Quick answer
Who has to file GSTR 9C, and when is it due?
GSTR 9C must be filed by every regular GST taxpayer whose aggregate turnover in the financial year exceeds ₹5 crore. It is a self-certified statement filed along with GSTR-9 by 31 December after the year ends, so the FY 2025-26 statement is due by 31 December 2026. No CA certification is required since 1 August 2021.
- Turnover above ₹5 crore: GSTR-9C is compulsory
- Self-certified by the taxpayer, not by a CA
- FY 2025-26 due date: 31 December 2026
- Late fee runs until 9C is filed, even if GSTR-9 is on time
- Rule 80(3) of the CGST Rules sets the limit
What is GSTR 9C and who needs to file it?
GSTR 9C is a reconciliation statement under section 44 of the CGST Act that ties the figures in your annual return to your audited accounts. Rule 80(3) makes it compulsory for registered persons whose aggregate turnover in the financial year exceeds ₹5 crore.
Aggregate turnover is counted on the PAN, across all states. So a Delhi company with ₹3.5 crore of sales from its Delhi GSTIN and ₹2 crore from a Haryana GSTIN crosses the limit, and each GSTIN files its own 9C. Input service distributors, TDS deductors, TCS collectors, casual taxable persons and non-resident taxable persons are outside the rule.
| Aggregate turnover in the year | GSTR-9 (annual return) | GSTR-9C (reconciliation) |
|---|---|---|
| Up to ₹2 crore | Exempt from FY 2024-25 onwards (Notification 15/2025-CT, reported) | Not required |
| Above ₹2 crore up to ₹5 crore | Required | Not required |
| Above ₹5 crore | Required | Required, self-certified |
| Composition taxpayer | Files GSTR-9A, not GSTR-9 | Not required |
Source: Rule 80, CGST Rules (CBIC), checked November 2026. The ₹2 crore exemption is taken from published copies of Notification 15/2025-CT dated 17 September 2025.
Is GSTR 9C still a CA-certified GST audit?
No. Until 31 July 2021, businesses above ₹2 crore had their accounts audited under section 35(5) and a chartered accountant or cost accountant certified the 9C. Finance Act 2021 removed section 35(5) from 1 August 2021, and the statement became self-certified by the taxpayer.
That change cut the cost but not the risk. The statement still goes to the department, the officer still compares it with your books, and a careless reconciliation is a common starting point for scrutiny. Most businesses above ₹5 crore still ask a CA to prepare and review it even though the CA no longer signs it. Our GST audit page explains how the department audit and special audit work today.
Need help with GSTR-9C reconciliation statement? Talk to a chartered accountant in Delhi today. First call is free.
What is reconciled in GSTR-9C?
GSTR-9C reconciles four things: turnover, taxable turnover, tax paid and input tax credit. For each, it starts from the audited financial statements, adjusts for timing and classification differences, and compares the result with GSTR-9. Any gap left unexplained becomes additional liability or a stated reason.
| Part | What it covers | Data you need |
|---|---|---|
| Part I | Basic details: GSTIN, year, legal name | Registration details |
| Part II | Turnover in the audited accounts compared with turnover declared in GSTR-9 | Trial balance, unbilled revenue, credit notes, branch transfers |
| Part III | Tax payable by rate compared with tax actually paid | Rate-wise sales register, GSTR-3B payments |
| Part IV | ITC in the books compared with ITC claimed in GSTR-9 | Purchase register, expense ledgers, GSTR-2B |
| Part V | Additional liability found during reconciliation | Working of unreconciled differences |
| Table 17 (new for FY 2024-25) | Late fee payable and paid | Auto-calculated by the portal |
Table 17 is described in the GSTN consolidated FAQ on GSTR-9/9C dated 17 December 2025. Part titles cross-checked with published guides.
