Annual GST compliance is an important responsibility for registered taxpayers in India. Apart from periodic GST returns such as GSTR-1 and GSTR-3B, certain taxpayers are also required to file annual returns and reconciliation statements.
One such important compliance is Form GSTR-9C, which serves as a reconciliation statement between the taxpayer's GST returns and audited financial statements. Although the mandatory GST audit by a Chartered Accountant has been removed, eligible taxpayers are still required to file GSTR-9C on a self-certified basis.
This article explains the applicability, turnover threshold, filing requirements, and key compliance considerations relating to GSTR-9C for FY 2026-27.
GSTR-9C is a reconciliation statement that reconciles:
The objective is to identify discrepancies between GST filings and books of accounts.
Originally, taxpayers crossing a specified turnover threshold were required to undergo a GST audit conducted by a Chartered Accountant or Cost Accountant.
However, the requirement for certification by an external professional has been removed. Taxpayers now file GSTR-9C on a self-certification basis where applicable.
A registered person whose aggregate turnover exceeds ₹5 crore during the financial year is generally required to file:
and
for the relevant financial year.
Aggregate turnover includes:
It is computed on an all-India PAN basis and excludes GST components such as CGST, SGST, IGST, and Compensation Cess.
| Aggregate Turnover | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 Crore | Optional (subject to notifications) | Not Applicable |
| More than ₹2 Crore and up to ₹5 Crore | Generally Applicable | Not Applicable |
| Above ₹5 Crore | Applicable | Applicable |
Taxpayers should always verify the latest notifications and circulars issued by the Government before filing.
The requirement for certification by a Chartered Accountant or Cost Accountant has been removed.
Currently:
The responsibility for accuracy remains with the taxpayer.
The reconciliation statement includes:
Comparison between:
Verification of:
Comparison of:
Any additional tax liability identified during reconciliation must be reported and discharged.
Accounting standards and GST provisions may recognize revenue differently.
Timing differences often create turnover mismatches.
Year-end accounting entries may not be reflected in GST returns.
Differences between books and GST returns are common due to:
GSTR-9C is generally filed along with GSTR-9.
The due date is typically:
unless extended through notification.
For FY 2026-27, taxpayers should monitor official notifications for any extension.
Failure to file GSTR-9C where applicable may result in:
✔ Reconcile turnover as per books and GST returns.
✔ Match GSTR-1 with GSTR-3B.
✔ Verify annual sales figures.
✔ Reconcile Input Tax Credit.
✔ Verify GST payable and GST paid.
✔ Review debit notes and credit notes.
✔ Identify and rectify reporting errors.
✔ Ensure consistency with audited financial statements.
Aggregate turnover must be calculated across all GST registrations under the same PAN.
These differences often lead to notices.
Failure to reconcile ITC may result in tax demands.
Periodic reconciliations throughout the year significantly reduce compliance risks.
GSTR-9C remains an important annual GST compliance requirement for taxpayers whose aggregate turnover exceeds ₹5 crore during FY 2026-27. Although the mandatory GST audit certification has been removed, taxpayers are still responsible for filing an accurate self-certified reconciliation statement. Timely reconciliation of turnover, tax liability, and Input Tax Credit can help businesses avoid notices, penalties, and future litigation while ensuring complete GST compliance.