GSTR-9C
Meaning, Turnover Limit & Due Date
5 min readYour accounts say one thing about the year’s sales and your GST returns say another, and somebody has to explain the difference.
What Is GSTR-9C?
GSTR-9C is the reconciliation statement that matches the figures in your GST annual return (GSTR-9) with your audited annual accounts and explains every gap between the two. In India it is filed under section 44 of the CGST Act by a registered business whose aggregate turnover crossed Rs.5 crore in the financial year.
Where GSTR-9C sits Audited annual accounts GSTR-9 annual return GSTR-9C explains every gap GSTR-9C adds no new sales data. It compares two sets of figures you already have.Who Has to File GSTR-9C
Turnover decides it, and the bands are simple.
| Turnover | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to Rs.2 crore | Exempt | Not needed |
| Rs.2-5 crore | Yes | Not needed |
| Over Rs.5 crore | Yes | Yes |
What catches people off guard is how that turnover is counted. It is aggregate turnover across every GST registration under one PAN, all over India, so a restaurant chain with outlets in Telangana, Karnataka and Maharashtra adds all three together even when no single state comes anywhere near the limit on its own. But the statement itself is filed separately for each GSTIN.
Three more points sit behind the table:
- No CA signature is needed. Since the 2020-21 return the business certifies the statement itself.
- GSTR-9 comes first. The portal will not open the statement until the annual GST return is filed.
- Some file no annual return at all, such as casual taxable persons, non-resident taxable persons and input service distributors.
A company still needs its statutory audit, and a firm or proprietor its tax audit where one applies, because those accounts are one half of the comparison.
What GSTR-9C Contains
The form runs in five parts, and only two of them take real effort.
| Part | What it reconciles |
|---|---|
| Part I | Basic details: year, GSTIN, legal name |
| Part II | Turnover in the accounts against GSTR-9 |
| Part III | Tax paid against tax worked out on that turnover |
| Part IV | Input tax credit in the books against GSTR-9 |
| Part V | Extra tax owed on gaps left unexplained |
Parts II and IV are those two. Each asks for reasons, in writing, wherever the two figures part ways.
GSTR-9 vs GSTR-9C
The two travel together, and that is why they get confused.
| Aspect | GSTR-9 | GSTR-9C |
|---|---|---|
| Nature | Annual return | Reconciliation statement |
| Source | Your GSTR-1 and GSTR-3B | GSTR-9 and audited accounts |
| Who files | Above Rs.2 crore | Above Rs.5 crore |
| Due | 31 December | 31 December |
So the first is a summary of the year’s GSTR-1 and GSTR-3B filings, and the second tests that summary against the books.
GSTR-9C Example
An electrical goods distributor in Nizamabad sits down with the turnover part in mid-December 2026, after the 30 November window for correcting the year’s monthly returns has shut.
| Line | Detail | Figure |
|---|---|---|
| Books | Turnover in audited accounts | Rs.6,12,48,300 |
| GSTR-9 | Turnover in the annual return | Rs.6,10,06,800 |
| Gap | Books minus GSTR-9 | Rs.2,41,500 |
| Reason | One March invoice never uploaded | Rs.2,41,500 |
| GST due | 18% of the missed invoice | Rs.43,470 |
Note: this is an invented example for illustration only. The distributor and the figures are not real.
The annual return had already gone in without that invoice. So the gap is a real miss, and the distributor reports Rs.43,470 as extra liability and pays it through Form DRC-03, with interest on top.
Not every gap ends in tax. A sale of an old delivery van (GST paid, but not booked as sales in the accounts), or a discount given without a GST credit note, also makes the two figures differ, and for those the statement only needs the reason.
What a Late GSTR-9C Costs
For 2025-26 the due date is 31 December 2026, unless the government extends it, which it has done in some earlier years.
Filing GSTR-9 on time is not enough. CBIC Circular 246/03/2025 says the annual return is complete only when both forms are in, so the late fee keeps running until the day GSTR-9C is filed.
| Turnover | Late fee per day | Ceiling |
|---|---|---|
| Rs.5-20 crore | Rs.100 | 0.04% of turnover in the state |
| Over Rs.20 crore | Rs.200 | 0.5% of turnover in the state |
Each figure is the central and state halves added together, the lower band coming from Notification 07/2023. Our GSTR-9 annual return checklist lists what to gather first.
Check Your GST Reports Before GSTR-9C
Most gaps begin in a single month’s entries, long before the year closes. A clean monthly sales record does more for GSTR-9C than any December effort.
For retail businesses, Petpooja Invoice calculates GST on every invoice and produces GST reports for compliance and audit, with tax payable and input tax credit visible in real time.
For restaurants, Petpooja POSS reports day-end sales and online orders, and our guide on closing and reconciling the day-end report shows the daily habit behind it.
Pull the year’s sales report and put it beside your accountant’s figure this month.
Frequently Asked Questions
Is GSTR-9C mandatory for turnover below Rs.5 crore?
No. Rule 80(3) of the CGST Rules asks for it only when aggregate turnover in the financial year is above Rs.5 crore.
Does a chartered accountant have to certify GSTR-9C?
Not any more. From the 2020-21 return onwards the taxpayer certifies it, though many businesses still have their CA prepare it.
Is the Rs.5 crore limit counted per GSTIN or per PAN?
Per PAN. Add up the turnover of every registration under the PAN across India. If the total crosses Rs.5 crore, each GSTIN files its own statement.
What is the GSTR-9C due date for 2025-26?
31 December 2026, the same day as GSTR-9. Check the GST portal in December, since the date has been extended in some past years.
Can GSTR-9C be revised after filing?
The portal gives no option to revise it. Any tax found later is paid through Form DRC-03, so check the figures with your CA before you submit.
