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In our previous blog, we brought to you the detailed final format for Form GSTR 9A, which was primarily for composition dealers. In this blog, we present the final format notified for Form GSTR 9C, along with steps to file it quickly.

Form GSTR 9C – Quick Rules

It will be mandatory to file all your GSTR 1, GSTR 3B and GSTR 9 returns for the FY 2017-18 before filing this return – in which where you will need to provide details for the period between July 2017 to March 2018. The reconciliation statement is to be filed for every GSTIN separately.

Towards the end of the return, you will also be given an option to pay any additional liability declared in this form, through Form DRC 03, by selecting “Reconciliation Statement” in the drop-down menu. However, this liability must be paid only via your electronic cash ledger.

Part 1: Form GSTR 9C – Basic Details

Part 1 of Form GSTR 9C requires you to fill in some basic details with regards to your business –

  • Financial Year
  • GSTIN
  • Legal Name
  • Trade Name (if any)
  • Are you liable to audit under any Act?

Part 2: Reconciliation of turnover declared in audited Annual Financial Statement with turnover declared in Annual Return (Form GSTR 9)

Part 2 of Form GSTR 9C comprises of the following tables:

Table No.Details
5AThe 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 or entities with presence over multiple States. Such persons or entities will have to internally derive their GSTIN wise turnover and declare the same here. This shall include export turnover, if any.
5BUnbilled revenue which was recorded in the books of accounts based on 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 such revenue, the value of such revenue shall be declared here.
5CValue 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.
5DAggregate value of deemed supplies 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.
5EAggregate 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 Form GSTR 9 shall be declared here.
5FTrade discounts which are accounted for in the audited Annual Financial Statement but on which GST was leviable (being not permissible) shall be declared here.
5GTurnover included in the audited Annual Financial Statement for April 2017 to June 2017 shall be declared here.
5HUnbilled revenue which was recorded in the books of accounts based on 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.
5IValue 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.
5JAggregate value of credit notes which have been accounted for in the audited Annual Financial Statement but were not admissible shall be declared here.
5KAggregate value of all goods supplied by SEZs to DTA units for which the DTA units have filed bill of entry shall be declared here.
5LThere 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 composition taxpayer as well as normal taxpayer. Therefore, the turnover for which GST was paid under the composition scheme shall be declared here.
5MThere may be cases where the taxable value and the invoice value differ due to valuation principles. Therefore, any difference between the turnover reported in Form GSTR 9 and turnover reported in the audited Annual Financial Statement due to difference in valuation of supplies shall be declared here.
5NAny difference between the turnover reported in Form GSTR 9 and turnover reported in the audited Annual Financial Statement due to foreign exchange fluctuations shall be declared here.
5OAny difference between the turnover reported in Form GSTR 9 and turnover reported in the audited Annual Financial Statement due to reasons not listed above shall be declared here.
5QAnnual turnover as declared in Form GSTR 9 shall be declared here. This turnover may be derived from Tables 5N, 10 and 11 of Form GSTR 9.
6Reasons for non-reconciliation between the annual turnover declared in the audited Annual Financial Statement and turnover as declared in Form GSTR 9 shall be specified here.
7The table provides for reconciliation of taxable turnover from the audited annual turnover after adjustments with the taxable turnover declared in Form GSTR 9.
7AAnnual turnover as derived in Table 5P above would be auto-populated here.
7BValue 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.
7CValue 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.
7DValue 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.
7EThe taxable turnover is derived as the difference between the annual turnover after adjustments declared in Table 7A above and the sum of all supplies (exempted, non-GST, reverse charge etc.) declared in Tables 7B, 7C and 7D above.
7FTaxable turnover as declared in Tables (4N – 4G) + (10 -11) of Form GSTR 9 shall be declared here.
8Reasons 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.

Part 3: Reconciliation of Tax Paid

Part 3 of Form GSTR 9C consists of reconciliation of the tax payable as per declaration in the reconciliation statement and the actual tax paid as declared in the Annual Return i.e. Form GSTR 9.

Part 3 of Form GSTR 9C comprises of the following tables:

Table No.Details
9The table provides for reconciliation of tax paid as per reconciliation statement and amount of tax paid as declared in Form GSTR 9. Under the head labelled “RC”, supplies where tax was paid on reverse charge basis by the recipient (i.e. the person for whom reconciliation statement has been prepared) shall be declared.
9PThe total amount to be paid as per liability declared in Tables 9A to 9O is auto populated here.
9QThe amount payable as declared in Table 9 of Form GSTR 9 shall be declared here. It should also contain any differential tax paid on Table 10 or 11 of Form GSTR 9.
10Reasons for non-reconciliation between payable / liability declared in Table 9P above and the amount payable in Table 9Q shall be specified here.
11Any amount which is payable due to reasons specified under Tables 6, 8 and 10 above shall be declared here.

Part 4: Reconciliation of Input Tax Credit (ITC)

Part 4 of Form GSTR 9C consists of reconciliation of ITC and comprises of the following tables:

Table No.Details
12AITC availed (after reversals) 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 or entities with presence over multiple States. Such persons or 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 reference to books of accounts in case of persons or entities having presence over multiple states.
12BAny ITC which was booked in the audited Annual Financial Statement of 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.
12CAny 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.
12DITC availed as per audited Annual Financial Statement or books of accounts as derived from values declared in Tables 12A, 12B and 12C above will be auto-populated here.
12ENet ITC available for utilization as declared in Table 7J of Form GSTR 9 shall be declared here.
13Reasons for non-reconciliation of ITC as per audited Annual Financial Statement or books of account (Table 12D) and the net ITC (Table 12E) availed in Form GSTR 9 shall be specified here.
14This table is for reconciliation of ITC declared in Form GSTR 9 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 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.
14RTotal ITC declared in Tables 14A to 14Q above shall be auto populated here.
14SNet ITC availed as declared in Form GSTR 9 shall be declared here. Table 7J of Form GSTR 9 may be used for filing this table.
15Reasons for non-reconciliation between ITC availed on the various expenses declared in Table 14R and ITC declared in Table 14S shall be specified here.
16Any amount which is payable due to reasons specified in Table 13 and 15 above shall be declared here.

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

Part 5 of Form GSTR 9C, 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 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 is recommended to be settled by the auditor shall be declared in this table.

Part 5 of Form GSTR 9C requires you to fill the liability details across the following heads:

  • 5%
  • 12%
  • 18%
  • 28%
  • 3%
  • 25%
  • 10%
  • Input Tax Credit
  • Interest
  • Late Fee
  • Penalty
  • Any other amount paid for supplies not included in Form GSTR 9
  • Erroneous refund to be paid back
  • Outstanding demands to be settled
  • Other (Please Specify)

We hope that our blogs on the final formats of Form GSTR 9, 9A & 9C will be useful to you while filing your Annual Returns. Keep watching this space on further updates on GST.

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Pramit Pratim Ghosh

Author: Pramit Pratim Ghosh

Pramit, who has been with Tally since May 2012, is an integral part of the digital content team. As a member of Tally’s GST centre of excellence, he has written blogs on GST law, impact and opinions - for customer, tax practitioner and student audiences, as well as on generic themes such as - automation, accounting, inventory, business efficiency - for business owners.