UNDERSTANDING GSTR 9C: ELIGIBILITY, DUE DATE & TURNOVER CRITERIA

INTRODUCTION

GSTR 9C is a crucial compliance form under the Goods and Services Tax (GST) regime in India. It is a reconciliation statement filed annually by taxpayers whose turnover exceeds a specified limit. This form reconciles the details declared in GSTR-9 (Annual Return) with the audited financial statements of the taxpayer for the relevant financial year.

The form is essentially a self-certified statement (or certified by a Chartered Accountant or Cost Accountant for earlier years), highlighting any differences between GST filings and books of accounts. Its purpose is to ensure consistency, accuracy, and accountability in GST reporting.

With TMWala, businesses can track turnover thresholds across multiple GSTINs and prepare for GSTR-9C well before the deadline, minimizing last-minute compliance stress.

GSTR 9C ELIGIBILITY

GSTR-9C must be filed by every registered taxpayer whose turnover in a fiscal year exceeds ₹5 crore. This eligibility criterion is determined based on aggregate turnover, calculated PAN-wise, across all registrations held by a person throughout India.

Aggregate turnover includes:

• Taxable supplies (excluding reverse charge supplies)
• Exempt supplies
• Exports of goods or services
• Inter-State supplies

It excludes GST tax components like CGST, SGST, IGST, UTGST, and cess. If your aggregate turnover crosses ₹5 crore in a financial year, you are eligible and obligated to file GSTR-9C for each GSTIN you hold.

GSTR 9C APPLICABILITY

GSTR 9C reconciles the numbers from a taxpayer’s audited financial report with the GSTR annual returns for a fiscal year. It was introduced on 13th September 2018 as part of the government’s drive for transparent tax compliance. Filing GSTR-9C ensures discrepancies between GST returns and financial records are explained and corrected.

According to CBIC Notification No. 30/2021 dated July 30, 2021, and Rule 80 of the CGST Rules, registered persons under GST whose total turnover exceeds ₹5 crore in a fiscal year are required to file GSTR-9C. Read the Notice here: notfctn-30-central-tax-english-2021.pdf

Exceptions to applicability include:

• International airlines that adhere to the 2013 Companies Act (CBIC Notification No. 09/2020)

• Non-resident taxpayers providing OIDAR services to unregistered individuals in India (CBIC Notification No. 30/2019)

TMWala helps in identifying exemptions and eligibility based on your business profile, saving time and ensuring only applicable forms are filed.

GSTR 9C DUE DATE

The due date for filing GSTR-9C is on or before 31st December of the subsequent financial year. This is the same as the deadline for filing the GSTR-9 (Annual Return).

For instance, for the financial year 2023–24, the deadline to file GSTR-9C is 31st December 2024, unless an extension is notified by the government.

Delays in filing may attract penalties, so businesses are encouraged to stay proactive in maintaining their compliance calendar.

GSTR 9C TURNOVER LIMIT

The GSTR-9C turnover limit has been raised to Rs. 5 crore for FY 2018-19, FY 2019-20, FY 2020-21, FY 2021-22, and FY 2022-23, based on CBIC notifications. This means only those businesses with an annual aggregate turnover above ₹5 crore in a financial year are required to submit this form.

The turnover threshold is PAN-based, so even if individual GSTINs have lower turnovers, all GST registrations under a PAN must file GSTR-9C if the combined turnover exceeds ₹5 crore.

WHO SHOULD FILE GSTR 9C

To restate the requirement, GSTR-9C must be filed by each registered taxpayer whose turnover exceeds ₹5 crore in a fiscal year.

This includes:

• Businesses and service providers
• Professionals or consultants registered under GST
• E-commerce operators
• Any entity with multiple GST registrations under a single PAN, provided aggregate turnover exceeds ₹5 crore

Each GSTIN must file a separate GSTR-9C return, regardless of individual turnover, if the overall PAN-based turnover crosses the threshold.

GST ANNUAL RETURN FILING

The GSTR-9C form is a crucial part of the GST annual return filing process for businesses in India. It supports and supplements GSTR-9, which is a comprehensive summary of:

• Outward and inward supplies
• Tax liability
• Tax payments made
• Input tax credits claimed and utilized

While GSTR-9 provides data, GSTR-9C reconciles it with the financial records, helping the authorities verify that the taxpayer’s compliance aligns with audited books of accounts.

DIFFERENCE BETWEEN GSTR 9 AND 9C

Although GSTR-9 and GSTR-9C are often filed together, they serve different purposes:

• GSTR-9: This is the annual summary return, covering all GST transactions throughout the year, both inward and outward supplies.
• GSTR-9C: This is a reconciliation statement, which compares figures from GSTR-9 with the audited financials of the entity. It highlights discrepancies and requires explanation for any mismatches.

In short, GSTR-9 is data-driven, while GSTR-9C is audit- and compliance-driven.

Tools like TMWala’s real-time reconciliation dashboard make this verification process seamless, helping businesses avoid mismatches and audit red flags.

GST AUDIT LIMIT IN INDIA

As of 2025, the GST audit limit in India is structured as follows:

• GSTR-9 is mandatory for businesses with an annual turnover exceeding ₹2 crore.
• GSTR-9C is mandatory for businesses with an annual turnover exceeding ₹5 crore.

The audit requirement stems from Section 35(5) of the CGST Act, which mandates reconciliation of GST returns with financial accounts for high-turnover taxpayers.

DOCUMENTS REQUIRED FOR GSTR 9C

Filing GSTR-9C involves uploading a few essential documents to validate the reconciliation. These include:

1. Audited Financial Statements:
   • Balance Sheet
   • Profit & Loss Account
   • Cash Flow Statement (if applicable)
2. Audit Report:
   • If audited under another law like the Companies Act or Income Tax Act, the respective audit report should also be enclosed.

These records aid in verifying the stated figures and offer clarity throughout the reconciliation procedure.

HOW TO FILE GSTR 9C ONLINE STEP BY STEP

Filing GSTR-9C on the GST Portal can be done by following these simple steps:

Step 1: Log in to the GST Portal

Go to www.gst.gov.in and enter your GSTIN and password to log in.

Step 2: Access the ‘Annual Return’ Section

From the dashboard, navigate to Services > Returns > Annual Return.

Step 3: Select Financial Year

Select the fiscal year that you are submitting your GSTR-9C.

Step 4: File GSTR-9 First

Make sure you have successfully filed GSTR-9 before proceeding. GSTR-9C cannot be filed without it.

Step 5: Select GSTR-9C Form

Click on GSTR-9C and begin filling in the reconciliation details, such as:

• Gross turnover
• Tax paid and payable
• Differences, if any, with explanations

Step 6: Upload Required Documents

Attach audited financial statements and audit reports. Ensure all documents are self-certified or digitally signed as required.

Step 7: Verify and Submit

Review the data carefully, verify using DSC or EVC, and submit the form.

Step 8: Save the Acknowledgment

Download and save the Acknowledgment Receipt for your records. It acts as proof of successful submission.

TMWala guides users through each filing step with checklists and prompts, reducing the risk of error or oversight during portal navigation.

CONCLUSION

GSTR-9C plays a pivotal role in India’s GST compliance system. With strict rules around eligibility, applicability, and turnover thresholds, taxpayers need to stay updated and ensure accurate reconciliation each year. Whether you handle your taxes or work with a GST practitioner, understanding GSTR-9C requirements can help you stay on the right side of compliance and avoid penalties or audit triggers down the road.