GSTR 9 & 9C – FY 2022-23

GSTR 9 is an annual return filed i.e., summary return of all the returns (GSTR 1 & 3B) filed during the financial year, whereas GSTR 9C is a reconciliation statement between returns and books.

We need to addressmainly on the applicability of GSTR 9 and 9C along with the importantrequirements to duly comply on time.

  1. A) Applicability for FY 2022-23

The applicability of GSTR 9 and GSTR 9C for FY 2022-23 is similar to that of FY 2021-22. The same has been summarised below

  • GSTR 9 is to be furnished by all taxpayers whose aggregate turnover exceeds INR 2 crore.
  • Additionally, a self-certified statement in GSTR 9C should be furnished by taxpayers whose aggregate turnover exceeds INR 5 crore.
  • Accordingly, a taxpayer (whose aggregate turnover is between INR 2 crores and INR 5 crore) is required to only file GSTR 9 and need not file GSTR 9C.
  • Therefore, any taxpayer whose aggregate turnover is less than INR 2 crores need not file both GSTR 9 & 9C. However, such taxpayers can file the forms voluntarily.

Following list of taxpayers need not file GSTR 9:

  • Input Service Distributors
  • Taxpayers opting for Composition Scheme
  • Casual Taxable Person
  • Non-resident Taxable Persons
  • Persons paying TDS under Section 51 or TCS under Section 52
  • Persons supplying OIDAR services from out of India to a person in India

Late fees applicable for delayed filing of the said forms are as below:

  1. GSTR 9 – Late fees of Rs 200 per day of delay subject to a maximum cap of an amount at 0.25% of total turnover in respective State/Union Territory
  2. GSTR 9C – No specific provision, Hence, subject to a general penalty of INR 25,000.


    B) Requirements
  • Finalisation of books of accounts would have been ideally completed by all taxpayers as the due date for filing income tax return for all assessees have been expired [timelines under Section 139(1) of Income Tax Act].
  • In case of taxpayers having registrations in multiple states, trial balance need to be pulled out state-wise whereby total of all states should be tallied with turnover/ input tax credit (‘ITC’) as per financials. Moreover, state-wise trial balance is a basic requirement incase a taxpayer’s case gets picked up for audit by the GST department directly.
  • From sales perspective, invoice wise reconciliation needs to be donebetween GSTR 1 vs GSTR 3B vs books of accounts and any differences need to be ascertained and their corresponding tax liability need to be calculated alongwith applicable interest liability.
  • From purchases perspective, invoice wise reconciliation needs to be done between GSTR 2B vs GSTR 3B vs books of accounts and any differences need to be ascertained and their corresponding impact (ITC reversal or payment of tax in DRC-03) need to be calculated alongwith applicable interest liability.
  • Details of outward and inward suppliesreported (along-with amendments) pertaining toFY 2022-23 in GSTR 1/ GSTR 3B of returns filed for the period April 2022 to October 2022 (filed till 30 November 2022) need to be listed, so that the same can be given impact in GSTR 9.
  • Similarly, any adjustments done in returns of FY 2022-23 pertaining to FY 2021-22 need to be traced and considered in GSTR 9C.
  • HSN wise outward supply details should be consolidated from the monthly/quarterly GSTR 1 returns filed for FY 2022-23 for the purpose of reporting in GSTR 9. (6 digit HSN for taxpayers with more than INR 5 crore turnover. 4 digit HSN for all B2B supplies by taxpayers having less than INR 5 crore turnover).
  • Rate-wise liability of outward supplies and RCM transactions (actuals as per books) should be prepared and be reconciled with amounts reported in GSTR 9 and any difference needs to be reconciled.
  • Data getting auto populated in Income tax website (Form AIS and Form 26AS) needs to be verified.