Comparative analysis of GSTR 9 and GSTR 9C

GSTR 9 AND GSTR 9C

Since CBIC released the GSTR-9 and GSTR-9C forms, there has been persistent confusion regarding who must file them and whether or not the information required for each is the same. But not any more!


The GSTR-9 structure is a yearly return that must be recorded by completely enrolled available people under GST. The GST reconciliation statement for a particular FY on or before December 31 is the GSTR-9C. For businesses with a turnover of more than 5 crores, the reconciliation must also be certified by a CA.


What is the annual return for the GSTR-9?


Taxpayers who are registered under the GST are required to submit an annual return known as GSTR 9. Important details:


  • It contains information about outbound and inbound supplies made or received during the relevant fiscal year under various tax heads like CGST, SGST, and IGST, as well as HSN codes.

  • It combines all of the monthly and quarterly returns (GSTR-1, GSTR-2A, and GSTR-3B) that were submitted during that year. Despite its complexity, this return facilitates extensive data reconciliation for transparent disclosures.


What's GSTR-9C?


A chartered accountant or a cost accountant is required to audit the accounts of any registered person whose annual revenue exceeds the limit of Rs. 5 crore.


GSTR-9C is a reconciliation declaration between:


  • The figures from the taxpayer's audited annual Financial Statements

  • The annual Returns in GSTR-9 that were submitted for a particular fiscal year.



It may be compared to a tax audit report provided in accordance with the Income Tax Act. It will include the consolidated gross and taxable turnover from all GST returns for an FY, reconciled with the respective figures from the books.


As a result, the reasons behind any disagreements that arise from this reconciliation exercise will be discussed in this space. For each GSTIN, the certified statement must be issued. Consequently, multiple GSTR-9C forms may be filed for a PAN.

GSTR-9 and GSTR-9C

Here is a quick comparison between GSTR-9 and GSTR-9C :



GSTR-9 :


  • GSTR 9 is a Return Form

  • In accordance with Section 44 of the CGST Act, as specified in Rule 80

  • The taxpayer must sign using a digital signature.

  • Both the Tax Payer and the Auditor are required to sign with their respective digital signatures. Late fees of Rs 200 per day of delay, up to a maximum of 0.25 percent of the state or territory's total revenue.

  • 31 December of the upcoming FY*

  • CA/CMA does not require certification; however, the taxpayer must attest to it using a digital signature.

  • To be submitted by each and every registered taxpayer for the Goods and Services Tax only for the fiscal years 2021 and 2022 

    • T.O. Up to 2 Cr. – Optional 

    • More than 2 Cr. – 5 Cr – Required 

    • More than 5 Cr – Required

  • Prior to GSTR-9C, GSTR-9 must be submitted.




GSTR-9C :


  • GSTR-9C is a Reconciliation Statement

  • In accordance with the CGST Act's Section 44, Section 35(5)

  • Both the Tax Payer and the Auditor are required to sign with their respective digital signatures.

  • No specific provision, Hence, subject to a general penalty of Rs 25,000

  • 31st December of next FY, either with or after filing GSTR-9*

  • A digital signature must be used to attest the taxpayer's certification of the GST auditor, who must be either a CA or CMA.

  • To be submitted if the annual revenue exceeds Rs. 2 crore 

    • Only for FY 2021-2022 

    • T.O. Up to Rs. 2 crore – None 

    • More than Rs. 2 crore – 5 Cr—optional 

    • More than 5 Cr—required

  • GSTR-9C must adhere to the annual return for GSTR-9.



GSTR 9 and GSTR 9C Exemptions: 


  • Non-resident taxable persons

  • Input service distributors, 

  • casual taxable persons, and persons 

  • collecting taxes under Section 52 of the GST Act and deducting taxes (TDS) under Section 51 of the GST Act are exempt from filing the GSTR-9 Annual Return.


Online Information and Database Access Retrieval Service In the case of GSTR-9C, in addition to individuals exempt from GSTR-9, registered taxpayers and composition dealers whose annual turnover does not exceed Rs 2 crores for a given fiscal year are exempt from submitting the GSTR-9C reconciliation statement.


For more info visit us @myfinancialadvisory.com to file your gst return. 


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