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 1stOct 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||
|Due date for filing||
|Late fees &||
||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.
||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||
|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||
||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.
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