GST audit threshold — Who needs GSTR-9C in FY 2026-27

GST audit threshold — Who needs GSTR-9C in FY 2026-27

Introduction

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.


What is GSTR-9C?

GSTR-9C is a reconciliation statement that reconciles:

  • Turnover reported in GST returns;
  • Tax paid under GST;
  • Input Tax Credit (ITC) claimed; and
  • Figures reported in the financial statements.

The objective is to identify discrepancies between GST filings and books of accounts.


What is the GST Audit?

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.


Who is Required to File GSTR-9C in FY 2026-27?

A registered person whose aggregate turnover exceeds ₹5 crore during the financial year is generally required to file:

GSTR-9 (Annual Return)

and

GSTR-9C (Reconciliation Statement)

for the relevant financial year.


Understanding Aggregate Turnover

Aggregate turnover includes:

  • Taxable supplies
  • Exempt supplies
  • Exports
  • Inter-state supplies
  • Supplies made on behalf of principals

It is computed on an all-India PAN basis and excludes GST components such as CGST, SGST, IGST, and Compensation Cess.


Applicability of GSTR-9C

Aggregate TurnoverGSTR-9GSTR-9C
Up to ₹2 CroreOptional (subject to notifications)Not Applicable
More than ₹2 Crore and up to ₹5 CroreGenerally ApplicableNot Applicable
Above ₹5 CroreApplicableApplicable

Taxpayers should always verify the latest notifications and circulars issued by the Government before filing.


Is Chartered Accountant Certification Required?

No

The requirement for certification by a Chartered Accountant or Cost Accountant has been removed.

Currently:

GSTR-9C is filed on a Self-Certified Basis

The responsibility for accuracy remains with the taxpayer.


Information Reported in GSTR-9C

The reconciliation statement includes:

Turnover Reconciliation

Comparison between:

  • Financial statements
  • GST returns

Tax Liability Reconciliation

Verification of:

  • Output tax payable
  • Tax paid through GST returns

Input Tax Credit Reconciliation

Comparison of:

  • ITC claimed in GST returns
  • ITC recorded in books

Additional Liability

Any additional tax liability identified during reconciliation must be reported and discharged.


Common Reasons for Differences in GSTR-9C

Revenue Recognition Differences

Accounting standards and GST provisions may recognize revenue differently.

Credit Notes Issued After Year-End

Timing differences often create turnover mismatches.

Unrecorded Adjustments

Year-end accounting entries may not be reflected in GST returns.

ITC Reconciliation Issues

Differences between books and GST returns are common due to:

  • Vendor non-compliance
  • Reversals
  • Ineligible credits

Due Date for Filing GSTR-9C

GSTR-9C is generally filed along with GSTR-9.

The due date is typically:

31st December following the end of the relevant financial year

unless extended through notification.

For FY 2026-27, taxpayers should monitor official notifications for any extension.


Consequences of Non-Filing

Failure to file GSTR-9C where applicable may result in:

  • GST notices
  • Scrutiny proceedings
  • Demand for reconciliation explanations
  • Additional tax liability
  • Interest and penalties under applicable GST provisions

Practical Checklist Before Filing GSTR-9C

✔ 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.


Common Mistakes Made by Taxpayers

Ignoring PAN-Level Turnover

Aggregate turnover must be calculated across all GST registrations under the same PAN.

Mismatch Between GSTR-1 and GSTR-3B

These differences often lead to notices.

Incorrect ITC Reporting

Failure to reconcile ITC may result in tax demands.

Waiting Until Year-End

Periodic reconciliations throughout the year significantly reduce compliance risks.


Benefits of Timely GSTR-9C Filing

  • Improved GST compliance
  • Reduced litigation risk
  • Early identification of discrepancies
  • Better financial reporting accuracy
  • Lower chances of departmental scrutiny

Conclusion

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.