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GSTR 9 Vs GSTR 9C, which one should You Prepare this Year?

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Since the day annual return filing has been announced in GST lobby, the taxpayers are perplexed on the applicability of the form type to them. Should they be filing GSTR 9 or GSTR 9 C or both? And who is to file what?

This blog throws light on the base logic behind the two forms and helps you decide which one is for you.

To start with, annual return is a statement of return which is required to be filed annually by each registered person (except few specified categories of persons) under GST giving summarized details of outward supply and taxes paid thereon, input tax credits claimed, taxes paid and refund claimed in the financial year in respect of which such monthly/quarterly returns are filed. This annual return has to be filed with the GSTN using form GSTR 9.

Now the GSTR 9 in itself is categorized in various form types based on taxpayer entities.

Sr. No. Annual Return Applicability to Taxpayers
1 GSTR 9 All taxpayers other than mentioned below in note 1
2 GSTR 9A Taxpayer who applies for composition scheme
3 GSTR 9B Tax collector who files GSTR 8. Read Note 2 mentioned
4 GSTR 9C Taxpayer who’s aggregate turnover exceeds 2 cr. and need to audit his accounts under GST

  • Note 1 – Following taxpayers do not need to file GSTR 9
    • Casual Taxable Person
    • Non-Resident Taxable Person
    • Input Service Distributor
    • Composition Dealers
    • Persons subject to TCS or TDS provision
  • Note 2 – GSTR 9B is not applicable for Financial year 2017-2018 because GSTR 8 got applicable from 1st Oct 2018.

As 9A is a completely different category to be used by taxpayers in composite scheme and 9B not applicable this year, let’s have a brief comparison of GSTR 9 and GSTR 9C, their formats, applicability and variation in form types.

While GSTR 9 is an annual return form filing, GSTR 9C is essentially a reconciliation statement to be prepared by taxpayers whose aggregate turnover exceeds Rs. 2 crore and have undergone GST audit. Such businesses have to file their CA certified audited financial statements along with GSTR 9C. So, ideally, GSTR 9C is dependent on preparation of your GSTR 9 return.

Additional point to note here is that there are no revision provisions for the annual return yet. Hence, the return should be prepared with complete accuracy. IRISGST, a robust GST filing platform is now equipped with GSTR 9 filing utility. With IRISGST you can easily bulk-fetch auto-drafted details from GSTN servers, compare auto-drafted details using GSTR 1 and 3B and your ledgers, review table-wise GSTR 9 data  and get exhaustive reports based on GST returns and reconciliation results to prepare the data for additional sections of GSTR 9. For more details and/or schedule demo, please visit https://irisgst.com/gstr9/

Let us now see some basic difference between the two forms:

Key Points GSTR-9 Annual Return GSTR-9C Reconciliation Statement
Nature It is compilation /consolidation of all details provided in GST returns i.e. GSTR 1 and GSTR 3B made during financial year 2017-2018. It is reconciliation between annual GSTR 9 return filed and audited annual financial statements
Applicable to As per Legal provision of Section 44(1) of CGST Act, every registered person shall be required to file GSTR-9. Hence, irrespective of the Turnover, every registered person under GST is required to file GSTR-9. Every registered person, whose aggregate turnover during a financial year exceeds the prescribed limit of Rs. 2 Crore, shall get his accounts audited by a chartered accountant or a cost accountant and need to file GSTR 9C.
Not applicable to
  • Casual Taxable Person
  • Non-Resident Taxable Person
  • Input Service Distributor
  • Input Service Distributor
  • Composition Dealers
  • Those who are not applicable to file GSTR-9
  • And also a registered person whose aggregate turnover in an FY is less than INR 2 Cr.
Due date for filing
  • 31st December of the subsequent financial year
    E.g. 31st December 2018 for FY 2017-18
  • This due date extended till 30th June 2019 (Order No.03/2018-Central tax)
  • 31st December of the subsequent financial year
  • E.g. 31st December 2018 with or after filing GSTR-9 for FY 2017-18
  • This due date extended till 30th June 2019 (Order No.03/2018-Central tax)
Late fees &
  • As per section 47(2) of CGST Act, Late fee for belated filing of GSTR-9 is Rs.100 per day
In a situation where a registered person files only GSTR 9, but fails to file GSTR 9C, the filing of GSTR 9C is not considered to
penalty subject to maximum of 0.25% of turnover in a state/UT. Similar provision is there in SGST Act also.

  • Hence, in total there will be late fee of Rs.200 per day subject to 0.50% of turnover in a state on late filing of GSTR-9.
have been defaulted. However, For GSTR 9C there may be consequences of default in complying with the provisions of Section 44(2).
Additional Tax liability Additional liability for the FY 2017-18 not declared in FORM GSTR-1 and FORM GSTR-3B may be declared in this return. (As per Notification 74/2018 dt 31/12/2018 ) In GSTR 9C, GST auditor need to mention additional tax liability arise and it’s reasons of arise.
Payment of additional Tax liability
  • Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ?Annual Return? in the drop down provided in FORM DRC-03.
  • It may be noted that such liability can be paid through electronic cash ledger only (As per notification 74/2018 dt 31-12-2018)
  • Towards the end of the return, taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select ?reconciliation statement in the drop down provided in FORM DRC-03.
  • It may be noted that such liability can be paid through electronic cash ledger only (As per notification 74/2018 dt 31-12-2018)
Availed ITC Taxpayers cannot claim input tax credit unclaimed during FY 2017-18 through this return. ITC cannot be availed through GSTR 9C
Details need to provide in Return
  • Details of the outward supplies, inward supplies on which tax is payable, ITC and tax paid, late fees as per the GST returns filed between July 2017 and March 2018
  • Along with its amendments made between April 2018 and September 2018.
  • Declaration of demands/ refunds, supplies from composition dealers, Job works, goods sent on an approval basis
  • HSN wise summary of outward Supplies
  • HSN summary for inward supplies. Here for inward supplies need to consider only which in value independently account for 10% or more of total value of inward supplies (As per notification no 74/2018 dt 31/12/2018)
  • • Late fees payable is required.

  • Part-A -Reporting of reconciliation needed between turnover, tax paid and ITC.
  • Report on Auditor’s recommendation of any additional tax liability.
  • Part -B -Certificate by GST Auditor/ CA/ CMA
Return Mandatory
  • It is mandatory to file all your FORM GSTR-1 and FORM GSTR-3B for the FY 2017- 18 before filing this GSTR 9 return.
  • The details for the period from July 2017 to March 2018 are needed to be provided in this return.
GSTR 9 is mandatory to file before filing of GSTR 9C
Annexures No annexures to be attached Annexure of Audited financial statement is required


Also recently 31st GST council Meeting was held on 22 December 2018. To know the highlights of meeting click here.

IRIS Business is a leading GST Suvidha Provider (GSP) providing easy and efficient solutions for GST (IRIS Sapphire) and E-way bill (IRIS Topaz) compliance. To have your GSTR-9 queries solved and to know more about our solution for filing GSTR-9, please contact us at support@irisgst.com

About Ashwini Gorhe

Ashwini Gorhe, a Chartered Accountant, is associated with IRIS as a Financial Analyst. She has around 6 years of experience in compliance space which includes XBRL reporting, GST and Data analysis. She is actively involved in the IRIS Sapphire (GST filing solution) and IRIS Topaz (E-way bill solution) product development. Before GST, she was handling US compliance analyzing US financial statements and reviewing XBRL filings for US and India market.

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