Indirect Tax Laws and Practice · GST Annual Return and GST Audit Return
GSTR-9 Late Fee, DRC-03 and No Revision Rules
Updated 11 October 2026 · Fact-checked
If you file the annual return (GSTR-9) after the due date, section 47(2) charges a late fee of ₹100 per day of delay, capped at 0.25% of your turnover in the State or Union territory. A filed GSTR-9 cannot be revised. Extra liability found later is paid through FORM GST DRC-03, with interest.
Understand Late Fee, Amendments and Compliance for Annual Return
The annual return under section 44 is due by 31 December following the end of the financial year (Rule 80). Rule 80 lists who must file it. Input Service Distributors, persons paying tax under section 51 or 52, casual taxable persons and non-resident taxable persons are excluded. Composition taxpayers file GSTR-9A, and others file GSTR-9.
If you miss that date, section 47(2) applies. The late fee is ₹100 for every day the failure continues. It is subject to a maximum of a quarter per cent (0.25%) of your turnover in the State or Union territory. So the cap depends on turnover. It is not a fixed rupee amount.
Do not mix this with section 47(1). That sub-section covers outward supply details under section 37 and returns under section 39, 45 or 52, and caps the fee at ₹5,000. The annual return falls under section 47(2), not section 47(1).
GSTR-9 is a one-time summary of the year. Once you file it, it cannot be revised. So reconcile your books with GSTR-1 and GSTR-3B before filing. If you find unpaid tax for the year afterwards, you do not amend the return. You pay the extra tax through FORM GST DRC-03, along with interest.
Late fee and interest are different. Late fee is a penalty for delay. Interest is calculated on tax that stays unpaid (Rule 88B(2)). Both are debited to the electronic liability register (Rule 85). Interest, late fee and other amounts are paid by debiting the electronic cash ledger (Rule 85(4)), not the credit ledger.
Key rules to remember
- Late fee on annual return (section 47(2))
- Late fee = ₹100 × number of days of delay, subject to a maximum of 0.25% × turnover in the State or UT
- Charge the lower of the two figures. Count days from the day after the due date until the date of filing.
- Due date of annual return (Rule 80)
- 31 December following the end of the financial year
- The rule text covers GSTR-9 and GSTR-9A. The date can be extended by notification, so read the question.
- Late fee cap on other returns (section 47(1))
- ₹100 per day, maximum ₹5,000
- Applies to section 37, 39, 45 and 52 returns, not to the annual return.
- Mode of payment of late fee and interest (Rule 85(4))
- Pay by debiting the electronic cash ledger
- Input tax credit in the electronic credit ledger cannot be used for late fee or interest.
- Interest on unpaid tax (Rule 88B(2))
- Interest = tax unpaid × notified rate × days from due date of payment to date of payment ÷ 365
- The rate comes from a notification under section 50(1). Use the rate given in the question.
- Reconciliation statement threshold (Rule 80(3))
- GSTR-9C is required if aggregate turnover in the financial year exceeds ₹5 crore
- It is filed with GSTR-9 by the same due date.
How to solve Late Fee, Amendments and Compliance for Annual Return questions
For any question on late fee, revision or extra liability in the annual return, work in this order.
- 1Identify the taxpayer. Check whether the person must file GSTR-9 or GSTR-9A, or is excluded under Rule 80.
- 2Note the due date. Unless the question gives an extended date, use 31 December after the financial year.
- 3Count the days of delay, starting from the day after the due date up to the filing date.
- 4Compute late fee as ₹100 × days. Then compute 0.25% of turnover in the State or UT and take the lower figure.
- 5If tax for the year is found unpaid after filing, say that GSTR-9 cannot be revised. The tax is paid through FORM GST DRC-03.
- 6Compute interest on that unpaid tax from its due date to the date of payment, at the rate given. State that late fee and interest are paid from the cash ledger.
- 7Write a one-line conclusion giving the total amount payable and the mode of payment.
Quickest way: Lower-of-two late fee check
When to use it: Use this for numerical MCQs and short parts that ask for the late fee on a delayed annual return.
- Write days of delay × 100.
- Write turnover × 0.25%.
- Pick the smaller figure. That is the late fee.
- If the question asks for the total outflow, add interest on any unpaid tax, then say it is paid in cash.
Common mistakes in Late Fee, Amendments and Compliance for Annual Return
Applying the ₹5,000 maximum to the annual return.
Students remember section 47(1) for GSTR-1 and GSTR-3B and assume it covers all returns.
Fix: Annual return falls under section 47(2). The cap is 0.25% of turnover in the State or UT.
