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Indirect Tax Laws · Returns

Other Returns: Composition, TDS/TCS, ISD and Annual Return (GSTR-4 to GSTR-9C)

Updated 5 October 2026 · Fact-checked

These are the special-category GST returns. Composition dealers file GSTR-4 annually, non-resident taxable persons GSTR-5, ISDs GSTR-6, TDS deductors GSTR-7 and e-commerce operators GSTR-8. Section 44 requires regular taxpayers to file GSTR-9, and GSTR-9C reconciliation applies above ₹5 crore. Solve by identifying the person, the form, the due date and the threshold.

Understand Other Returns: Composition, TDS/TCS, ISD and Annual Return

GSTR-1 and GSTR-3B are the returns for ordinary regular taxpayers. GST also has persons whose role is different: a composition dealer pays a flat rate, a non-resident is here for a short time, an ISD only distributes credit, a government deductor withholds tax, and an e-commerce operator collects tax. Each gets its own return. If you can match the person to the form, most questions on this topic are solved.

GSTR-4 is for a composition taxpayer. Tax is paid quarterly through statement-cum-challan CMP-08, due by the 18th after the quarter. GSTR-4 is now an annual return, due by 30 April after the financial year. GSTR-5 is the monthly return of a non-resident taxable person. GSTR-6 is the monthly return of an Input Service Distributor, showing credit received and distributed.

GSTR-7 is filed by a person who deducts tax at source under Section 51. GSTR-8 is filed by an e-commerce operator who collects tax at source under Section 52. Both are monthly, due by the 10th of the next month. The deductor or collector is only a conduit. The tax goes to the credit of the supplier or deductee.

Section 44 is the annual return provision. Every registered person must file an annual return, except an ISD, a person paying tax under Section 51 or 52, a casual taxable person and a non-resident taxable person. The form is GSTR-9, due by 31 December after the financial year. The ₹2 crore figure is not a standing rule in the Act. For specified financial years (from 2022-23 onwards), filing of GSTR-9 was exempted by notification for registered persons whose aggregate turnover is up to ₹2 crore. Check the notification for the year in the question before you say GSTR-9 is optional or mandatory.

GSTR-9C is a reconciliation statement. It is not a return. It reconciles the turnover and tax in your audited financial statements with GSTR-9, and the ITC claimed with the ITC available. It is self-certified. It applies where aggregate turnover exceeds ₹5 crore. The old requirement of certification by a CA or cost accountant was removed by the Finance Act, 2021, from 2020-21 onwards.

Key rules to remember

GSTR-4 (composition)
Annual return by 30 April after the financial year; tax paid quarterly through CMP-08 by the 18th after the quarter
A composition taxpayer does not file GSTR-1 or GSTR-3B. Do not call GSTR-4 quarterly.
GSTR-5 (non-resident taxable person)
Monthly, by the 13th of the next month, or within 7 days after the registration expires, whichever is earlier
The earlier-of rule matters for the final return.
GSTR-6 (Input Service Distributor)
Monthly, by the 13th of the next month
Filed even where there is nothing to distribute in the month, as a general rule. An ISD does not file GSTR-9.
GSTR-7 (TDS under Section 51)
Monthly, by the 10th of the next month; TDS 2% (1% CGST + 1% SGST, or 2% IGST) on the contract value
Applies to notified deductors such as government departments, local authorities and government agencies. The 2% is on the value of a supply under a contract above ₹2,50,000, excluding GST. The deductor issues GSTR-7A to the deductee.
GSTR-8 (TCS under Section 52)
Monthly, by the 10th of the next month; TCS 0.5% (0.25% CGST + 0.25% SGST, or 0.5% IGST) on net taxable supplies
Net value means taxable supplies made through the operator minus supplies returned. Supplies on which tax is payable under reverse charge are excluded from the net value of taxable supplies. The rate was 1% until it was reduced from 10 July 2024. Check the rate for the period asked.
Section 44: GSTR-9 annual return
By 31 December after the financial year; mandatory for all registered persons not excluded, except where a notification for the year exempts aggregate turnover up to ₹2 crore (notified for specified years from 2022-23 onwards)
Excluded: ISD, Section 51 and 52 persons, casual taxable person, non-resident taxable person. Composition taxpayers file GSTR-4 instead. The ₹2 crore exemption is year-specific, so check the notification for the year asked.
GSTR-9C reconciliation statement
Self-certified; required where aggregate turnover exceeds ₹5 crore; filed with GSTR-9
The threshold is a different figure from the ₹2 crore notified exemption limit for GSTR-9.
Late fee on GSTR-9 (Section 47)
₹200 per day (₹100 CGST + ₹100 SGST), capped at 0.5% of turnover in the State or Union territory
Notified relief reduces this for smaller taxpayers. Mention that the notification exists.

