GSTR-9C: Who Must File For FY 2024-25

The Goods and Services Tax (GST) regime in India requires businesses to maintain transparency and accuracy in their tax filings. One of the key annual compliance requirements is GSTR-9C, often referred to as the GST audit and reconciliation statement.

What is GSTR-9C?

GSTR-9C is a reconciliation statement that compares the figures declared in your annual return (GSTR-9) with your audited financial statements. It is essentially a certification that the details filed in GST returns match the books of accounts.

This form is certified by either:

• A Chartered Accountant (CA), or
• A Cost Accountant.

Who Must File GSTR-9C for FY 2024-25?

As per the GST rules for FY 2024-25:

Every registered taxpayer with an aggregate turnover exceeding ₹5 crore during the financial year must file GSTR-9C.

In simple terms:

• If the turnover is above ₹5 crore, GSTR-9C is mandatory.
• If the turnover is up to ₹5 crore, you are exempt. You only need to file GSTR-9 (annual return), not GSTR-9C.

Format of GSTR 9C

Part-A: Reconciliation Statement

• Table 5 - Reconciliation of gross turnover

Map audited financials (entity or GST-registered segment) to "turnover under GST" after removing non-GST items/other branches, unbilled revenue, credit notes, etc.

• Table 6 - Reasons for differences in gross turnover (explain unreconciled items).
• Table 7 - Reconciliation of taxable turnover (from gross to taxable; exclusions such as exempt/zero-rated/RCM).
• Table 8 - Reasons for differences in taxable turnover.
• Table 9 - Reconciliation of tax liability & tax paid (rate-wise).
• Table 10 - Reasons for differences in tax payment.
• Table 11 - Additional liability payable (if any)-usually paid through DRC-03.
• Table 12 - Reconciliation of Net ITC.
• Table 13 - Reasons for differences in ITC.
• Table 14 - ITC as per expense-wise mapping (A-Q heads) vs ITC in GSTR-9 (e.g., purchases, freight, advertising, capital goods, etc.).
• Table 15 - Additional liability due to non-reconciliation (if any).

Verification (Self-certification)

• Registered person declares correctness & responsibility for differences; CA/CMA certification is not required for FY 2024-25.

Documents Needed

• Audited financial statements (entity & branch/unit breakup if applicable).
• GSTR-1 & GSTR-3B for all months of FY 2024-25; GSTR-9 draft/working.
• Rate-wise liability workings; RCM ledger.
• Expense-wise ITC mapping (to fill Table 14).
• DRC-03 payment details if any extra liability arises.

Step-by-step: Filing GSTR-9C on the GST Portal

Prerequisites

• Ensure all monthly/quarterly returns (GSTR-1, 3B) are filed. Prepare and (preferably) finalise GSTR-9 first-9C pulls numbers from 9 and audited books.
• Login → Services ▸ Returns ▸ Annual Return → Select FY 2024-25 → Prepare Online for GSTR-9, complete and Submit (or keep saved) before moving to 9C.
• Open GSTR-9C (same Annual Return page): click Prepare Online (or Initiate Filing). The system will show Part-A tables.

Fill Part-A

• T5-T8 (Turnover): start with audited turnover, adjust per the on-screen guidance to reach GST turnover/taxable turnover; explain differences in T6 & T8.
• T9-T11 (Tax): enter rate-wise outward/RCM liability, tax paid; if any shortfall, create DRC-03 and record reference in T11.
• T12-T13 (ITC): reconcile Net ITC from books vs GSTR-9; give reasons for differences.
• T14 (Expense mapping): report eligible ITC against expense heads; the total should match ITC in GSTR-9 (net of reversals)

Compute liabilities (if any) → Pay via DRC-03 → capture CIN/ARN in the relevant fields.

Verification (self-declaration) → Proceed to File.

• Companies/LLPs: file with DSC.
• Others: EVC (OTP) allowed.

Download & keep the filed PDF/JSON and ARN for records. (It's often requested during scrutiny).

Due date to file GSTR 9C

The due date for filing GSTR-9C (reconciliation statement) is 31st December of the year following the relevant financial year, or such extended date as notified by the Government.

Penalty / late-fee for non filing or late filing

Late fee (for the complete annual return): Section 47(2) of the CGST Act levies a late fee for delay in furnishing the annual return under section 44. Practically this is ₹100/day under CGST + ₹100/day under SGST = ₹200/day total (until the cap), subject to the statutory maximum (quarter-percent cap under each Act - effectively 0.5% of turnover (state/UT) as the ceiling). CBIC clarified that late fee is levied until the complete annual return (GSTR-9 + GSTR-9C where applicable) is filed.

General penalty for non-filing (where no specific penalty exists): Since there's no separate penalty expressly for failing to furnish GSTR-9C, authorities may rely on Section 125 (general penalty) - maximum ₹25,000 - for contraventions where no other penalty is prescribed. Courts have sometimes limited application of Section 125 where a specific late fee is available, but the risk of notices/penalties (and subsequent litigation) exists.Show-cause / assessment risk and notices: non-filing can trigger departmental notices, GST assessments or audits - which can lead to demands, interest, and penalties depending on findings.

Important historical relief (time-bound): The Government (Notification 08/2025-Central Tax, 23-Jan-2025) and CBIC circular gave a limited waiver of excess late fees for pending GSTR-9C for FY 2017-18 to FY 2022-23 if filed on or before 31-Mar-2025 (no refund of fees already paid). That window has passed (current date is Oct 3, 2025), so that relief isn't available now - file asap to avoid present/ongoing late fees and penalties.

FAQs

Is a CA/CMA certificate needed?

No-self-certified since 01-Aug-2021; threshold AATO > ₹5 crore.

What is the Due date for FY 2024-25?

31 Dec 2025 (government often extends; watch for notifications).

Can one file 9C without 9?

No 9C reconciles GSTR-9 vs audited books, so GSTR-9 must be prepared first

Is it mandatory to file GSTR-9C using the offline utility?

No, it is not mandatory to use the GSTR 9c offline tool for filing. You can choose to file GSTR-9c directly on the GST portal.

Can GSTR-9C be revised after submission?

No once submitted the 9C cannot be revised.

What if there are mismatches in GSTR-9C vs audited financials?

If there are any discrepancies, explanations for the same should be given in the reconciliation statement and the same shall be reported by the CA or Cost Accountant in the certificate.