Published 11 October 2026
GSTR-9C is the one GST form that starts from the audited accounts rather than from the returns. That changes who prepares it. The figures in GSTR-9 come out of the portal. The figures in GSTR-9C come out of the balance sheet and the profit and loss account, adjusted line by line until they meet the returns. Since 2025 a further point has been settled. A late GSTR-9C keeps the late fee on the annual return running, even where GSTR-9 itself was filed on time.
The purpose of the reconciliation, and the kinds of difference it usually explains, are discussed in The Annual Return and Reconciliation Statement. This guide covers the filing.
Who must file it
Section 44(1) says the annual return “may include a self-certified reconciliation statement”, reconciling the value of supplies in the returns “with the audited annual financial statement”. Rule 80(3) makes the statement compulsory for a person whose aggregate turnover during the financial year “exceeds five crore rupees”. It is filed in FORM GSTR-9C “along with the annual return”.
The rule excludes the same classes as GSTR-9:
- Government departments and local authorities under the second proviso to section 44
- Input Service Distributors
- persons deducting or collecting tax under sections 51 and 52
- casual taxable persons
- non-resident taxable persons
Two notifications add exclusions:
- OIDAR suppliers. Persons registered under rule 14 to supply online information and database access or retrieval services from outside India are excused from both GSTR-9 and GSTR-9C (Notification No. 30/2019-Central Tax).
- Foreign airlines. Foreign airline companies that meet the conditions of Notification No. 09/2020-Central Tax are excused from GSTR-9C. Each GSTIN must instead submit, by 30 September after the year, a statement of receipts and payments for its Indian operations authenticated by a practising chartered accountant.
The threshold is measured on aggregate turnover, which section 2(6) computes for all registrations under one PAN across India. The statement itself is filed for each GSTIN: instruction 2 to the form says it “is to be filed for every GSTIN separately”. A registration with modest turnover of its own therefore files GSTR-9C if the PAN’s turnover exceeds Rs 5 crore.
What changed in 2021
The threshold and the certification have changed over the years:
| Financial year | Who filed GSTR-9C | Certified by |
|---|---|---|
| 2017-18 | Persons with aggregate turnover above Rs 2 crore, whose accounts were audited under section 35(5) | The auditor |
| 2018-19, 2019-20 | Above Rs 5 crore (proviso to the old rule 80(3)) | The auditor |
| 2020-21 onwards | Above Rs 5 crore | The registered person (self-certified) |
The Finance Act, 2021 omitted the audit requirement in section 35(5) and substituted section 44. Notification No. 29/2021-Central Tax brought both changes into force on 1 August 2021. Notification No. 30/2021-Central Tax amended the form from the same date:
- Part B, the auditor’s certificate, was omitted
- Part V lost its heading “Auditor’s recommendation”
- the verification now reads: “I am uploading this self-certified reconciliation statement in FORM GSTR-9C”
The portal’s own guidance has not fully caught up. Its GSTR-9C manual, the offline-utility guide last updated on 27 January 2020, notes that Part B “will not be available from financial year 2020-2021”. But its GSTR-9 FAQ still says GSTR-9C filers must have their accounts audited by a chartered or cost accountant. The rule and the form now require neither. A person may still need an audit under the Companies Act or the Income-tax Act, and Table 4 of the form asks: “Are you liable to audit under any Act?”
What to have ready
| Item | Where it comes from |
|---|---|
| GSTR-9 for the year, filed | Portal. The GSTR-9C tile opens only after GSTR-9 is filed (the portal’s GSTR-9C manual) |
| Audited balance sheet and profit and loss account (or income and expenditure account) | Books. The manual makes uploading both a condition for filing |
| GSTIN-wise turnover and credit, where one PAN has several registrations | Books, derived internally (instructions to Tables 5A and 12A) |
| Unbilled revenue and unadjusted advances at the start and end of the year | Books |
| Credit notes issued after 31 March but shown in GSTR-9; trade discounts and credit notes not admissible under section 34 | Books, and GSTR-9 Tables 4 and 5 |
| Schedule I supplies (for example, between distinct persons) not in book turnover | Books |
| Rate-wise taxable value and tax, including reverse charge | Books, and GSTR-9 Tables 4, 9, 10 and 11 |
| Expense-wise credit (purchases, freight, rent, capital goods and so on) | Books, and GSTR-9 Table 7J |
The form, part by part
Part I (Tables 1 to 4) holds the year, the GSTIN and names, and the question whether the person is liable to audit under any Act.
Part II reconciles turnover.
- Table 5 starts from turnover in the audited financial statements for the State (5A). It adjusts for unbilled revenue at the start and end of the year, advances, deemed supplies under Schedule I, credit notes after the year end, inadmissible trade discounts and credit notes, SEZ-to-DTA supplies, turnover under the composition scheme, valuation differences under section 15, and foreign exchange differences. The result (5P) is compared with turnover in GSTR-9 (5Q), and any gap is shown in 5R.
- Table 6 gives the reasons for that gap.
- Table 7 derives taxable turnover by removing exempt, nil-rated, non-GST and no-supply turnover, zero-rated supplies without tax, and reverse-charge supplies. Row 7D1 is new: supplies on which an e-commerce operator pays tax under section 9(5), reported by the supplier.
- Table 8 gives the reasons for any difference in taxable turnover.
Part III reconciles tax.
- Table 9 lists liability rate by rate: 5, 6, 12, 18, 28, 3, 0.25 and 0.10 per cent, each with a reverse-charge row, plus “Others” (K-1). Row K-2 is new: supplies on which an e-commerce operator must pay tax under section 9(5), reported by the operator. Interest, late fee and penalty follow. The total (9P) is compared with tax payable in GSTR-9 (9Q).
