Overview of GST Annual Return (GSTR-9) and Reconciliation Statement (GSTR-9C)

GSTR-9 is an annual return to be filed yearly by taxpayers registered under GST (subject to turnover limit above Rs. 2 Cr.). It consists of details regarding outward supplies and inward supplies made/ received during the relevant financial year under different tax heads i.e. CGST, SGST & IGST.

It is a consolidation of all the monthly/quarterly returns (GSTR-1, GSTR-2A/2B, GSTR-3B) filed in that year. Due date of filling GSTR-9 for FY 2023-24 is 31^st December 2024.

GSTR-9C is a reconciliation statement to be filed by taxpayers whose aggregate turnover during a financial year exceeds Rs. 5 Cr. It is a statement which consist reconciliation of GST returns filed with the Audited Annual Accounts. Due date of filing GSTR-9C for FY 2023-24 is 31^st December 2024.

GSTR-9C is dependent on GSTR-9 annual return as there are certain fields which are auto-populated from GSTR-9. There are some optional and mandatory fields to be filled up in GSTR-9C. Due care must be taken while filing GST annual return such as reconciliation of GSTR-2A/2B with GSTR-3B, GSTR-1 with GSTR-3B and all the GST returns to be reconciled with books of accounts.

Best Practices & Tips:

• Maintain GSTR- 9 & 9C workings with links to all the relevant data.
• Maintain separate details of ITC claimed, reversed, and re-claimed if the taxpayer fulfils the conditions mentioned u/s 16.
• In case of amendments, outward register to be maintained with original values.
• Credits as per books if unclaimed due to non-matching with GSTR 2A/2B. An option for recovering from vendors can be explored.
• Providing an “Annual GST - Management Report” which may consist of the following:
  • Folder with final workings and filed Form GSTR 1, 3B, GSTR 9 & 9C for the Financial Year.
  • Reconciliations for the FY – Outward, Inward & RCM – birds eye view
  • Reasons for variances and action taken (summarily)
  • Where additional liability was noticed – summary details + payment documentation
  • Suggestions on internal accounting/processes/reporting going forward