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Annual Return GSTR-9 and Reconciliation GSTR-9C

Updated 5 October 2026 · Fact-checked

GSTR-9 is the annual return under section 44 of the CGST Act, filed by regular registered taxpayers by 31 December after the financial year. GSTR-9C is a self-certified reconciliation statement of the annual return with the audited financial statements, needed when aggregate turnover exceeds ₹5 crore. Check the turnover, apply the thresholds, then state the due date.

Understand Annual Return GSTR-9 and Reconciliation GSTR-9C

Every month or quarter you file GSTR-1 and GSTR-3B. Mistakes creep in: invoices missed, credit wrongly claimed, amendments made late. The annual return (GSTR-9) is the one place where a taxpayer sums up the whole financial year and corrects the picture. It is filed under section 44 of the CGST Act, 2017.

Not everyone files it. Section 44 excludes an Input Service Distributor, a casual taxable person, a non-resident taxable person, and a person paying tax under section 51 (tax deducted at source) or section 52 (tax collected at source). A composition taxpayer is not excluded by section 44 itself. Its annual return is Form GSTR-4 under Rule 62, which replaced GSTR-9A from FY 2019-20, so it does not file GSTR-9. Also, small taxpayers get a relief by notification: a registered person whose aggregate turnover in the financial year is up to ₹2 crore need not file GSTR-9. Treat this as a notified relief, so read the question for the year and facts given.

GSTR-9C is different. Earlier, a CA or cost accountant had to audit and certify it. Since 2020-21 the audit requirement has gone. Now a registered person whose aggregate turnover exceeds ₹5 crore files a self-certified reconciliation statement along with GSTR-9. It reconciles the turnover, tax paid and input tax credit in the annual return with the audited annual financial statements, and explains the differences.

GSTR-9 has six parts. In brief: basic details; outward and inward supplies declared during the year; ITC; tax paid; transactions of the previous financial year declared in returns filed from April to November of the following financial year (or up to the date of filing the annual return for the previous financial year, whichever is earlier); and other information such as demands, refunds, late fee and HSN summary. Figures come from GSTR-1 and GSTR-3B already filed. GSTR-9 cannot be revised after filing.

GSTR-10 is the final return. It is filed under section 45 and Rule 81 by a registered person whose registration is cancelled or surrendered, other than an Input Service Distributor, a person paying TDS or TCS, or a non-resident taxable person. A casual taxable person and a composition taxpayer whose registration is cancelled or surrendered are covered and file it. It closes the tax account of that person.

Key rules to remember

Who files GSTR-9 (section 44)
Every registered person, except an ISD, a casual taxable person, a non-resident taxable person, and a person paying tax under section 51 or section 52
A composition taxpayer is not excluded by section 44 itself. Its annual return is Form GSTR-4 under Rule 62, which replaced GSTR-9A from FY 2019-20.
GSTR-9 small taxpayer relief
Aggregate turnover ≤ ₹2 crore in the financial year → filing exempt (by notification)
Check the year in the question. The relief is by notification, not part of section 44 itself.
GSTR-9C applicability
Aggregate turnover > ₹5 crore → self-certified reconciliation statement in GSTR-9C
No CA/CMA audit or certification is needed now. At exactly ₹5 crore it is not required.
Due date of GSTR-9 and GSTR-9C
31 December following the end of the financial year
For 2026-27 this is 31 December 2027. The Government can extend it by notification.
Late fee for GSTR-9 (section 47(2))
₹200 per day (₹100 CGST + ₹100 SGST) subject to a maximum of 0.25% of turnover in the State or UT under each Act (0.5% in total)
Reduced slabs apply by notification. Aggregate turnover up to ₹5 crore: ₹50 per day (₹25 CGST + ₹25 SGST), cap 0.04% of turnover in the State or UT (0.02% + 0.02%). Above ₹5 crore up to ₹20 crore: ₹100 per day (₹50 + ₹50), cap 0.08% (0.04% + 0.04%). Above ₹20 crore, the standard ₹200 per day and the 0.25% per Act cap (0.5% in total) apply. Use the slabs only if the question gives them.
GSTR-10 final return (section 45, Rule 81)
Due within 3 months of the date of cancellation or the date of the cancellation order, whichever is later
Rule 81 requires it from a registered person whose registration is cancelled or surrendered, other than an ISD, a person paying TDS/TCS or a non-resident taxable person. Casual taxable persons and composition taxpayers are covered.
Aggregate turnover (section 2(6))
Aggregate value of all taxable supplies (excluding inward supplies on reverse charge), exempt supplies, exports of goods or services, and inter-State supplies, of persons having the same PAN, computed on an all-India basis; excludes CGST, SGST, IGST and cess, and excludes non-taxable supplies
Exempt supplies are included, but non-taxable supplies, such as supplies of alcohol for human consumption, are not. Inter-State supplies are counted within these categories, not added again. It covers supplies made by the person, not purchases. Count each supply once. Use this figure, not the State turnover, for the thresholds.

