Understand the key differences between GSTR-9 and GSTR-9C, including filing rules, due dates, and penalties to ensure GST compliance.
Since the introduction of GSTR-9 and GSTR-9C forms by the CBIC, taxpayers have frequently encountered uncertainty regarding their filing obligations and the data requirements for each. This article aims to clarify these points by offering a concise comparison between GSTR-9 and GSTR-9C.
Comparison Table for GSTR-9 and GSTR-9C
| Comparison Aspect | GSTR-9: Yearly Return | GSTR-9C: Reconciliation Report |
|---|---|---|
| Nature | Provides comprehensive information; a summary of all GST returns filed. | An analytical report on GST returns that requires self-certification by the Chief Financial Officer (CFO) or Finance Head. |
| Who must file | Any GST-registered taxpayer. | GST-registered taxpayers with an aggregate annual turnover exceeding Rs 5 crore. |
| Not applicable to | – Dealers under the composition scheme- Casual taxable individuals (CTP)- Non-resident taxable individuals (NRTP)- Input Service Distributors (ISD)- Holders of Unique Identification Numbers (UIN)- Providers of Online Information and Database Access Retrieval (OIDAR) services- Entities subject to Tax Collected at Source (TCS) or Tax Deducted at Source (TDS) provisions. | Individuals listed under the GSTR-9 column, along with registered persons whose aggregate turnover for a financial year is below Rs. 5 crore. |
| Optional for | Optional for businesses with an annual turnover under Rs 2 crore (effective from FY 2017-18). | Optional for businesses with an annual turnover under Rs 5 crore. |
| Due date for filing* | December 31st of the subsequent financial year*. | December 31st of the subsequent financial year, to be filed concurrently with or subsequent to GSTR-9*. |
| Late fees & penalty | Applicable from Financial Year 2022-23 onwards: | |
| 1. For businesses with a turnover up to Rs 5 crore: A fee of Rs 50 (Rs 25 each for CGST and SGST Acts). The maximum late fee is capped at 0.04% of the state/UT turnover (0.02% each for CGST and SGST Acts). | ||
| 2. For businesses with a turnover exceeding Rs 5 crore but less than Rs 20 crore: A fee of Rs 100 (Rs 50 each for CGST and SGST Acts). The maximum late fee is capped at 0.04% of the state/UT turnover (0.02% each for CGST and SGST Acts). | ||
| 3. For businesses with a turnover exceeding Rs 20 crore: A fee of Rs 200 (Rs 100 each for CGST and SGST Acts). The maximum late fee is capped at 0.50% of the state/UT turnover (0.25% each for CGST and SGST Acts). | There are no specific provisions for GSTR-9C late fees; therefore, a general penalty of Rs 25,000 applies. | |
| Filing of the return | Submitted via the official GST portal or a designated facilitation centre. | Submitted via the official GST portal or a designated facilitation centre, either concurrently with or following the GSTR-9 filing. |
| Format of the return | A consolidated summary of the following details: | |
| – Turnover | ||
| – Input Tax Credit (ITC) and taxes paid | ||
| – Late fees settled for GST returns filed during the financial year | ||
| – Amendments made between April and November 30th of the subsequent financial year. |
Additionally, where relevant, the following details must be declared:
– Demands or refunds
– Supplies received from composition dealers
– Job work activities
– Goods dispatched on an approval basis
– Harmonized System of Nomenclature (HSN) wise summary of sales and purchases
– Any late fees due. | Part A outlines the reconciliation required for turnover, taxes paid, and Input Tax Credit (ITC). It also includes a report on the auditor’s recommendation for any additional tax liabilities. Part B involves self-certification by the Chief Financial Officer (CFO) or Finance Head. |
| Who must certify/ attest | Certification by a Chartered Accountant (CA) or Cost and Management Accountant (CMA) is not mandatory; however, the taxpayer must attest it with a digital signature. | The Chief Financial Officer (CFO) or Finance Head is required to certify this document using a digital signature. |
| Annexures | No annexures are required to be attached. | An annexure containing the audited financial statement is mandatory. |
The Budget 2023 introduced an amendment restricting taxpayers from filing GSTR-9 more than three years after its original due date has expired. This amendment is awaiting notification by the CBIC.
*These dates are subject to any extensions notified by the CBIC.
For late fees applicable up to FY 2021-22: A daily late fee of Rs 200 was imposed, with a maximum limit set at 0.50% (0.25% each under CGST and SGST) of the total turnover within the respective State/Union Territory, applicable until March 31, 2023.
Through notification 07/2023 dated March 31, 2023, the CBIC announced a waiver of late fees exceeding Rs 20,000 (Rs 10,000 each under CGST and SGST laws) for delayed GSTR-9 filings pertaining to the financial years 2017-18 through 2021-22, provided they were filed between April 1, 2023, and June 30, 2023.
