GST Annual Return filing is a critical compliance requirement for most GST-registered taxpayers in India. It provides a comprehensive summary of all the transactions undertaken during a financial year and acts as a consolidation of the monthly/quarterly returns (like GSTR-1 and GSTR-3B) filed during that period.
What is the GST Annual Return (GSTR-9)?
GSTR-9 is an annual return form that consolidates all the information furnished by a regular registered taxpayer in their monthly/quarterly GST returns (GSTR-1, GSTR-3B, etc.) throughout a financial year. It also allows for reporting of certain adjustments or details that might not have been captured in the regular returns.
Key Information Reported in GSTR-9
- Details of outward supplies (sales) made.Details of inward supplies (purchases) received.Input Tax Credit (ITC) availed and reversed.Tax paid and payable.Demands and refunds.
- Supplies from composition taxpayers, job work, etc.
- HSN-wise summary of outward and inward supplies.
Who Needs to File GSTR-9?
Mandatory Filing
GSTR-9 is mandatory for regular registered taxpayers whose Annual Aggregate Turnover (AATO) exceeds ₹2 crore in a financial year.
Optional Filing
For taxpayers with an AATO up to ₹2 crore, filing GSTR-9 is optional for Financial Years 2017-18 to 2023-24. The GST Council often provides this relaxation to reduce the compliance burden on small businesses. It’s crucial to check the specific notification for each financial year’s applicability.
Who is EXEMPT from filing GSTR-9?
The following types of registered persons are not required to file GSTR-9:
- Casual Taxable Persons
- Non-Resident Taxable Persons
- Input Service Distributors (ISD)
- Persons liable to deduct TDS (Tax Deducted at Source) under Section 51 of the CGST Act.
- Persons liable to collect TCS (Tax Collected at Source) under Section 52 of the CGST Act.
- OIDAR (Online Information and Database Access or Retrieval) service providers.
What is GSTR-9C?
GSTR-9C
is a reconciliation statement that taxpayers need to file. It’s a statement of reconciliation between the annual turnover as declared in the audited annual financial statements and the turnover as declared in the annual return (GSTR-9). It also reconciles the tax paid as per the books of accounts with the tax paid as per GSTR-9.
Key Aspects of GSTR-9C
- It highlights any discrepancies between the financial books and the GST returns.
- It includes a self-certification by the taxpayer (or earlier, by a Chartered Accountant/Cost Accountant) to ensure the accuracy of the reconciliation.
Who Needs to File GSTR-9C?
- GSTR-9C is mandatory for registered taxpayers whose Annual Aggregate Turnover (AATO) exceeds ₹5 crore in a financial year.
- For taxpayers with an AATO up to ₹5 crore, filing GSTR-9C is optional (since FY 2020-21).
Important Change: Earlier, GSTR-9C required certification by a Chartered Accountant (CA) or Cost Accountant (CMA). However, from FY 2020-21 onwards, it needs to be self-certified by the taxpayer themselves.
Due Date for Filing GSTR-9 and GSTR-9C
The due date for filing both GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) for a financial year is December 31st of the next financial year.
- For FY 2024-25: The due date for filing GSTR-9 and GSTR-9C will be December 31, 2025.
Penalties for Late Filing of GSTR-9/9C
Late filing of GSTR-9/9C attracts a late fee and interest:
Late Fee
- ₹100 per day under the CGST Act, 2017.
- ₹100 per day under the respective SGST/UTGST Act, 2017.
- This means a total of ₹200 per day (₹100 CGST + ₹100 SGST).
Maximum Late Fee
This daily late fee is subject to a maximum cap of 0.25% of the turnover in the respective State or Union Territory (0.25% each under CGST and SGST/UTGST, totaling 0.50% of turnover).
Reduced Late Fee (from FY 2022-23 onwards)
- For turnover up to ₹5 crore: ₹50 per day (₹25 CGST + ₹25 SGST), subject to a maximum of 0.04% of turnover (0.02% CGST + 0.02% SGST).
- For turnover more than ₹5 crore and up to ₹20 crore: ₹100 per day (₹50 CGST + ₹50 SGST), subject to a maximum of 0.04% of turnover (0.02% CGST + 0.02% SGST).
- For turnover more than ₹20 crore: ₹200 per day (₹100 CGST + ₹100 SGST), subject to a maximum of 0.50% of turnover (0.25% CGST + 0.25% SGST).
Interest
If there is any additional tax liability declared in the GSTR-9 and paid through DRC-03, interest at 18% per annum is applicable from the original due date of filing the monthly/quarterly returns till the date of payment.
Key Considerations and Best Practices for Filing Annual Returns
Prioritize Monthly/Quarterly Filings
It is crucial to have filed all your GSTR-1 and GSTR-3B (or GSTR-4 for composition dealers) for the entire financial year before attempting to file GSTR-9. The GSTR-9 primarily consolidates data from these returns.
Reconciliation is Key
- Sales Reconciliation: Reconcile your sales data as per your books of accounts with the GSTR-1s filed and the auto-populated data in GSTR-3B.
- ITC Reconciliation: Reconcile your Input Tax Credit as per your books with GSTR-2B and GSTR-3B. Ensure you have claimed all eligible ITC and reversed any ineligible ITC. Note that from FY 2023-24, ITC auto-population in GSTR-9 (Table 8A) will be based on GSTR-2B.
Correct Discrepancies
Any discrepancies or omissions found during reconciliation (e.g., undeclared sales, excess ITC claimed, or unrecorded purchases) should ideally be addressed by making amendments in the monthly/quarterly returns (GSTR-1, GSTR-3B) of the current financial year (i.e., by September 30th of the next financial year or the due date of filing the annual return, whichever is earlier).
Pay Additional Liability via DRC-03
If any additional tax liability is identified while preparing GSTR-9 (e.g., due to un-reported sales or excess ITC claim in previous returns), it should be paid using Form DRC-03. When making payment through DRC-03, select “Annual Return” in the dropdown.
No Amendment After Filing
Once GSTR-9 is filed, there is no provision to revise or amend it. Therefore, accuracy is paramount.
Maintain Proper Records
Keep meticulous records of all sales, purchases, ITC, and tax payments for the financial year to facilitate accurate annual return filing and future audits.
File your GST Annual returns with our experts. GST Annual Return filing is a comprehensive exercise that demands careful attention to detail and thorough reconciliation. It serves as an opportunity for taxpayers to review their entire year’s GST activities and rectify any errors that may have occurred during monthly/quarterly filings.