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Indirect Tax Laws and Practice · GST Returns

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

Updated 11 October 2026 · Fact-checked

GSTR-9 is the annual return most registered persons file for each financial year, by 31 December following the year end. GSTR-9C is a self-certified reconciliation statement, filed with it only when aggregate turnover exceeds ₹5 crore. To solve questions, check who is excluded, the turnover and the due date.

Understand Annual Return and Reconciliation Statement

Every registered person files monthly or quarterly returns during the year. The annual return under section 44 of the CGST Act is a once-a-year summary for the whole financial year. It lets the department compare what you declared across the year in one place.

The Act says the annual return may include a self-certified reconciliation statement. This statement reconciles the value of supplies declared in your returns for the year with your audited annual financial statement. Rule 80 gives this statement its form: FORM GSTR-9C.

Not everyone files. Section 44 excludes an Input Service Distributor, a person paying tax under section 51 (TDS deductor), a person paying tax under section 52 (e-commerce operator collecting tax), a casual taxable person and a non-resident taxable person. The Act also does not apply to Central or State Government departments and local authorities whose books are audited by the CAG or an auditor appointed under law.

The form depends on the taxpayer. A regular person files GSTR-9. A person paying tax under section 10 (composition) files GSTR-9A. An e-commerce operator required to collect tax at source files an annual statement in GSTR-9B. GSTR-9C is needed only above the turnover threshold.

The Commissioner may, on the Council's recommendation, exempt a class of registered persons from filing the annual return. Also, a return for a year cannot be filed after three years from its due date, unless the Government allows it by notification on the Council's recommendation.

Key rules to remember

Who files GSTR-9 (Rule 80(1))
Every registered person, except ISD, section 51 payer, section 52 payer, casual taxable person, non-resident taxable person and the Government/local authority class in the second proviso to section 44
Composition taxpayers under section 10 file GSTR-9A instead.
Due date of GSTR-9
31 December following the end of the financial year
Example: for FY 2026-27, the due date is 31 December 2027. The 28 February 2022 date was only for FY 2020-21.
GSTR-9C threshold (Rule 80(3))
Aggregate turnover during the financial year > ₹5 crore
The test is 'exceeds', so exactly ₹5 crore does not require GSTR-9C. The statement is self-certified and filed with GSTR-9 by the same due date.
Time bar (section 44(2))
No annual return after 3 years from the due date
Government may allow later filing by notification on Council's recommendation, with conditions.
Other annual forms
GSTR-9A: section 10 payer; GSTR-9B: e-commerce operator under section 52
GSTR-9B is an annual statement under section 52(5).

How to solve Annual Return and Reconciliation Statement questions

Use this order for any question on applicability, forms or due dates.

  1. 1Identify the person: regular, composition, ISD, TDS deductor, e-commerce operator collecting tax, casual or non-resident taxable person.
  2. 2Check the exclusions. If the person is an ISD, a section 51 or 52 payer, a casual or non-resident taxable person, no GSTR-9 or GSTR-9C applies under Rule 80(1) and (3).
  3. 3Pick the form: GSTR-9 for regular persons, GSTR-9A for section 10 payers, GSTR-9B for e-commerce operators collecting tax under section 52.
  4. 4Test the turnover. If aggregate turnover for the financial year exceeds ₹5 crore, GSTR-9C is also required.
  5. 5Fix the due date: 31 December following the end of the financial year, unless the question gives a special date for that year.
  6. 6Explain the reconciliation: GSTR-9C ties supplies declared in returns to the audited annual financial statement, self-certified.
  7. 7State the conclusion clearly with the rule reference.

Quickest way: Three-question filter

When to use it: Use for MCQs and short case questions on who files and when.

  1. Q1: Is the person excluded (ISD, section 51 or 52, casual, non-resident)? If yes, no annual return.
  2. Q2: Composition? Then GSTR-9A. Otherwise GSTR-9.
  3. Q3: Turnover above ₹5 crore? Then add GSTR-9C by 31 December after the year end.

