GSTR-9 is the annual return in which a registered person consolidates the year's monthly returns, filed on the GST portal for each financial year. You reconcile the books with what was declared in the outward-supply statement and the summary returns, fill the turnover and input tax credit tables, pay any shortfall and file. GSTR-9C is a separate reconciliation statement, certified by a chartered accountant or cost accountant, required only above the turnover threshold the Act fixes.
Before you start
- Every monthly and quarterly return filed for the year, with their acknowledgements, so the declared figures can be pulled together.
- The annual financial statements — trading account, profit and loss account and balance sheet — which carry the turnover and expenses against which the returns are reconciled.
- The electronic credit ledger, the electronic cash ledger and the electronic liability register for the year.
- The input tax credit register, showing credit availed, credit reversed and credit claimed on inward supplies.
- A list of the differences you already know about — liabilities reported late, credit reversed under a rule, invoices not uploaded by suppliers.
- The turnover threshold that applies to you for that year, to decide whether the reconciliation statement is also required.
Steps
- 1. Confirm that the return is due for you. All normal registered persons file GSTR-9 for the year, and composition dealers file the composition annual return. Only the categories the Act exempts, and those below the turnover threshold the notification fixes for the year, are out of it. Check the threshold before deciding you are covered.
- 2. Open the annual return on the portal. The form auto-populates much of its data from the monthly returns filed during the year. Treat the auto-filled figures as a starting point, not as the answer, because the auto-population only mirrors what was filed and does not cure an error.
- 3. Reconcile the returns with the books. Compare the turnover declared in the returns with the turnover in the audited or finalised accounts, and the tax paid with the tax payable. Every difference is entered in the return with its reason, not quietly adjusted.
- 4. Fill the turnover tables. The return asks for the details of advances, inward and outward supplies, the outward supplies split by rate and by supply type, and the tax payable on them. The figures must tie to the returns filed for the year; where a supply was reported late, it is shown as a late declaration with the tax that follows.
- 5. Fill the input tax credit tables. The credit portion separates credit availed on inward supplies, credit availed on the basis of documents received late, credit reversed, and credit taken but not eligible. Reconcile the total credit availed with what the monthly returns reported and with the credit ledger.
- 6. Work out the tax paid and the tax payable. The return shows the tax paid through the cash and credit ledgers against the tax payable for the year. A short payment shown here must be discharged, usually by debiting the cash ledger and reporting the payment with the return.
- 7. Decide on the reconciliation statement. Where your turnover crosses the threshold, a reconciliation statement is required along with the annual return, certified by a chartered accountant or cost accountant. It reconciles the audited accounts, the returns and the tax, and sets out the differences and their reasons. The annual return is your declaration; the reconciliation statement is the accountant's certificate.
- 8. File and verify. Submit the return, verify it with the digital signature or the electronic verification code, and download the acknowledgement with its reference number. Then file the reconciliation statement, if it applies, separately.
Documents to keep
- The filed annual return and the reconciliation statement, if any, with their acknowledgements.
- The reconciliation working papers that tie the books to the returns, which are what an audit will ask for first.
- The monthly returns, the ledgers and the credit register for the year.
- The challans for any shortfall paid with the annual return.
- The financial statements of the year, signed, along with the audit file, kept for the period the Act requires.
What goes wrong
- Filing late and attracting the late fee, which runs for each day of delay within the limit the Act sets and is heavier for larger turnover. The exact amount is not fixed in the abstract, so the safe course is to file by the date the Act prescribes.
- Accepting the auto-populated figures without reconciling them, so an error in a monthly return is carried straight into the annual return.
- Ignoring a difference between the returns and the accounts instead of disclosing it with its reason.
- Splitting the input tax credit wrongly, so credit that was reversed during the year is shown as credit availed.
- Forgetting that the reconciliation statement is a separate filing, and treating the annual return as the end of the matter.
Common questions
Who must file GSTR-9?
Every registered person other than those the Act exempts, for each financial year, and composition dealers file the composition annual return. The exemption is turnover based, and the threshold is fixed by notification for the year, so confirm the figure that applies before concluding that no annual return is due.
What is the difference between GSTR-9 and GSTR-9C?
The annual return is the taxpayer's own consolidated declaration of the year's supplies, credit and tax. The reconciliation statement is a certification by a chartered accountant or cost accountant that reconciles the audited accounts with the returns, and it is required only above the turnover threshold. The two are filed as separate documents.
Can I revise GSTR-9 once it is filed?
No. The annual return is not amended once filed. The figures for a year, once consolidated in the annual return, stand as filed, which is why the reconciliation must be done carefully before submission rather than corrected afterwards.
What if there is a short payment for the year?
The shortfall has to be paid and shown with the annual return, normally by debiting the electronic cash ledger. The return will not settle a difference silently; the tax payable and the tax paid have to agree, so any gap is discharged at the time of filing.
The annual return is the year's last filing but not its only one, and the wider services we provide keep the monthly returns on track through the year.
FileX Advocates & Legal Consultants, Kolkata, prepares annual return reconciliations, GSTR-9 and GSTR-9C workings and the audit file behind them. Call +91 7439811422 or WhatsApp us for a first consultation. Our GST and tax law desk and the tax and regulatory formats section set out the papers involved.