Documents needed to prepare GSTR-9C
You need the audited financial statements, the filed GSTR-9 for the same GSTIN, and ledger-level detail that explains every difference between them. The audit report must be final before the reconciliation can be finished.
| Document | Why it is needed |
|---|---|
| Audited balance sheet, profit and loss account and notes | Starting point for turnover and ITC |
| GSTIN-wise trial balance if you have more than one state | Splits company turnover by registration |
| Sales and purchase registers with GST rate and HSN | Rate-wise tax reconciliation |
| Filed GSTR-1, GSTR-1A, GSTR-3B and GSTR-9 for the year | Declared figures to compare |
| GSTR-2B for the year and the following months | ITC availability check |
| Credit and debit note registers, unbilled and advance receipts | Timing differences |
| List of ITC reversals and reclaims under Rules 37 and 37A | Correct year of reporting |
| DRC-03 challans for any tax paid voluntarily | Credit for payments outside 3B |
How to file GSTR 9C on the GST portal: step by step
GSTR-9C is filed online on gst.gov.in after GSTR-9 for the same year. The portal opens the form only when every GSTR-1 and GSTR-3B for that year has been filed. Many preparers build it in the offline tool and upload the JSON.
- 1
Close the books and finish the audit
The reconciliation must start from the audited accounts, so the company audit or tax audit figures need to be final.
- 2
File every pending return
Clear any missing GSTR-1 or GSTR-3B for the year, otherwise GSTR-9 and 9C stay disabled on the portal.
- 3
File GSTR-9
Review the auto-filled tables, correct what the portal cannot know and file the annual return first.
- 4
Prepare the reconciliation
Work through turnover, rate-wise tax and ITC, and write a short reason for each difference that remains.
- 5
Pay any additional liability
Tax found short in Part V is paid through DRC-03 with interest before or while filing.
- 6
Upload and self-certify
Upload the statement and the audited accounts, then sign with DSC or EVC as the registration allows.
What is the GSTR 9C due date and late fee?
The GSTR 9C due date is 31 December following the financial year, the same as GSTR-9. CBIC Circular 246/03/2025 says the annual return is complete only when both forms are filed, so the late fee keeps running until the 9C goes in, even if GSTR-9 was filed on time.
Section 47(2) of the CGST Act sets the late fee at ₹100 a day, capped at a quarter per cent of turnover in the state, with a matching amount under the Delhi GST Act. The portal now calculates it in Table 17 of the 9C. Section 44(2) also bars filing an annual return more than three years after its due date, so an old 9C cannot be left forever.
| Item | Rule or date | Source |
|---|---|---|
| FY 2025-26 due date | 31 December 2026 | Rule 80(3) |
| FY 2024-25 due date | 31 December 2025 (now late if not filed) | GSTN FAQ examples |
| Late fee | ₹100 a day under CGST plus SGST equivalent, capped at 0.25% of state turnover per Act | Section 47(2) |
| When the fee stops | On the date the 9C is filed | Circular 246/03/2025 |
| Last chance to file | Three years from the due date | Section 44(2) |
Sources: CBIC Circular 246/03/2025-GST; section 47, CGST Act, checked November 2026. Reduced fee slabs may apply by notification; the portal figure is final.
Worked example: a 9C reconciliation for a Delhi distributor
A Delhi FMCG distributor with ₹7.8 crore of audited revenue files GSTR-9 showing ₹7.62 crore. The ₹18 lakh gap is not automatically a problem; it has to be explained line by line.
- ₹11 lakh is March 2026 revenue booked in the accounts but invoiced in April 2026, a timing difference reported with its reason.
- ₹5 lakh is a credit note issued in the books after the GSTR-1 cut-off, so it was not declared in the year.
- ₹2 lakh is scrap sale income in other income, which should have been in GSTR-1 and was missed. Tax on it is paid through DRC-03 and shown in Part V.
