In my earlier article, "Departmental Audit and Special Audit under GST - When the Law Listens," we saw how the law seeks the truth through its external mechanisms - the Departmental Audit under Section 65, where authorised officers verify the correctness of self-assessment, and the Special Audit under Section 66, where the Commissioner may direct an independent Chartered Accountant or Cost Accountant to conduct a deeper professional scrutiny. These provisions are the law's way of ensuring clarity and honesty-objective, systematic, and committed to matching declarations with reality. Ultimately, the highest level of compliance comes when the registered person genuinely listens to their own inner voice.
That inner process is beautifully reflected in Section 44, which focuses on the audit carried out by the registered person through the annual return and reconciliation statement. While Sections 65 and 66 give the law the authority to audit you, Section 44 invites you to conduct a self-audit - to review your records, verify your declarations, and ensure that your internal books match the outward picture you present to the tax authorities. In this way, this provision turns a legal requirement into a meaningful act of self-awareness and professional integrity.
Conceptually, Section 44 fits very well with Sections 35 and 59 of the CGST Act. Under Section 35, a registered person must keep accurate and truthful records of supplies, input tax, and other relevant details. Under Section 59, they are responsible for self-assessing the tax owed and submitting returns. Section 44 is like the final piece of this puzzle - it's where the taxpayer takes a moment to review, compare, and confirm that their record-keeping and self-assessment match perfectly. It beautifully completes the cycle - from maintaining records to filing returns, and finally, to verifying everything on their own.
As Anand Bakshi Ji famously wrote in the inspiring song from Movie Aap Ki Kasam. (1974):
ज़िंदगी के सफ़र में गुज़र जाते हैं जो मुकाम,वो फिर नहीं आते, वो फिर नहीं आते…(फ़िल्म: आप की कसम, 1974 - गीत: आनंद बक्षी जी)
These moving words remind us that every financial year, once gone, never returns. Therefore, the annual audit under Section 44 is not merely a compliance ritual but an opportunity to look back without regret and ensure completeness before stepping into the following year. It is a dialogue between the taxpayer and his conscience - a meeting point where law and honesty quietly shake hands.
SELF-AUDIT UNDER GST - जब ख़ुद से मुलाक़ात होती है -(Section 44 of the CGST Act, 2017 read with Rule 80 of the CGST Rules, 2017)
After the external lenses of Departmental Audit under Section 65 and Special Audit under Section 66, there's the important self-audit, which the registered person conducts themselves. This isn't an inspection by someone else, but a chance for the individual to look inward - a mirror in which they review their own compliance, reconcile their figures, and ensure their self-assessment honestly reflects the realities of their business.
Section 44(1) requires every registered person, except those explicitly exempted, to submit an annual return electronically in Form GSTR-9 for each financial year. This return should include a comprehensive summary of outward supplies, inward supplies, input-tax credits claimed, taxes paid, refunds claimed, and demands raised. The main goal is to bring together all the periodic returns filed throughout the year and to identify any discrepancies between your books of accounts and the data entered on the GST portal, ideally before the Department notices them.
Recognising the challenges faced by small businesses, the first proviso to Section 44(1) allows the Commissioner, based on the recommendations of the GST Council, to grant exemptions from filing the annual return to certain groups of people depending on their total turnover. Building on this, the Government issued Notification No. 15/2025 - Central Tax on September 17, 2025, offering a permanent exemption from submitting the annual return in Form GSTR-9 for all registered persons whose total turnover in a financial year is ₹2 crore or less. This helpful exemption applies from the 2024-25 financial year, making life easier for small businesses and showcasing the Government's dedication to simplifying the process of doing business.
Before this change, if registered persons had turnover above certain limits, they had to submit a reconciliation statement in Form GSTR-9C, which needed to be certified by a Chartered Accountant or Cost Accountant. But under the Finance Act, 2021, this requirement was replaced, so they now only need to do a self-certification. The registered person must prepare and self-certify the reconciliation statement, ensuring that the figures in the annual return match those in the audited financial statements. This update shifted the process from reliance on external certification to a more straightforward self-audit grounded in honesty, accountability, and discipline.
Essentially, Section 44 together with Rule 80 captures the true essence of GST - "trust but verify." The law trusts the registered person to declare and reconcile their data honestly, yet it also encourages them to perform an internal check before submitting the annual return. This process allows the registered person to wear two hats: that of an auditor and an auditee - helping spot accidental errors, fix omissions, and voluntarily settle any shortfall before the Department's review begins, fostering a spirit of transparency and cooperation.
This self-audit requires a disciplined and proactive approach. The registered individual must compare turnover reported in books, Form GSTR-1, and Form GSTR-3B; reconcile input-tax credits from books with Form GSTR-2B; and verify the accuracy of taxes, refunds, and adjustments. The reconciliation in Form GSTR-9C links financial statements with GST returns, ensuring revenue and tax liabilities are consistent and aligned.
The purpose of this annual self-review is to encourage voluntary compliance and gently promote self-improvement. When the registered person carefully reconciles their own records, they become more aware of recurring mismatches, missed credits, and procedural lapses - gaining valuable insights that help strengthen internal systems and improve future compliance. In this way, self-audit is more than just a statutory requirement; it's a meaningful conversation between the business and its conscience - a positive habit of honesty that turns compliance into a source of confidence.
