GSTR-9C often gets confused with GSTR-9 — the two are related but not the same. GSTR-9 is the annual return every regular taxpayer above the exemption threshold files; GSTR-9C is a separate reconciliation statement that only kicks in once turnover crosses ₹5 crore, and it exists purely to catch mismatches between your books of accounts and what you actually declared in your GST returns through the year.
Quick Summary
- Applicable only above ₹5 crore aggregate annual turnover
- Due date FY 2025-26: 31 December 2026 — same date as GSTR-9
- Self-certified since FY 2020-21 — no CA/CMA signature required
Who Must File GSTR-9C
Applicability is based on aggregate annual turnover (PAN-wide, all GSTINs combined) for the financial year:
| Aggregate Turnover | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional (CBIC exemption continues) | Not applicable |
| ₹2 crore – ₹5 crore | Mandatory | Not applicable |
| Above ₹5 crore | Mandatory | Mandatory |
What Changed: It's Now Self-Certified
This is the single biggest practical change from the early GST years — the CA/CMA certification requirement was removed starting FY 2020-21. Today, you (the taxpayer) reconcile and certify GSTR-9C yourself, digitally signed, without a separate chartered accountant's audit sign-off. That doesn't mean the numbers matter less — the reconciliation itself still has to genuinely tie out, since it's filed on your own responsibility now, not shielded behind an external certifier.
Reconciliation Checklist — What Actually Needs to Tie Out
- Turnover as per audited financial statements vs turnover declared in GSTR-9/GSTR-1 for the year
- Taxable turnover reconciliation — adjustments for credit notes, debit notes, and unbilled revenue
- ITC as per books (purchase register) vs ITC actually claimed in GSTR-3B and available in GSTR-2B
- Tax paid — cash ledger + credit ledger utilisation matched against total tax liability
- HSN-wise summary of outward supplies
- Any tax payable on reverse charge (RCM) that was missed during the year
Why Mismatches Happen (and How to Avoid Them)
Common Reconciliation Gaps
Most mismatches trace back to timing differences, not real errors: a credit note issued in April for a March sale, ITC claimed a month later than the purchase invoice date, or an RCM liability on an import of service that never got booked. The fix isn't complicated — a monthly (not annual) reconciliation habit through the year means GSTR-9C in December is a formality, not a scramble.
If your turnover has crossed ₹5 crore this year, GSTR-9C is not optional — and because it's self-certified now, the responsibility for a clean reconciliation sits entirely with you. Rajput Lalit & Associates handles GSTR-9 and GSTR-9C reconciliation end-to-end, along with the monthly bookkeeping that makes year-end reconciliation painless. See our GSTR-9 Annual Return guide for the base return, or book a free consultation.
Frequently Asked Questions
Is GSTR-9C compulsory for everyone above ₹2 crore turnover?
No. GSTR-9 (the annual return) is mandatory above ₹2 crore. GSTR-9C (the reconciliation statement) only becomes mandatory once aggregate turnover crosses ₹5 crore. Between ₹2 crore and ₹5 crore, you file GSTR-9 alone.
Do I still need a CA to sign off on GSTR-9C?
Not anymore. Since FY 2020-21, GSTR-9C is self-certified by the taxpayer using a digital signature or Aadhaar e-sign — the earlier requirement for a separate CA/CMA certification was removed. Many businesses still choose to have a professional prepare and review it, but the legal sign-off is now yours.
What is the due date for GSTR-9C for FY 2025-26?
31 December 2026 — the same date as GSTR-9 for the same financial year, since both are filed together.
What happens if I file GSTR-9C late?
A late fee applies under Section 47(2) of the CGST Act, capped at 0.25% of turnover in the relevant state/UT (combined with the GSTR-9 late fee cap, not an additional separate cap on top). There is no advantage to delaying — the earlier a mismatch is caught, the easier it is to explain or correct.
Can GSTR-9C be revised after filing?
No, GST law does not currently allow revision of a filed GSTR-9C. This is exactly why the reconciliation checklist matters — get it right before filing, since there's no correction window afterward.
This article reflects the GSTR-9C rules and turnover thresholds as commonly understood as of September 2026, based on CBIC notifications and circulars (including Notification 08/2025-Central Tax on late-fee relief for older years). Thresholds and forms are subject to periodic CBIC changes — please verify your specific applicability with a professional before filing.