How to solve Other Returns: Composition, TDS/TCS, ISD and Annual Return questions

Use this order for any question on these returns. Each step takes a few seconds and keeps you from mixing up forms.

  1. 1Identify the person and their status: composition, non-resident, ISD, government deductor, e-commerce operator, or regular taxpayer.
  2. 2Name the return that matches that status: GSTR-4, 5, 6, 7, 8 or 9.
  3. 3State the period and the due date. Check the 10th, 13th, 18th, 30 April and 31 December carefully. Apply the earlier-of rule for a non-resident.
  4. 4For GSTR-9 or 9C, compute aggregate turnover (all-India, same PAN, including exempt supplies and exports, excluding taxes and inward supplies on reverse charge). Test it against the ₹2 crore notified exemption for that year and the ₹5 crore limit for 9C.
  5. 5Check the exclusions under Section 44: ISD, Section 51 and 52 persons, casual and non-resident taxable persons.
  6. 6Where 9C applies, describe it as a self-certified reconciliation of audited financial statements with GSTR-9, not as a return and not as a CA certification.
  7. 7Write the answer in provision, facts, conclusion form, and add late fee or consequence only if the question asks for it.

Quickest way: Person to Form to Date to Threshold

When to use it: Use for MCQs and 5 to 6 mark case scenarios where you must say which return applies and when it is due.

  1. Write the five anchor dates: 10th (GSTR-7, 8), 13th (GSTR-5, 6), 18th (CMP-08), 30 April (GSTR-4), 31 December (GSTR-9).
  2. Match the person: Composition = 4, Non-resident = 5, ISD = 6, TDS = 7, TCS = 8, Regular = 9.
  3. For turnover, remember 2 and 5: ₹2 crore is the notified GSTR-9 exemption limit for specified years (check the year), ₹5 crore is the limit for 9C.
  4. Check the Section 44 exclusion list before saying GSTR-9 is due.
  5. Conclude in one line: form, due date, and whether 9C applies.

Common mistakes in Other Returns: Composition, TDS/TCS, ISD and Annual Return

  • Saying GSTR-4 is a quarterly return for a composition dealer.

    Older rules had quarterly GSTR-4, and CMP-08 is quarterly, so the two get mixed.

    Fix: CMP-08 is quarterly payment (18th after the quarter). GSTR-4 is annual, due 30 April.

  • Treating GSTR-9C as a certified audit report by a CA.

    The pre-2020-21 position required a CA or cost accountant to certify it.

    Fix: It is now a self-certified reconciliation statement for turnover above ₹5 crore.

  • Applying the ₹5 crore limit to GSTR-9 or the ₹2 crore limit to GSTR-9C.

    Two thresholds with similar sound.

    Fix: Remember ₹2 crore as the year-specific notified GSTR-9 exemption limit and ₹5 crore as the GSTR-9C limit.

  • Treating the ₹2 crore GSTR-9 exemption as a permanent threshold in the Act.

    The same figure has been notified for several years, so it looks like a fixed rule.

    Fix: State that it is an exemption by notification for specified years and check the notification for the year asked.

  • Giving the same due date for GSTR-7, GSTR-8, GSTR-5 and GSTR-6.

    All are monthly returns.

    Fix: GSTR-7 and 8 fall on the 10th, GSTR-5 and 6 on the 13th. For GSTR-5 apply the earlier-of rule at expiry of registration.

  • Requiring GSTR-9 from an ISD, TDS deductor, casual or non-resident taxable person.

    Students read 'every registered person' and stop.

    Fix: Quote the Section 44 exclusions in every answer on GSTR-9 applicability.

  • Computing aggregate turnover only for one State or excluding exempt supplies and exports.

    Confusing aggregate turnover with State-wise turnover or taxable turnover.

    Fix: Take all-India turnover on the same PAN, include taxable, exempt and export supplies, exclude taxes and inward supplies on reverse charge.

Worked examples

Example 1

For the financial year, four registered persons have these figures: Alpha Ltd (regular taxpayer) aggregate turnover ₹1.8 crore; Beta Pvt Ltd (regular) ₹3.6 crore; Gamma Ltd (regular) ₹7.4 crore; Delta Traders (composition taxpayer) ₹70 lakh. Assume the notification exempting GSTR-9 for aggregate turnover up to ₹2 crore applies to that year. Advise on GSTR-9 and GSTR-9C for each.