As a registered person, you're required to file the annual return using Form GSTR-9 electronically on the common portal. Additionally, Rule 80(3) requires submission of Form GSTR-9C, the reconciliation statement, which now involves self-certification and must be submitted along with the annual return. Usually, the deadline for both forms is December 31st of the following financial year, but this can be extended through notifications. Remember, missing the deadline can lead to late fees under Section 47(2) and, in some cases, to scrutiny or further action.
Therefore, the self-audit under Section 44 completes the trilogy of GST audit mechanisms. While Section 65 covers audits conducted by the Department, and Section 66 involves audits carried out by professionals appointed by the Department, Section 44 concerns audits performed by the registered person themselves-the most self-reflective, reformative, and empowering approach. It serves as a reminder to every business that compliance is rooted not in enforcement but in self-discipline and transparency.
"ये दोस्ती हम नहीं तोड़ेंगे…"(Film-Sholay (1975))
Anand Bakshi Ji's heartfelt words beautifully highlight the importance of self-accountability - a friendship that stands firm. Similarly, the self-audit under GST symbolises a lasting connection between the registered person and truth - a bond founded on trust, integrity, and a sincere commitment to walk the path of compliance year after year consistently.
The Melody of Self-Reflection - Where Law Meets Conscience
When we step back and view the GST audit framework as a whole, we begin to appreciate the elegant symmetry within the law. Section 35 requires every registered person to maintain accurate and correct accounts - the foundation of responsible record-keeping. Section 59 builds upon it by allowing self-assessment, entrusting taxpayers with the confidence to compute and declare their own liability. Sections 65 and 66 bring in the State's supervisory wisdom - where the law listens, reviews, and verifies the accuracy of self-assessment through departmental and special audits. Finally, Section 44 completes this circle of trust by turning the mirror inward - reminding every registered person to verify his own truth before anyone else does. It is the final act of reconciliation between law and conscience, where compliance meets character.
The true essence of law is not just about enforcement; it is about empowering individuals. Section 44 is not focused on policing; it's about registered persons being active partners in good governance. The annual return and reconciliation statement are more than just forms; they are tools for reflection. When a business owner carefully reviews every figure, checks every ledger, and verifies every credit claimed, they're not just fulfilling a legal obligation-he is reaffirming the importance of accuracy, discipline, and trustworthiness.
Seen this way, the self-audit under Section 44 symbolises the most mature stage of compliance. It tells us that transparency is not demanded from outside - it is discovered within. The law can verify only what we have declared, but our integrity ensures that the declaration itself is correct. That's why, with genuine commitment and sincerity, we take extra care to make sure everything is in order. Professionalism, every return filed honestly becomes not just a legal statement but a moral one - an expression of the taxpayer's faith in the system and in himself.
Each new financial year presents a fresh opportunity to renew our trust and commitment. Just as auditors learn from past experiences to better the future, the annual self-audit offers each registered person a chance to reflect on his performance, make adjustments, and start the following year on a positive note. It's a peaceful moment of reflection between the closing of one year and the beginning of another - where learning turns into leadership. In that quiet space between numbers and faith, Anand Bakshi Ji's heartfelt words shine like a guiding light.
🎵किसी राह में, किसी मोड़ पर,कहीं चल न देना तू छोड़ कर, मेरे हमसफ़र, मेरे हमसफ़र,किसी हाल में, किसी बात पर,कहीं चल न देना तू छोड़ कर, मेरे हमसफ़र, मेरे हमसफ़र…(Film Mere Ham Safar 1970)
These timeless lines serve as a gentle reminder that once we decide to walk the path of sincerity, it is essential to stay committed all the way. While laws might change and notifications may shift, the core spirit of discipline and truth should always remain steady. Just like a loyal friend walking closely alongside us through every step, our honesty needs to be with us through every audit, every return, and every year, providing a guiding light.
So, when a registered person completes an audit under Section 44, it is really just the start of a new, more confident chapter. It's where the spirit of the law aligns with honesty, turning compliance into a part of who we are. And as Anand Bakshi Ji's gentle words remind us, "चलते रहो सच्चाई के साथ, क्योंकि यही है असली हमसफ़र," it encourages every taxpayer to keep moving forward with truth as their faithful companion.
Author's Note - The Journey Within the Journey
Every law is meant to guide us, but its true purpose shines when it inspires. When I wrote about Audit by the Registered Person under Section 44, I was reminded again that compliance isn't just about following rules - it is about building discipline. While the State may listen to us through Sections 65 and 66, Section 44 gives us a chance to listen to ourselves, to check not only the strength of our records but also the sincerity of our intentions.
As professionals, we often view audit as a routine task; however, beneath that duty lies a wonderful opportunity - to take joy in knowing that each number genuinely reflects the truth. That beautiful balance between law and honesty is what makes the GST framework more than just a tax system - it's a reflection of our shared integrity.
This article has been thoughtfully crafted with references to popular Hindi film songs penned by Anand Bakshi Ji, aiming to spark curiosity and keep readers engaged, even in today's busy, mobile-driven world. In a time when reading often feels rushed and fragmented, I hope to offer a blend of entertainment and insight - a smooth and enjoyable rhythm that transforms learning about GST from a simple task into a delightful and memorable journey.
Anand Bakshi Ji's writing has always inspired me to share complex ideas using simple words. His songs remind us that the deepest truths are often the humblest. With that in mind, I truly believe that tax law can also be harmonious - if we approach it with faith, sincerity, and a smile.
"कदम-कदम पर सच्चाई को साथी बना लो -यही सफ़र को मंज़िल में बदल देता है।"
And that, perhaps, is the most beautiful audit of all - when the figures in our books begin to echo the honesty in our hearts.
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