Replied 08 July 2021
GST Audit i. e. "SECTION 35(5) of the CGST Act 2017" by a Chartered Accountant (CA) or a Cost and Management Accountant (CMA) has been omitted vide Section 101 of the Finance Act 2021, which is yet to be notified under the CGST Act 2017 from FY 20-21 onwards.
Now FORM GSTR-9C will only be a "Self Certified Reconciliation Statement" w. e. f FY 20-21 onwards. As per the general Rule of 9C ( Rule 80 of the CGST Rules 2017 ), it was mandatory to file FORM GSTR-9C when the annual aggregate turnover exceeds Rs. 2 crores. But for FY 18-19 & 19-20, the notified limit for GST Audit was 5 crores.
Therefore a clarification is required from the Government regarding the limit of Aggregate Turnover for the purpose of applicability of Self Certified Reconciliation Statement ( FORM GSTR-9C) from FY 20-21 onwards.