OBJECTIVE Goods and Services Tax (GST) is an Indirect Tax levied in India introduced in July 2017 which was one of the most important reforms in the Indian Economy. There are various periodic compliance requirements and filings under GST. Under the Act, certain registered persons are required to carry out GST Audit and in such cases a reconciliation statement in Form GSTR 9C has to be filed. In this webinar, we shall analyse and understand the said form under the Act.

1. Reconciliation Statement
and Certification under
GST – Form GSTR 9C
CA Jugal Narendra Gala

2. 2
Credits and Acknowledgments
Harish Kumar R

3. Legends used in the Presentation
3
DTA Domestic Tariff Area
FY Financial Year
GSTIN Goods and Services Tax Identification Number
ITC Input Tax Credit
SEZ Special Economic Zone

4. Presentation Schema
4
Introduction Annual Return Form GSTR 9C
Basic Details
Reconciliation of
Turnover
Reconciliation of Tax
Paid
Reconciliation of Input
Tax Credit
Auditor’s
Recommendation on
Non-reconciliation
Certification

5. Introduction
5
The Goods and Services Tax (GST) is a trust-based taxation regime where a taxpayer is required to self-
assess his tax liability, pay taxes and file returns
GST being in the nature of a self-assessment tax, audit procedures are introduced for error
correction and ensuring proper compliance
GSTR 9C shall be filed along with Annual Return (GST-9), in case of registered persons liable to GST
Audit

6. Annual Return – Sec 44
6
Every Registered person, other than
Input Service Distributor
Person paying tax under Sec 51 or 52 (Prescribes to deduct
tax or to collect tax)
Casual Taxable Person (CTP)
Non-Resident Taxable Person
Shall furnish an annual return for every FY electronically in such form and manner as may be prescribed on or before the
31st day of December following the end of such FY
-Every registered person who is required to get his accounts audited in accordance with the provisions of Sec 35(5)
-shall furnish electronically, the annual return
-along with a copy of the audited annual accounts and a reconciliation statement within the same due date
Every registered person whose turnover during a financial year exceeds Rs. 2 crores shall get his
accounts audited by a Chartered Accountant or a Cost Accountant
Sec 35(5)
Form GSTR 9
Form GSTR 9C

7. 7
Form GSTR 9C
Form GSTR 9C is the form for filing reconciliation statement when the registered person is required to get his
accounts audited
Form GSTR 9C is divided into 2 Parts
Part A Part B
Part I Part II Part III Part IV Part V
Basic Details Auditor's
recommendation
for non-
reconciliation
Reconciliation
of turnover
declared in
audited Annual
Financial
Statement with
turnover
declared in
Annual Return
(GSTR9)
Reconciliation
of tax paid
Reconciliation
of Input Tax
Credit
Certification

8. GSTR 9C – Part A

9. “
9
Part I – Basic Details

10. 10
Basic Details
Part I seeks to capture the following basic details of registered person
Financial Year GSTIN Legal Name and Trade Name
Auto populatedKey in PAN based
15 digit GSTIN
Disclose the Financial Year to
which the Reconciliation
Statement in Part A relates to

11. “
11
Part II - Reconciliation of Turnover Declared
in Audited Annual Financial Statement with
Turnover Declared in Annual Return (GSTR9)

12. 12
Part II – Reconciliation of Turnover
This Part seeks to reconcile the gross turnover in terms of audited financial statements with the turnover
declared in the annual return
Under this part all the streams of the income, whether or not liable for GST, needs to be duly
reconciled
Auditor may require the break up of the audited financial statements at GSTIN level for reporting in
GSTR-9C
This part is further divided into
Reconciliation
of Gross
Turnover
Reasons for un-
reconciled difference
in Taxable Turnover
Reconciliation of
Taxable Turnover
Reasons for un-
reconciled difference in
Annual Gross turnover
The Taxable value of all taxable supplies (excluding the value of inward supplies on which tax is payable by a person on reverse
charge basis), exempt supplies, exports of goods or services or both and inter-State supplies of persons having the same PAN, to be
computed on all India basis but excludes central tax, State tax, Union territory tax, integrated tax and cess
Taxable Turnover

