9c filing doubt

good afternoon 🙏

a proprietor has 3 gst registrations in the state. one is wholesale trading (above 5 crore turnover), other is lodging service (50 lacs only) and another lodge (approx 70 lacs turnver.
all three seperate gst numbers (migrated from prev tax regime).

doubt - 9c to be filed for all three showing each audited turnover figures or total of three business turnover in 9c ?
or only one 9c to be filed only in the wholesale trading gst reg portal ?


pls advice !
Replies (5)
Quick Summary
This discussion addresses a proprietor with three separate GST registrations under one PAN, each with different turnover figures. The core question is whether to file a single GSTR-9C for the wholesale trading business, or separate GSTR-9C filings for each registration. The consensus, supported by CBIC clarifications, is that GSTR-9C must be filed for each registration individually, as the aggregate turnover across all registrations under the same PAN determines the filing requirement.

If you have separate GST Registration, then you have to file separate GST 9c,showing each audited turnover figures.
One firm turnover above 5crore and other two firm turnover blow 2crore
For firm above 5cr Gstr 9c will be applicable and below 2cr GSTR 9 will be applicable. In case of you are not filing Gstr 9 ,the auto populated Gstr 9 will be considered as final one
For all three businesses he has to file GSTR 9C because turnover of an assessee should be considered at PAN level. As in this case if you clubbed turnover of all businesses it is more than the threshold limit of 2crs and if possible you can file p&l and BS GSTIN level otherwise you can upload consolidated financials and you need to reconcile each business turnover with each separate registration by filing different GSTR 9Cs..
It's already being clarified by cbic in press release on 3/7/2019 , need to file 9C for all the branches.

Extract from Press Released as below :

Turnover for eligibility of filing of reconciliation statement: It may be noted that the aggregate turnover
i.e. the turnover of all the registrations having the same Permanent Account Number is to be used for determining the
requirement of filing of reconciliation statement. Therefore, if there are two registrations in two different States on the
same PAN, say State A (with turnover of Rs. 1.2 Crore) and State B (with turnover of Rs. 1 Crore) they are both
required to file reconciliation statements individually for their registrations since their aggregate turnover is greater
than Rs. 2 Crore. The aggregate turnover for this purpose shall be reckoned for the period July, 2017 to March, 2018

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