InsightsGSTGSTR-9 vs GSTR-9C: which applies to you
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GSTR-9 vs GSTR-9C: which applies to you

CA Sitaram PareekLast reviewed June 20266 min read

GSTR-9 is the GST annual return summarising the year's supplies, ITC and tax; GSTR-9C is a self-certified reconciliation statement linking GSTR-9 to the audited annual financial statements. GSTR-9 is optional below Rs.2 crore turnover; GSTR-9C is required above Rs.5 crore. Both are due by 31 December following the financial year.

What each form is

GSTR-9 (Section 44, Rule 80) consolidates the monthly/quarterly returns of a financial year — outward and inward supplies, ITC claimed and reversed, tax paid, and demands/refunds — into a single annual return per GSTIN.

GSTR-9C is a reconciliation statement that matches the turnover, tax paid and ITC in GSTR-9 with the figures in the audited financial statements, explaining any differences. Since FY 2020-21 it is self-certified by the taxpayer (the earlier requirement of certification by a CA/CMA was removed).

Turnover thresholds

Aggregate annual turnoverGSTR-9GSTR-9C
Up to Rs.2 croreOptional (exempt)Not required
Rs.2 crore to Rs.5 croreMandatoryNot required
Above Rs.5 croreMandatoryMandatory (self-certified)

Thresholds are based on aggregate turnover (PAN-level, all-India). Verify the threshold notified for the specific financial year, as the exemption limit has been varied by annual notifications.

Due date and late fee

Both GSTR-9 and GSTR-9C are due by 31 December following the end of the financial year (for example, 31 December 2026 for FY 2025-26). Late filing of GSTR-9 attracts late fee under Section 47 at Rs.200 per day (Rs.100 CGST + Rs.100 SGST), subject to a turnover-based cap rationalised by Notification 07/2023-CT.

Practical points for finance teams

  • GSTR-9 is largely auto-populated from GSTR-1 and GSTR-3B but must be reconciled to books before filing — differences cannot be corrected after submission.
  • Additional liability identified in GSTR-9/9C can be paid through Form DRC-03, but additional ITC cannot be claimed in the annual return.
  • Even though GSTR-9C is self-certified, the reconciliation should be supported by a working that a reviewer or department can follow.
  • Keep the turnover computation (aggregate, PAN-level) documented to evidence why 9C was or was not filed.

Key takeaways

  • GSTR-9 = annual return; GSTR-9C = reconciliation with audited accounts.
  • GSTR-9 optional up to Rs.2 crore; GSTR-9C mandatory above Rs.5 crore.
  • GSTR-9C is self-certified since FY 2020-21 (no CA certification).
  • Both due by 31 December; extra liability via DRC-03, no new ITC.

Frequently Asked Questions

Is GSTR-9C certified by a Chartered Accountant?

Not since FY 2020-21. GSTR-9C is now self-certified by the taxpayer; the earlier mandatory CA/CMA certification and GST audit under Section 35(5) were removed.

Can I claim additional ITC through GSTR-9?

No. The annual return cannot be used to claim ITC not already taken; additional tax liability can be paid via DRC-03, but missed credit generally cannot be recovered here.

What is the due date for GSTR-9 and 9C?

31 December following the end of the financial year, subject to any extension notified by the CBIC.

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Written & reviewed by

CA Sitaram Pareek

Chartered Accountant (ICAI) and holder of the Diploma in International Taxation (DIIT-ICAI). Works in-house with a multinational group operating across India, the UAE and Singapore, handling GST compliance, direct tax, transfer pricing, DTAA advisory and FEMA matters. Every article on NumberIQ is written against the bare Act, current CBDT/CBIC notifications and official portals (incometax.gov.in, gst.gov.in, cbic.gov.in).

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