- Table 10 gives the reasons for any difference.
- Table 11 shows additional tax payable that was not paid.
Part IV reconciles input tax credit.
- Table 12 starts from credit in the audited statements (12A), adjusts for credit booked in an earlier year (12B) or not yet credited to the ledger (12C), and compares the result with net credit in GSTR-9 Table 7J.
- Table 14 reconciles credit expense head by expense head.
- Tables 13 and 15 give the reasons for any difference.
- Table 16 shows the tax payable on that difference.
Part V sets out the additional liability arising from non-reconciliation, any erroneous refund to be paid back, and outstanding demands to be settled.
Table 17, “Late fee payable and paid”, was inserted by Notification No. 13/2025-Central Tax from 22 September 2025. Its instruction reads: “Late fee will be payable as per section 47(2)”.
Tables that may be left out
The instructions let the filer leave out certain rows for named years.
- Table 5, rows 5B to 5N. These may be left blank, with adjustments reported in 5O. The option was extended year by year. Notification No. 12/2024-Central Tax took it to 2023-24, and No. 13/2025-Central Tax to 2024-25.
- Table 14, the expense-wise credit reconciliation, is optional on the same footing up to 2024-25.
The consolidated GSTR-9C on the CBIC website still shows the Table 5 option for 2017-18 to 2019-20 only. It has not picked up those later substitutions. As with GSTR-9, no notification up to 11 October 2026 extends either option to 2025-26.
Portal steps
The portal’s GSTR-9C manual describes a JSON prepared in the GSTN’s offline tool, uploaded on the GSTR-9C tile and then filed. The sequence it gives, with the auditor’s steps removed, is:
- After GSTR-9 is filed, the filer downloads the filed GSTR-9 and the GSTR-9C tables that the portal derives from it.
- The statement is prepared in the GSTR-9C offline tool (Downloads > Offline Tools), and a JSON file is generated. The manual describes the JSON as signed with a DSC in the tool. In 2020 that DSC was the auditor’s.
- The JSON is uploaded on the GSTR-9C tile. If it is processed with errors, the portal provides an error report for correction.
- The balance sheet and the profit and loss or income and expenditure statement are uploaded in PDF or JPEG. The manual says PROCEED TO FILE is enabled only after the signed JSON and these two statements are uploaded.
- Once the portal shows “Ready to file”, the filer completes the verification, selects the authorised signatory and files with DSC or EVC. The portal issues an ARN.
The manual predates self-certification, and some screens may have changed. The sequence above is limited to what survives the 2021 changes.
Paying what the reconciliation finds
Any amount shown as payable in Tables 11, 16 or Part V is paid through FORM GST DRC-03, with “Reconciliation Statement” chosen from the drop-down (instruction 8). Since 22 September 2025, instruction 8 allows payment from the cash ledger “or electronic credit ledger”. Before then it said cash ledger only. Interest under section 50 is paid in cash.
Signing
Rule 26 allows a DSC, an e-signature or a notified mode such as EVC. Rule 26(2) says who signs for each kind of person. The verification is the registered person’s own declaration: no accountant signs the statement.
Due date and late fee
GSTR-9C is due with GSTR-9, by 31 December after the year (rule 80(3)). The return for 2025-26 is due by 31 December 2026. The three-year bar in section 44(2) applies to the annual return as a whole, and the portal lists “GSTR 9/9C” among the barred forms. See Late Returns.
The late fee is the one under section 47(2), at the reduced rates in Notification No. 07/2023-Central Tax. They are set out in Filing the Annual Return, GSTR-9.
Circular No. 246/03/2025-GST (30 January 2025) settled how the fee applies to GSTR-9C. Where GSTR-9C is required, “the annual return under section 44 of the CGST Act consists of the return in FORM GSTR-9 along with a reconciliation statement in FORM GSTR-9C”. The fee is not charged twice. It runs from the due date until “the date of furnishing of FORM GSTR-9C, if FORM GSTR-9C is furnished subsequent to furnishing of FORM GSTR-9”.
For 2017-18 to 2022-23, Notification No. 08/2025-Central Tax waived the extra fee where a late GSTR-9C was filed by 31 March 2025. The fee was limited to what was payable up to the date of GSTR-9, and fees already paid were not refunded. For 2023-24 onwards there is no such waiver.
After filing
The manual is explicit: “Form GSTR-9C once filed cannot be revised.” Changes are possible only until filing. An error found later can be dealt with by paying tax through DRC-03, or explained when the department examines the year. The options are in Correcting Mistakes in Returns.
The procedure in order
- Check whether aggregate turnover across the PAN exceeded Rs 5 crore in the year, and whether an exclusion applies.
- Obtain the audited financial statements, and derive GSTIN-wise turnover and credit where there are several registrations.
- File GSTR-9 first. The GSTR-9C tile opens only after that.
- Reconcile turnover (Tables 5 to 8), tax (Tables 9 to 11) and credit (Tables 12 to 16), using row 7D1 or K-2 where section 9(5) supplies are involved, and the optional rows only for the years named.
- Prepare and sign the JSON, upload it with the balance sheet and profit and loss account, and file with DSC or EVC by 31 December.
- Pay any additional amount through DRC-03, choosing “Reconciliation Statement”.
- If filing late, expect the late fee on the annual return to run until GSTR-9C is filed, and record it in Table 17.
The next guide covers the final return, GSTR-10, due after a registration is cancelled.