How to solve Annual Return GSTR-9 and Reconciliation GSTR-9C questions

Use this order for any question on GSTR-9, GSTR-9C or GSTR-10. It keeps your answer in the provision-facts-conclusion format.

  1. 1Identify the type of person: regular, composition, ISD, casual, non-resident, TDS or TCS deductor. If the person is excluded under section 44, say so and stop. If the person is a composition taxpayer, say that its annual return is GSTR-4 under Rule 62 (replacing GSTR-9A from FY 2019-20), not GSTR-9.
  2. 2Compute aggregate turnover for the financial year on an all-India basis for the same PAN: all taxable supplies (excluding inward supplies on reverse charge), exempt supplies, exports of goods or services, and inter-State supplies. Count each supply once, so do not add inter-State supplies again if already included. Exclude taxes and non-taxable supplies.
  3. 3Compare with ₹2 crore for GSTR-9 relief and with ₹5 crore for GSTR-9C. State clearly that the limit is 'exceeds' for 9C.
  4. 4State the return required: GSTR-9 alone, GSTR-9 with GSTR-9C, or none. Mention that 9C is self-certified.
  5. 5Fix the due date: 31 December after the financial year. For cancellation cases, use the section 45 three-month rule for GSTR-10 (this covers a composition taxpayer too), and check that the person is not an ISD, TDS/TCS deductor or non-resident taxable person.
  6. 6If there is delay, work out days late. Apply ₹200 per day only if turnover is above ₹20 crore or the question says standard rate; otherwise use the reduced slab given (₹50 per day up to ₹5 crore, ₹100 per day from ₹5 crore to ₹20 crore). Then check the cap (0.25% of turnover in the State or UT under each Act at the standard rate). Show both amounts.
  7. 7Write a one-line conclusion that names the return, the due date and the late fee, if any.

Quickest way: Threshold ladder for MCQs and short answers

When to use it: Use for MCQs on applicability and for the first two lines of a written answer.

  1. Think of three rungs: up to ₹2 crore, above ₹2 crore up to ₹5 crore, above ₹5 crore.
  2. First rung: GSTR-9 not compulsory (notified relief). Second rung: GSTR-9 only. Third rung: GSTR-9 plus GSTR-9C.
  3. Cross out options that mention a CA audit or certification for GSTR-9C. It is self-certified now.
  4. Cross out options with a date other than 31 December unless the question mentions an extension.
  5. For late fee, multiply days × the per-day rate, then compare with the cap on turnover and take the lower amount. Standard rate is ₹200 a day with a cap of 0.25% of turnover in the State or UT under each Act (0.5% in total). Reduced slabs: ₹50 a day (cap 0.04%) up to ₹5 crore, and ₹100 a day (cap 0.08%) from ₹5 crore to ₹20 crore.
  6. In a written answer, give the section (44, 45 or 47), the facts with figures, and a one-line conclusion to earn step marks.