Common mistakes in Annual Return and Reconciliation Statement

  • Saying GSTR-9C is required at ₹5 crore turnover.

    Students read the threshold as 'five crore and above'.

    Fix: Rule 80(3) says 'exceeds five crore rupees'. Exactly ₹5 crore needs no GSTR-9C.

  • Treating GSTR-9C as a CA/CMA-certified audit statement.

    Older rules required audited accounts and a certified statement.

    Fix: The current Rule 80(3) requires a self-certified reconciliation statement. The earlier certification wording was substituted in 2021.

  • Asking a composition dealer to file GSTR-9.

    Forms get mixed up.

    Fix: The proviso to Rule 80(1) directs a section 10 payer to file GSTR-9A.

  • Including casual taxable persons or ISDs among GSTR-9 filers.

    Students remember 'every registered person' and forget the exclusions.

    Fix: Learn the exclusion list from section 44 and Rule 80 as one set.

  • Using 28 February 2022 as the general due date.

    The special FY 2020-21 date appears in the rule text.

    Fix: That date applied only to FY 2020-21. The general date is 31 December after the year end.

  • Saying GSTR-9 can be filed at any time later.

    Ignoring section 44(2).

    Fix: Late filing is barred after three years from the due date, unless the Government notifies relief.

Worked examples

Example 1

Sunrise Traders Pvt. Ltd., Pune, is a regular registered person. Its aggregate turnover for FY 2026-27 is ₹7.40 crore. Which annual forms must it file and by when?

Show the solution
  1. Sunrise is a regular registered person, not excluded under section 44 or Rule 80.
  2. So it files GSTR-9 under Rule 80(1).
  3. Aggregate turnover ₹7.40 crore exceeds ₹5 crore, so a self-certified reconciliation statement in GSTR-9C is also required under Rule 80(3).
  4. Due date for both is 31 December following the end of the financial year, that is 31 December 2027.

Answer: File GSTR-9 and GSTR-9C (self-certified) by 31 December 2027.

Example 2

Kaveri Foods, Chennai, pays tax under section 10 with turnover of ₹1.2 crore. Anand Ltd. is a casual taxable person with turnover of ₹9 crore from a temporary stall. Advise on annual returns for each.

Show the solution
  1. Kaveri pays tax under section 10, so under the proviso to Rule 80(1) it files GSTR-9A.
  2. Kaveri's turnover is ₹1.2 crore, not above ₹5 crore, and GSTR-9C is not triggered.
  3. Anand is a casual taxable person. Section 44 and Rule 80(1) and (3) exclude such a person from the annual return and the reconciliation statement.
  4. Turnover of ₹9 crore does not change the exclusion.

Answer: Kaveri files GSTR-9A only. Anand files no GSTR-9 or GSTR-9C.

Exam tips

  • MCQs often test the threshold word 'exceeds'. Check whether turnover equals ₹5 crore.
  • Memorise the exclusion list as five items plus the Government/local authority class.
  • In case questions, name the form for each taxpayer type before answering the date.
  • Mention 'self-certified' and 'audited annual financial statement' when describing GSTR-9C.
  • Do not cite relief dates for specific past years unless the question gives them.

Practice questions from GST Returns

Annual Return and Reconciliation Statement 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 and Reconciliation Statement: frequently asked questions

Who must file GSTR-9?

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. Government departments and local authorities audited by the CAG or a legally appointed auditor are also outside section 44. A composition taxpayer files GSTR-9A instead.

When is GSTR-9C required?

When aggregate turnover in the financial year exceeds ₹5 crore. It is a self-certified reconciliation statement filed with GSTR-9 on or before 31 December following the year end.

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

GSTR-9 is the annual return summarising the year. GSTR-9C reconciles supplies declared in returns with the audited annual financial statement. GSTR-9 is filed by most registered persons; GSTR-9C only above the threshold.

Can I file GSTR-9 after the due date?

Yes, but not after three years from the due date. Section 44(2) bars it unless the Government notifies relief on the Council's recommendation.