Counting the due date itself as a day of delay.
Students subtract dates without thinking about when the failure starts.
Fix: The failure starts on the day after 31 December. Count from 1 January through the filing date.
Saying a GSTR-9 can be revised by filing an amended return.
Students carry over the idea of amending GSTR-1 or Ind AS prior period items.
Fix: A filed GSTR-9 cannot be revised. Pay extra liability through DRC-03 and plan reconciliation before filing.
Paying late fee or interest using input tax credit.
Students treat all dues as tax payable from any ledger.
Fix: Under Rule 85(4), interest, fee and penalty are paid by debiting the electronic cash ledger.
Applying the cap to turnover in India instead of the State or UT.
The word turnover is read loosely.
Fix: Section 47(2) refers to turnover in the State or Union territory. Use the figure for that registration.
Treating late fee as a substitute for interest.
Both arise from delay, so they look the same.
Fix: Late fee is charged for the delay in filing. Interest is charged on tax that is unpaid. Compute both separately.
Worked examples
Example 1
Sundaram Textiles Pvt Ltd, registered in Tamil Nadu, has turnover of ₹4 crore in the State for the year. It filed its GSTR-9 on 20 January of the following year. The due date was 31 December. Compute the late fee under section 47(2).
Show the solution
- Delay: 1 January to 20 January is 20 days.
- Fee by days: 20 × ₹100 = ₹2,000.
- Cap: 0.25% × ₹4,00,00,000 = ₹1,00,000.
- The lower figure is ₹2,000.
Answer: Late fee payable is ₹2,000, paid by debiting the electronic cash ledger.
Example 2
Meera Traders in Kerala has turnover of ₹40 lakh in the State. It files GSTR-9 after a delay of 150 days. Afterwards it finds ₹30,000 of tax for the year was not paid. State the late fee and the way to pay the unpaid tax.
Show the solution
- Fee by days: 150 × ₹100 = ₹15,000.
- Cap: 0.25% × ₹40,00,000 = ₹10,000.
- The lower figure is ₹10,000, so the late fee is capped at ₹10,000.
- GSTR-9 cannot be revised once filed, so the ₹30,000 cannot be added by amending it.
- Pay ₹30,000 through FORM GST DRC-03 with interest at the notified rate on the unpaid tax from its due date to the payment date.
- Pay the late fee and interest by debiting the electronic cash ledger.
Answer: Late fee is ₹10,000. The ₹30,000 tax is paid through DRC-03 along with interest. GSTR-9 is not revised.
Exam tips
- For a late fee numerical, always show both figures (days × ₹100 and 0.25% of turnover) and then choose the lower.
- Read whether the question says the due date was extended. If so, count days from the new date.
- If asked whether GSTR-9 can be amended, answer plainly that it cannot be revised and name DRC-03 as the route for additional liability.
- Quote the section: section 47(2) for annual return, section 47(1) for other returns with the ₹5,000 cap.
- Do not forget to mention payment from the cash ledger when a question asks about the mode of payment.
Practice questions from GST Annual Return and GST Audit Return
- Which of the following registered persons is NOT excluded by section 44(1) of the CGST Act from the requirement to furnish an annual return?
- Under Rule 102 of the CGST Rules as given, which statement about special audit under section 66 is correct?
- Under section 44(2) of the CGST Act as reproduced, a registered person for a financial year whose annual return due date was 31 December 202…
- Which of the following registered persons is NOT required by Rule 80(1) to furnish an annual return in FORM GSTR-9?
- Which statement about audit provisions in the CGST Rules, 2017 as reproduced is correct?
Late Fee, Amendments and Compliance for 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.
Late Fee, Amendments and Compliance for Annual Return: frequently asked questions
What is the GSTR-9 late fee per day under section 47?
Section 47(2) provides a late fee of ₹100 for every day the failure continues. It is subject to a maximum of 0.25% of turnover in the State or Union territory. Any relief given by notification applies only if the question states it.
Can GSTR-9 be revised after filing?
No. Once filed, GSTR-9 cannot be revised. Check your reconciliation with GSTR-1 and GSTR-3B before you file.
How do I pay additional liability for the year after filing GSTR-9?
You pay it through FORM GST DRC-03, with interest on the unpaid tax. Interest runs from the date the tax was due to be paid until it is paid (Rule 88B(2)). Payment is made from the electronic cash ledger.
Is the ₹5,000 late fee cap applicable to GSTR-9?
No. The ₹5,000 maximum is in section 47(1) for returns under sections 37, 39, 45 and 52. GSTR-9 is governed by section 47(2), where the cap is 0.25% of turnover in the State or UT.