details which are to be provided in SI. No.5B

(Unbilled revenue at the beginning of Financial Year)?

The unbilled revenue at the beginning of Financial Year are required to be added in Clause 5B.
The unbilled revenue recorded on the basis of the accrual system of Accounts in the Books of
accounts for the earlier financial year for which the invoice is issued under GST law, is required
to be declared here. Understanding more clearly, the value of such Revenue which has been
recognized as income during a financial year on which GST is liable to be paid, is required to be
mentioned in SI. No.5B

Q.15 – Mention the adjustments to be included/excluded from SI.

No.5C of Form GSTR-9C?

The advances which are received could be of various purposes. Therefore, the Advances on
which GST is liable should only be considered for the adjustment. The illustrations of advances
to be included/excluded are as follows:

Include for Adjustment

1. Advance received in respect of services for which the Revenue not recognized in
supply has not been made as on 31st March 2018 books, but offered to tax for
GST

2. Advance received for Goods before 15th Nov 2017 and Revenue not recognized in
the supply of goods not complete as on 31st March books, but offered to tax for
2018 GST


Do NOT include for Adjustment

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Sl. Particular’s Reason

No.

1. Advance received for EXEMPTED services as on 31St March GST is not

2018 applicable

2. Advance received for Goods after 15th Nov 2017 GST is not
applicable

3. Financial Advances received which are not adjustable against NOT a GST
any services Transaction

How to File GSTR 9C By Gen GST Software

(6E9xI3_1bG0)


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SUBODH KUMAWAT (HTTPS://BLOG.SAGINFOTECH.COM/AUTHOR/SUBODH)

Subodh has done with numerous professional degrees ranging from Human Rights to
Banking along with MBA in HR Marketing. He is also interested in the field of tax-related
articles and blog as per the industry based norms. Having expert knowledge in diverse
sectors, he assures facts and figures along with testimony, in his articles. Working in SAG
Infotech, he is a trusted author among the readers globally.

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

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15 thoughts on “Easy Guide to GSTR 9C (GST Audit Form) Online

Return Filing Process”

THIRUMALAI MANIVASAGAM
November 23, 2019 at 8:59 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-49088)

How to get the button named get the client?

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=49088#RESPOND)

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

November 25, 2019 at 2:54 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-49140)

Please specify in detail

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=49140#RESPOND)

DHAVAL PATEL
November 7, 2019 at 10:17 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-48878)

HOW TO SHOW RCM ITC (ON TRANSPORT) IN GSTR – 9C?

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=48878#RESPOND)

 NITESH SHARMA
August 10, 2019 at 1:56 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-47527)

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12/7/2019 Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

Sir, Please tell me about GSTR 9C due to filling

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=47527#RESPOND)

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

August 13, 2019 at 11:06 am (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-47641)

Due date is 31.08.2019

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=47641#RESPOND)

PAYAL PATEL
July 5, 2019 at 11:24 am (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-46782)

I have nil return & no input in Jan, Feb & Mar 2017-18 is it compulsory to file GSTR 9C
reconciliation statement for me

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=46782#RESPOND)

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

July 5, 2019 at 6:41 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-46791)

GSTR-9C IS REQUIRED TO BE FILED ONLY IN CASE YOU ARE LIABLE FOR AUDIT
UNDER GST.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=46791#RESPOND)

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12/7/2019 Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

AJAY
May 13, 2019 at 12:18 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-46200)

Sir, part II -5, (E), a credit note issued after the end of the fy but reflected in the annual return,
-_———-
We have declared credit note, issued in 17-18, under Part-II 4-(I), of Gstr9
And credit notes issued in next year 18-19, declared in Part V- 11, of Gstr9,
——–
We are confused, about point II -5, (E),

Please clarify … thanks

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=46200#RESPOND)

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

May 14, 2019 at 10:34 am (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-46213)

Part II- 5 (E) covers NIL rated supplies. so please clarify your query.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=46213#RESPOND)

CA PAWAN KEDIA
April 27, 2019 at 7:43 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-46008)

Very good efforts has been made by you and it is very useful material.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=46008#RESPOND)

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12/7/2019 Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

ABHI
March 18, 2019 at 12:37 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-45239)

Sir, Can you please explain where to file GSTR 9C?

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=45239#RESPOND)

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

March 19, 2019 at 5:17 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-45256)

GSTR-9C is still not released by dept. on portal.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=45256#RESPOND)

CHANDRAVIJAY SHAH
September 15, 2018 at 3:30 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-40319)

Painstaking efforts by you.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=40319#RESPOND)

CHANDRAVIJAY SHAH
September 15, 2018 at 3:29 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-40318)

Is it an Audit Report or a Reconciliation Statement?

Can you provide Excel format of 9C?


REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=40318#RESPOND)

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12/7/2019 Easy Guide to GSTR 9C (GST Audit Form) Online Return Filing Process

SAG INFOTECH (HTTPS://BLOG.SAGINFOTECH.COM/)

September 18, 2018 at 6:08 pm (https://blog.saginfotech.com/gstr-9c-online-return-filing#comment-40405)

There is no excel format of GSTR-9C yet. A pdf is made available by Govt. which shall be
available on CBIC, gov, in under Notification No. 49/Central Tax dated 14.09.2018.

REPLY (HTTPS://BLOG.SAGINFOTECH.COM/GSTR-9C-ONLINE-RETURN-FILING?REPLYTOCOM=40405#RESPOND)

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