13. 13
Table 5 – Reconciliation of Gross Turnover
S.No Description
A
Turnover (including exports) as per Audited Financial Statement for the State /
UT (For multi-GSTIN units under same PAN, the turnover shall as be derived from
the Audited Annual Financial Statements )
B Unbilled revenue at the beginning of the Financial Year
C Unadjusted advances at the end of the Financial Year
D Deemed Supply under Schedule I
E
Credit Notes issued after the end of the financial year but reflected in the annual
return
F
Trade Discounts accounted for in the audited Annual Financial Statement but are
not permissible under GST
G Turnover from April 2017 to June 2017
H Unbilled revenue as at the end of the Financial Year
I Unadjusted Advances as at the beginning of the Financial Year
Under this table, the auditor has to reconcile the Gross Turnover of the registered person
Value of all advances for which GST
has not been paid but the same has
been recognized as revenue
The turnover as per the audited Annual
Financial Statement shall be declared here
Unbilled revenue recorded on the basis of
accrual system of accounting in the last FY
and was carried forward to the current FY
Value of all advances for which GST has been
paid but has not been recognized as revenue
Aggregate value of deemed supplies under
Schedule I of the CGST Act, 2017
Aggregate value of credit notes which were
issued after 31st of March but before filing
annual return
Unbilled revenue recorded on the basis of
accrual system of accounting during the
current FY, but GST was not payable on such
revenue in the same FY shall be declared here.

14. Contd.
14
S.No Description
J
Credit notes accounted for in the audited Annual Financial Statement but
are not permissible under GST
K Adjustments on account of supply of goods by SEZ units to DTA Units
L Turnover for the period under composition scheme
M Adjustments in turnover under Sec 15 and rules thereunder
N Adjustments in Turnover due to foreign exchange fluctuation
O Adjustment in Turnover due to reasons not listed above
P
Annual Turnover after adjustments as above(A+B+C+D-E+F-G-H-I+J-K-
L+M+N+O)
Q Turnover as declared in Annual return (GSTR9)
R Un-Reconciled turnover (Q- P)
Aggregate value of all goods supplied by SEZs
to DTA units for which the DTA units have
filed bill of entry shall be declared here
Sec 15 provides that the transaction value
would be the basis for computation of tax
only when the price is paid or payable, and
such price is the sole consideration for the
supply and the supplier and the recipient are
not related
The difference would be auto generated

15. Table 6 - Reasons for Un - Reconciled
difference in Annual Gross turnover
15
This table seeks reasons for non-reconciliation between the annual turnover declared in the audited
Annual Financial Statement and turnover as declared in the Annual Return (GSTR 9)
The data which has to be filled up in this table is a conclusion drawn up on account of a
Reconciliation for the turnover as per Books of Accounts compared with Annual Return
The Auditor shall make a reference for reconciliation of the turnover related adjustments based on
the information available in the Notes to Accounts and any special adjustments caused by reference
to other statutory requirements
Transaction reported in a Delivery challan during the FY for supply on sale or approval
basis beyond a period of six months shall be deemed to be a supply under GST
However, that may not be a sale for revenue recognition in the Books
Example

16. Table 7 - Reconciliation of Taxable Turnover
16
S.No Description
A
Annual Turnover after adjustments [from 5(P) above]
B
Value of Exempted, Nil Rated (0% GST e.g. Salt, jaggery), Non-GST
Turnover, No supply turnover
C
Zero rated supplies without payment of tax (e.g. supply to SEZ)
D
Supplies on which tax is to be paid by the recipient on reverse charge
basis
E
Taxable turnover as per adjustments above (A-B-C-D)
F
Taxable turnover as per liability declared in Annual Return (GSTR9)
G
Un-reconciled Taxable Turnover (F-E)
Auto-populated
Value of zero-rated supplies (including supplies to
SEZs) on which tax is not paid shall be declared here
Reasons for non-reconciliation between adjusted
annual taxable turnover and taxable turnover shall
be additionally declared here
The table provides for reconciliation of taxable turnover from the audited annual turnover after
adjustments with the taxable turnover declared in Annual Return
Declare the value of reverse charge supplies on
which tax is to be paid by the recipient (not the
dealer)
Taxable turnover as declared in Table 4N of the
Annual Return (GSTR9) shall be declared here