Common mistakes in Annual Return GSTR-9 and Reconciliation GSTR-9C

  • Saying GSTR-9C needs a certificate from a Chartered Accountant.

    Older material and notes from before 2020-21 required a CA audit of the reconciliation statement.

    Fix: Write that GSTR-9C is a self-certified reconciliation statement, filed where aggregate turnover exceeds ₹5 crore.

  • Applying GSTR-9C at exactly ₹5 crore.

    Students read the limit as 'up to and including'.

    Fix: The law says 'exceeds ₹5 crore'. At ₹5 crore exactly, only GSTR-9 is required.

  • Requiring a composition taxpayer to file GSTR-9.

    Composition dealers are registered persons, so students assume section 44 treats them like regular persons.

    Fix: Section 44 does not exclude a composition taxpayer, but its annual return is Form GSTR-4 under Rule 62 (replacing GSTR-9A from FY 2019-20). Mention this in the first line of your answer.

  • Using State-wise turnover for the thresholds, or adding inter-State supplies again on top of taxable and exempt supplies.

    Returns are filed per GSTIN, so students use the GSTIN turnover. Others treat inter-State supplies as a separate extra item and count them twice.

    Fix: Use aggregate turnover on an all-India basis for the same PAN: all taxable supplies (excluding inward supplies on reverse charge), exempt supplies, exports and inter-State supplies, excluding taxes and non-taxable supplies. Count each supply once.

  • Counting late fee without the cap, or counting only the CGST half.

    Students remember ₹100 per day and forget that SGST adds another ₹100.

    Fix: Total ₹200 per day at the standard rate. Then compare with the cap of 0.25% of turnover in the State or UT under each Act (0.5% in total) and take the lower. Remember that reduced slabs apply by notification: ₹50 per day with 0.04% cap up to ₹5 crore, and ₹100 per day with 0.08% cap from ₹5 crore to ₹20 crore.

  • Applying the standard ₹200 per day late fee to every taxpayer.

    Students learn the section 47(2) rate and miss the notified reduced slabs.

    Fix: Reduced per-day fees and caps apply by notification to taxpayers with aggregate turnover up to ₹20 crore (two slabs: up to ₹5 crore, and ₹5 crore to ₹20 crore). The standard ₹200 per day and the 0.25% per Act cap (0.5% in total) apply above that.

  • Requiring GSTR-10 from every person whose registration ends, including an ISD, a TDS/TCS deductor or a non-resident taxable person, or leaving out a casual taxable person.

    Students read section 45 as covering every cancellation and forget the exclusions in Rule 81. Some also assume a casual taxable person is excluded because it is excluded from GSTR-9.

    Fix: State that Rule 81 requires GSTR-10 from a registered person whose registration is cancelled or surrendered, other than an ISD, a TDS/TCS deductor or a non-resident taxable person. Casual taxable persons and composition taxpayers are covered. GSTR-10 is due within three months of the date of cancellation or the cancellation order, whichever is later.

Worked examples

Example 1

Three regular taxpayers have the following aggregate turnover for 2026-27: Arya Traders ₹1.8 crore, Bhatt & Co ₹4 crore, Chandra Industries ₹6.5 crore. State which annual return and reconciliation statement each must file and the due date.

Show the solution
  1. Arya Traders: aggregate turnover ₹1.8 crore is up to ₹2 crore, so the notified relief applies and GSTR-9 is not compulsory. GSTR-9C is not required as turnover does not exceed ₹5 crore.
  2. Bhatt & Co: ₹4 crore exceeds ₹2 crore but does not exceed ₹5 crore. GSTR-9 is required. GSTR-9C is not required.
  3. Chandra Industries: ₹6.5 crore exceeds ₹5 crore. GSTR-9 and a self-certified GSTR-9C are both required.
  4. Due date: 31 December following the financial year, that is 31 December 2027, unless extended by notification.

Answer: Arya Traders: no compulsory filing (GSTR-9 optional under the notified relief). Bhatt & Co: GSTR-9 only. Chandra Industries: GSTR-9 and self-certified GSTR-9C. Due date for all: 31 December 2027.

