Quick comparison of GSTR-9 & GSTR-9C

Ever since GSTR-9 & GSTR-9C forms have been released by CBIC, there has been persistent confusion surrounding who must file these forms and whether the details required for both are the same or not. But not any more!

This article provides you a quick comparison of GSTR-9 and GSTR-9C. 

Quick comparison of GSTR-9 & GSTR-9C

Points of comparisonGSTR-9: Annual ReturnGSTR-9C: Reconciliation Statement
NatureInformational/ a consolidation of all GST returnsAnalytical statement on GST returns to be self-certified by CFO/Finance head
Who must fileGST registered taxpayerGST registered taxpayer to whose aggregate annual turnover is more than Rs 5 crore
Not applicable to – Composition Dealers
 – Casual Taxable Person (CTP)
 – Non-Resident Taxable Person (NRTP)
 – Input Service Distributor (ISD)
 – Unique Identification Number (UIN) holders 
 – Online Information and Database Access Retrieval (OIDAR) Service providers 
 – Persons subject to TCS or TDS provisions
Those persons mentioned under the column for GSTR-9 including a registered person whose aggregate turnover in an FY is less than Rs.5 crore
Optional forBusinesses having less than Rs 2 crore turnover (w.e.f FY 2017-18)  Businesses having less than Rs 5 crore turnover
Due date for filing^31st December of next FY*31st December of next FY, either with or after filing GSTR-9*
Late fees & penaltyFrom FY 2022-23 onwards-S.No Turnover limit Late fee per dayMaximum late fee1Up to Rs 5 croreRs 50 (Rs 25 each under CGST and SGST Act)0.04% of turnover in state/UT (0.02% each under CGST and SGST Act)2More than Rs 5 crore and less than Rs 20 croreRs 100 (Rs 50 each under CGST and SGST Act)0.04% of turnover in state/UT (0.02% each under CGST and SGST Act)3More than Rs 20 croreRs 200 (Rs 100 each under CGST and SGST Act) 0.50% of turnover in state/UT (0.25% each under CGST and SGST Act)
 Up to FY 2021-22-
– Late fees of Rs 200 per day of delay subject to a maximum cap of an amount at 0.50% (0.25% each under CGST and SGST) of total turnover in respective State/UT until 31st March 2023.

The CBIC has notified vide 07/2023 dated 31st March 2023 to waive off late fee in excess of Rs.20,000 (Rs.10,000 each under CGST and SGST laws) for delayed filing of GSTR-9 for years 2017-18  up to 2021-22 if filed between 1st April 2023 to 30th June 2023.
No specific provision, Hence, subject to a general penalty of Rs 25,000
Filing of the returnOn GST portal or through facilitation centreOn GST portal or through facilitation centre at the time of or after filing GSTR-9
Format of the returnConsolidated summary details of the 
 – Turnover
 – ITC and tax paid
 – Late fees paid in GST returns filed during the FY
 – Amendments made between April to 30th November of next FY

Also, below details must be declared wherever applicable: 
 – Demands/ refunds
 – Supplies from composition dealers
 – Job works
 – Goods sent on an approval basis
 – HSN wise summary of sales and purchases
 – Late fees payable
Part-A -Reporting of reconciliation needed between turnover, tax paid and ITC. Report on Auditor’s recommendation of any additional tax liability.

 Part -B – Self-certification by CFO/Finance head.
Who must certify/ attestNo certification required by CA/CMA; however it must be attested by the taxpayer using a digital signatureCFO/Finance head must certify using a digital signature
AnnexuresNo annexures to be attachedAnnexure of Audited financial statement is required
^Budget 2023 amended that taxpayers can not file a GSTR-9 after three years from the expiry of the original due date. CBIC is yet to notify this change.
* Subject to CBIC notifications for any due date extension.

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