17. Table 8 - Reasons for Un - Reconciled difference
in Taxable Turnover
17
This table seeks reasons for non-reconciliation between adjusted annual taxable turnover
as derived from Table 7E above and the taxable turnover declared in Table 7F
S.No. Reasons
A
For e.g.: Outward taxable supplies of Rs. 1 lakh not
shown in GST returns.

18. “
18
Part III - Reconciliation of tax Paid

19. Reconciliation of Tax Paid
19
The Part III of the Form GSTR 9C requires an Auditor to reconcile
-the rate wise liability of tax,
-total amount payable thereon with tax actually paid as declared in Annual Return and
-recommendation of additional tax payable
This is further bifurcated into :
Reconciliation of rate wise Liability
and amount payable thereon
Reasons for un-reconciled
payment of amount
Additional amount of tax,
Interest, Late Fees, Penalty and
Others payable but not paid

20. Table 9 - Reconciliation of Rate Wise Liability
and Amount Payable
20
S.No Description
Taxable
Value
Tax
Payable
A 5%
B 5% (RC)
C 12%
D 12% (RC)
E 18%
F 18% (RC)
G 28%
H 28% (RC)
I 3%
J 0.25%
The relevant Table 9 requires the Auditor to provide details of taxable value along with
Gross tax Liability booked by the Registered Person
S.No Description
Taxable Value
Tax Payable
K 0.10%
L Interest
M Late Fee
N Penalty
O Others
P
Total amount to be paid as
per tables above (A to O)
Q
Total amount paid as
declared in Annual Return
(GSTR 9)
R Un-reconciled payment (Q-P)

21. Table 10 - Reasons for Un-Reconciled
Payment of Amount
21
This table seeks reasons for non-reconciliation between payable / liability declared in Table
9P and the amount payable in Table 9Q
The table mandates an Auditor to identify and disclose the reasons for un-reconciled
payment of amount of tax, Interest, Penalty, Cess and Others
It has to be ensured that for whole amount of non-reconciliation reported in Table 9, the
reason wise quantification of same is done in Table 10

22. Table 11 - Additional amount Payable
but not Paid
22
S.No Description
A 5%
B 12%
C 18%
D 28%
E 3%
F 0.25%
G 0.10%
H Interest
I Late Fee
J Penalty
K Others
Here, the amount of tax, interest, penalty, late fees and
other Dues which are payable but not actually paid as
declared in Annual Return in GSTR 9 are to be reported
with rate wise bifurcation

23. “
23
Part IV - Reconciliation of
Input Tax Credit (ITC)

24. Reconciliation of ITC
24
Part IV consists of reconciliation of Input Tax Credit (ITC). This is further divided into:
Reconciliation of Net
Input Tax Credit
Reconciliation of ITC
declared in Annual
Return with ITC
availed on Expenses
as per Audited
Annual Financial
Statement or Books
of Account
Un-reconciled
ITC
Reasons for Un -
reconciled difference
in ITC

25. Table 12 - Reconciliation of Net Input Tax
Credit (ITC)
25
S.No Description
A
ITC availed as per audited Annual Financial Statement for the State/ UT
(For multi-GSTIN units under same PAN, this should be derived from
books of accounts)
B ITC booked in earlier Financial Years claimed in current Financial Year
C
ITC booked in current Financial Year to be claimed in subsequent
Financial Years
D
ITC availed as per audited financial statements or books of accounts (A +
B - C)
E ITC claimed in Annual Return (GSTR9)
F Un-reconciled ITC (E-D)
ITC availed (after reversals) as
per the audited Annual Financial
Statement shall be declared here
Any ITC which was booked in the audited Annual
Financial Statement of earlier FY but availed in the
ITC ledger in the FY for which the reconciliation
statement is being filed for shall be declared here
Any ITC which has been booked in the audited
Annual Financial Statement of the current FY but
the same has not been credited to the ITC ledger
for the said FY
Reversal of ITC means the credit of inputs utilised earlier would now be added to the output tax liability, effectively
nullifying the credit claimed earlier

26. Table 13 – Un-reconciled ITC
26
This table seeks reasons for non-reconciliation of ITC as per audited Annual Financial
Statement or books of account and the net ITC availed in the Annual Return (GSTR9)
S.No. Description
A
For e.g.: ITC of Rs. 10,000 reversed in GST
returns but not in books of accounts.
Hence there might be a variance to that
extent.