Example 2

Dev Ltd, a regular taxpayer with aggregate turnover of ₹30 crore (all in one State) for 2026-27, files GSTR-9 on 12 January 2028. Compute the late fee. Turnover is above ₹20 crore, so the standard rate of ₹200 per day and the cap under section 47(2) apply. Also state whether GSTR-9C is required.

Show the solution
  1. Due date is 31 December 2027. Filing on 12 January 2028 is 12 days late (1 to 12 January).
  2. Turnover ₹30 crore is above ₹20 crore, so the reduced slabs do not apply and the standard rate applies.
  3. Late fee at ₹100 per day under CGST = 12 × ₹100 = ₹1,200. Late fee under SGST = ₹1,200. Total = ₹2,400.
  4. Cap: all turnover is in one State, so turnover in the State is ₹30 crore. 0.25% of ₹30 crore = ₹7,50,000 under each Act, total ₹15,00,000.
  5. ₹2,400 is far below the cap, so the cap does not apply.
  6. Turnover ₹30 crore exceeds ₹5 crore, so a self-certified GSTR-9C must also be filed with the annual return.

Answer: Late fee is ₹2,400 (₹1,200 CGST + ₹1,200 SGST). GSTR-9C is required, as turnover exceeds ₹5 crore.

Exam tips

  • Start every applicability answer by naming the type of person and then the turnover. Examiners award marks for this order.
  • Write 'self-certified' next to GSTR-9C. Any mention of a CA audit loses the mark.
  • In late fee sums, show days late, rate, total and cap check on separate lines for step marks.
  • For MCQs, memorise the ladder: ₹2 crore for GSTR-9 relief, ₹5 crore for GSTR-9C, 31 December for due date.
  • Link GSTR-10 to cancellation or surrender, and always quote 'three months' with the 'whichever is later' rule. Note that ISD, TDS/TCS deductors and non-resident taxable persons do not file it, while a casual taxable person and a composition taxpayer do.

Practice questions from Returns

Annual Return GSTR-9 and Reconciliation GSTR-9C in other exams

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

Annual Return GSTR-9 and Reconciliation GSTR-9C: frequently asked questions

Who must file GSTR-9 and what is the turnover limit?

Every registered person must file it, except an ISD, a casual taxable person, a non-resident taxable person and a person paying tax under section 51 or section 52 (TDS or TCS). A composition taxpayer is not excluded by section 44 itself, but its annual return is Form GSTR-4 under Rule 62 (replacing GSTR-9A from FY 2019-20). A taxpayer with aggregate turnover up to ₹2 crore is exempt from filing GSTR-9 under the notified relief.

Is a GSTR-9C audit still compulsory?

No. The CA or cost accountant audit was removed from 2020-21. If aggregate turnover exceeds ₹5 crore, you file a self-certified reconciliation statement in GSTR-9C along with GSTR-9.

What is the due date and late fee for GSTR-9?

The due date is 31 December after the end of the financial year, unless extended. The standard late fee is ₹200 per day (₹100 CGST and ₹100 SGST), capped at 0.25% of turnover in the State or UT under each Act (0.5% in total). Reduced fees apply by notification: ₹50 per day with a 0.04% cap up to ₹5 crore turnover, and ₹100 per day with a 0.08% cap from ₹5 crore to ₹20 crore. The standard rate applies above ₹20 crore.

When should GSTR-10 be filed?

Under Rule 81, GSTR-10 is the final return of a registered person whose registration is cancelled or surrendered, other than an ISD, a person paying TDS or TCS, or a non-resident taxable person. Casual taxable persons and composition taxpayers are covered. It is due within three months of the date of cancellation or the date of the cancellation order, whichever is later.

Can I revise GSTR-9 after filing?

No. GSTR-9 cannot be revised once filed. Check the figures against GSTR-1, GSTR-3B and your books before you submit.