This is a valid observation about the GSTR-9C format. Here is the clarification:
1. GSTR-9C Structure: GSTR-9C (Reconciliation Statement) is meant to reconcile the figures in the audited financial statements with those declared in GSTR-9 (Annual Return). It is NOT a return — it is a reconciliation/audit document.
2. ITC in GSTR-9C: - Table 12 of GSTR-9C: Covers reconciliation of ITC declared in GSTR-9 with ITC availed as per audited accounts - The reconciliation identifies: ITC as per books, ITC as per GSTR-9, and the difference (with reasons) - There is NO separate field for ITC utilisation (i.e., how much ITC was applied toward IGST output, CGST output, SGST output) in GSTR-9C — this is because utilisation detail is already captured in GSTR-3B (monthly) and GSTR-9 (annual return)
3. Where ITC Utilisation is Reported: - GSTR-9 (Annual Return): Table 6 shows ITC availed. Table 7 shows ITC reversed. Table 8 provides detailed ITC reconciliation with 2A - GSTR-9C: Only compares books with GSTR-9 — utilisation is assumed to be as per GSTR-9
4. If There is a Mismatch: - If books show different ITC utilisation than GSTR-9 (e.g., excess ITC utilised or ITC reversal not done), it must be flagged in GSTR-9C under Table 14 (Auditor's Recommendation on additional liability due to non-reconciliation)
5. Practical Tip: Ensure GSTR-9 is filed correctly (especially Tables 6, 7, and 8) before finalising GSTR-9C — the reconciliation in GSTR-9C is only as good as the GSTR-9 data it is benchmarked against