GSTR-9C: Reconciliation Statement (Self-Certified, ₹5 Cr Threshold)

What is GSTR-9C?

GSTR-9C is the Reconciliation Statement filed by GST taxpayers with aggregate turnover above ₹5 crore. It reconciles:

• Turnover declared in GST returns (GSTR-9) with turnover as per audited Annual Financial Statements
• Tax paid as per GST returns with tax liability as per books
• ITC claimed with ITC available as per books
• Differences with reasons (justified or unjustified)

Major changes from FY 2020-21: GSTR-9C is now SELF-CERTIFIED by the taxpayer, not CA/CMA audited (as was earlier required under Section 35(5)).

Applicability threshold

• Aggregate turnover > ₹5 crore in any FY — GSTR-9C mandatory for that FY
• Below ₹5 cr — Not required
• If turnover crosses ₹5 cr threshold during the year — applicable from that FY
• Exemption: Same exemptions as GSTR-9 (composition, casual, ISD, etc.)

'Aggregate turnover' is PAN-level (combined across all GSTINs), not state-wise.

Key reconciliations required

Part II — Reconciliation of Turnover:

• Gross turnover as per audited financial statements
• Add: Unbilled revenue (if recognised in AS-9 but not invoiced)
• Less: Unadjusted advances and excise duty
• = Adjusted turnover
• Reconcile to turnover declared in GSTR-9

Part III — Reconciliation of Tax Paid:

• Tax liability as per books
• Add/Less: Differences (RCM tax, ITC reversed, etc.)
• Reconcile to tax declared in GSTR-9

Part IV — Reconciliation of ITC:

• ITC as per books
• Less: Blocked ITC under Section 17(5)
• Reconcile to ITC in GSTR-9

Due date and penalty

Due date: 31 December of next FY (same as GSTR-9)

For FY 2025-26: Due 31 December 2026.

Late filing fees: Same as GSTR-9 (₹200/day capped at 0.5% turnover). Plus increased risk of departmental scrutiny.

Practical reconciliation tips

1. Start early — Reconciliation takes 1-2 months for medium-sized businesses. Don't wait till December.
2. Tally accounting software with GST portal — Use software's GST reports vs GST portal downloads.
3. Identify timing differences — Sales invoiced in March but GST paid in April (next FY). Document properly.
4. RCM transactions — Ensure all are reported. RCM is a common reconciliation gap.
5. Credit notes — Ensure correct year and tax adjustments.
6. Consult CA for complex items — Even though self-certified, CA review catches errors. Cost ₹15,000-50,000 for review.