Show the solution
  1. Section 44 requires GSTR-9 from registered persons other than the excluded categories. None of the four is excluded as an ISD, TDS or TCS person, or casual or non-resident taxable person.
  2. Alpha: turnover ₹1.8 crore is up to ₹2 crore. Under the assumed notified exemption, filing GSTR-9 is optional. GSTR-9C does not apply.
  3. Beta: ₹3.6 crore exceeds ₹2 crore, so GSTR-9 is mandatory. It does not exceed ₹5 crore, so GSTR-9C is not required.
  4. Gamma: ₹7.4 crore exceeds both limits. GSTR-9 is mandatory, and a self-certified GSTR-9C reconciliation statement must also be filed.
  5. Delta: a composition taxpayer files annual GSTR-4, due 30 April after the year, not GSTR-9. GSTR-9C does not apply.

Answer: Alpha: GSTR-9 optional (under the assumed notification), no 9C. Beta: GSTR-9 mandatory, no 9C. Gamma: GSTR-9 and self-certified GSTR-9C. Delta: GSTR-4 only.

Example 2

Rohan Ltd, a non-resident taxable person, was registered from 10 January to 25 February. It made taxable supplies in both months. A municipal corporation, a notified deductor, made payments in February under a ₹10,00,000 works contract (excluding GST) to a supplier. The supply under the contract is an intra-State supply. State the return and due date for each.

Show the solution
  1. Rohan is a non-resident taxable person, so it files GSTR-5 monthly.
  2. January return: the registration is still in force on 13 February. Seven days after expiry (4 March) is later than 13 February, so the earlier date, 13 February, applies.
  3. February return: registration expires on 25 February. Seven days after expiry is 4 March. The normal date is 13 March. The earlier date applies, so it is due by 4 March.
  4. The municipal corporation is a deductor under Section 51. The contract value ₹10,00,000 exceeds ₹2,50,000, so TDS is 2% = ₹20,000. Because the supply is intra-State, this is 1% CGST ₹10,000 plus 1% SGST ₹10,000. (Had it been an inter-State supply, it would be 2% IGST = ₹20,000.)
  5. The deduction is reported in GSTR-7 for February, due by 10 March. The deductor issues GSTR-7A to the supplier.

Answer: Rohan: GSTR-5 for January by 13 February, and for February by 4 March. Municipal corporation: GSTR-7 by 10 March, TDS ₹20,000 (₹10,000 CGST + ₹10,000 SGST for intra-State; ₹20,000 IGST if inter-State).

Exam tips

  • Questions often give a turnover figure and ask for GSTR-9 and 9C status. State the ₹2 crore notified exemption for the year and the ₹5 crore 9C limit, then compare.
  • Learn the Section 44 exclusions word for word. Examiners test them in short scenarios.
  • For due dates, check whether the question says an extension notification applies. If not, use the normal dates and state them clearly.
  • Differentiate GSTR-9 from GSTR-9C in a table-like list: return vs statement, filer vs self-certification, annual figures vs reconciliation with financial statements.
  • For TDS and TCS, give the rate, the base value, who files and the due date. Confirm the period for the TCS rate, and exclude reverse charge supplies from the TCS base.

Practice questions from Returns

Other Returns: Composition, TDS/TCS, ISD and Annual Return in other exams

The same ground in other exams, if you are preparing for more than one or want another angle on it.

Other Returns: Composition, TDS/TCS, ISD and Annual Return: frequently asked questions

What is the difference between GSTR-9 and GSTR-9C?

GSTR-9 is the annual return under Section 44 summarising the year's outward and inward supplies, ITC and tax paid. GSTR-9C is a reconciliation statement that compares your audited financial statements with GSTR-9. It is self-certified and required above ₹5 crore aggregate turnover.

Who must file GSTR-9 under Section 44?

Every registered person must file it except an ISD, a person paying tax under Section 51 or 52, a casual taxable person and a non-resident taxable person. Composition taxpayers file annual GSTR-4. For specified years from 2022-23 onwards, filing was exempted by notification up to ₹2 crore aggregate turnover, so check the notification for the year asked.

What is the due date of GSTR-4 for a composition dealer?

GSTR-4 is an annual return due by 30 April after the financial year. The tax itself is paid quarterly through CMP-08 by the 18th after each quarter.

What is the difference between GSTR-7 and GSTR-8?

GSTR-7 is filed by a notified person who deducts tax at source under Section 51. GSTR-8 is filed by an e-commerce operator who collects tax at source under Section 52. Both are monthly, due by the 10th of the next month.