27. Table 14 - Reconciliation of ITC declared in Annual
Return with ITC availed on Expenses as per Audited
Annual Financial Statement or Books of Account
27
S.No Description Value
Amount of Total
ITC
Amount of
eligible ITC
availed
A Purchases
B Freight / Carriage
C Power and Fuel Costs
D Imported goods (Including received from SEZ)
E Rent and Insurance Expense
F
Goods lost, stolen, destroyed, written off or
disposed of by way of gift or free samples
G Royalties
H Employee's Cost (Salaries, Wages, Bonus etc .)
This table is for reconciliation of ITC declared in the Annual Return (GSTR9) against the expenses
booked in the audited Annual Financial Statement or books of account

28. Contd.
28
S.No. Description Value
Amount of
Total ITC
Amount of
eligible ITC
availed
I Conveyance charges
J Bank Charges
K Entertainment charges
L
Stationery Expenses (including postage
etc.)
M Repair and Maintenance
N Other Miscellaneous expenses
O Capital goods
P Any other expense 1
Q Any other expense 2
R
Total amount of eligible ITC availed (A to
Q)*
S ITC claimed in Annual Return (GSTR9)
T Un-reconciled ITC (S-R)*

29. Table 15 - Reasons for Un - Reconciled
difference in ITC
29
This table seeks reasons for non-reconciliation between ITC availed on the
various expenses declared in Table 14R (Total amount of eligible ITC availed)
and ITC declared in Table 14S (ITC claimed in GSTR 9)
S.No. Reasons
A
For e.g.: ITC availed in returns but booked
as expense in books (or) ineligible ITC now
being identified by auditor

30. Table 16 - Tax payable on Un-reconciled
difference in ITC
30
Any amount which is payable due to reasons specified in Table 13 (Un-reconciled ITC ) and Table
15 (Reasons for Un - Reconciled difference in ITC) above shall be declared here
S.No Description
A Central Tax
B State tax /UT tax
C Integrated Tax
D Cess
E Interest
F Penalty

31. “
31
Part V - Auditor’s
Recommendation on
additional liability due
to non-reconciliation

32. Auditor’s Recommendation on Additional
Liability due to Non-Reconciliation
32
This consists of the auditor’s recommendation on the additional liability to be discharged by the
taxpayer due to non-reconciliation of turnover or non-reconciliation of input tax credit
S.No Description
A 5%
B 12%
C 18%
D 28%
E 3%
F 0.25%

33. Contd.
33
S.No. Description
G 0.10%
H Input tax credit
I Interest
J Late Fee
K Penalty
L
Any other amount paid for supplies not included in
annual return (GSTR9)
M Erroneous refund to be paid back)
N Outstanding demands to be settled
O Other

34. GSTR 9C – Part B

35. Part B - Certification
35
This part provides the format of certification by the auditor
It has two parts Module I, Module II and either one of them shall be applicable
Module I applies for certification in cases where the reconciliation statement (FORM GSTR 9C) is
drawn up by the person who had conducted the audit and GST audit certification
Module II applies for certification in cases where the reconciliation statement in (GSTR 9C) is drawn
up by a person other than the person who had conducted the audit of the accounts

36. Certification in Cases where the Reconciliation
Statement (GSTR 9C) is drawn up by the Person who
had conducted the Audit
36

37. Contd.
37

38. Certification where the Reconciliation Statement is
drawn up by a Person Other Than the Person who had
Conducted the Audit of the Accounts
38

40. 40
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