On the credit side, the books show ₹4.1 lakh more ITC than GSTR-9 because some supplier invoices never reached GSTR-2B. That ITC is not claimable, and Table 13 records why the books and return differ. This is the kind of work our accounting team sets up monthly so year-end is short.
Common GSTR-9C mistakes that lead to notices
The most common error is treating 9C as a formality and leaving large unexplained differences. Officers read Part V and Table 13 closely, and a bare "timing difference" with no working invites a question.
- Starting from unaudited figures and not updating after audit adjustments.
- Using company-level turnover for one GSTIN instead of a state-wise split.
- Reporting ITC of the earlier year in the wrong table after the FY 2024-25 changes.
- Ignoring other income such as scrap, rent or asset sales that attracts GST.
- Filing GSTR-9 on time and the 9C weeks later, which still attracts late fee.
- Not paying the additional liability before filing, so interest keeps adding up.
If a notice has already arrived after filing, our GST notice reply service handles the response.
GSTR 9C filing help in Delhi: how CA in Delhi handles it
We take on GSTR-9C preparation for Delhi businesses above ₹5 crore, along with the GSTR-9 it goes with. You send the audited accounts, registers and portal logins; we return a working file that shows every reconciliation, a list of tax to pay if any, and the filed acknowledgement.
Among the listed firms, Khubchandani & Co. Chartered Accountants and Moneymji both list GST return work, and the enquiry goes to whichever suits your size and timeline. Traders and manufacturers from Wazirpur and other industrial areas can send papers on WhatsApp and visit the Netaji Subhash Place office only if they want to. The fee for your GSTINs is fixed in writing before anyone opens your books. If you only need the annual return, see GSTR 9 filing, or compare options on our GST consultant in Delhi page.
Frequently asked questions
Is GSTR 9C mandatory for turnover below ₹5 crore?
No. Rule 80(3) requires the reconciliation statement only when aggregate turnover for the year exceeds ₹5 crore. Between ₹2 crore and ₹5 crore you file GSTR-9 alone. You may still keep an internal reconciliation, because officers can ask for one during scrutiny.
Does a chartered accountant need to sign GSTR-9C?
Not since 1 August 2021. The statement is self-certified by the taxpayer using the DSC or EVC of an authorised signatory. Many businesses still have a CA prepare it, but the CA's signature and UDIN are no longer part of the form.
Can I file GSTR 9C after GSTR-9?
Yes, the portal allows it, but the delay costs money. Late fee runs from the due date of the annual return until the 9C is filed, so filing GSTR-9 on 31 December and 9C on 7 January gives seven days of late fee.
Is aggregate turnover counted per GSTIN or per PAN?
Per PAN. Aggregate turnover adds all GSTINs on the same PAN across India. If the total crosses ₹5 crore, each GSTIN files its own GSTR-9C for its own state turnover, even if one branch is small.
Can GSTR-9C be revised after filing?
The portal does not offer a revision. If you find an error later, pay any extra tax through DRC-03 and keep a note on file. Spending time on the working file before submission is cheaper than explaining a wrong figure in a notice.
What happens if unreconciled differences remain?
Give the reason in the statement. Differences that mean tax was short paid go into Part V and are paid with interest. Differences with a genuine reason, such as timing or a non-GST income item, are explained and left as they are.
What is the last date for GSTR 9C for FY 2024-25?
It was 31 December 2025. If it is still pending in November 2026, file it now: late fee is accruing daily, and section 44(2) stops annual returns being filed more than three years after the due date.
Do I need audited accounts if my business is a proprietorship?
Yes, if turnover is above ₹5 crore. A proprietor at that level is usually under tax audit, and the reconciliation uses those audited figures. Without them the statement cannot start from the audited annual financial statement as section 44 requires.
Can you file GSTR-9C for a business outside Delhi?
Yes. The work runs on documents and portal access, so we handle GSTINs in Haryana, Uttar Pradesh and other states the same way. The listed firm working on it confirms the scope and a fixed quote first.