Who must file GSTR-9C above ₹5 crore turnover?

What is GSTR-9C?

GSTR-9C is a reconciliation statement. It sits on top of the GSTR-9 annual return and reconciles the turnover, tax paid, and input tax credit declared across the year's returns with the figures in the audited annual financial statements. Where the two do not match, the statement is where the difference is shown and explained.

The legal hook is section 44 of the CGST Act, read with rule 80 of the CGST Rules. Section 44 provides that the annual return may include a self-certified reconciliation statement reconciling the value of supplies declared in the return with the audited annual financial statement.

Who must file GSTR-9C?

Every registered person whose aggregate turnover in a financial year exceeds ₹5 crore files GSTR-9C for that year. It is furnished per GSTIN, so a business registered in more than one State files one reconciliation statement for each registration whose turnover pulls it into the net.

A registered person at or below the ₹5 crore line is out of GSTR-9C entirely and files only the annual return. Persons outside the annual-return net in the first place, such as an input service distributor or a casual taxable person, do not reach GSTR-9C either.

How is the ₹5 crore turnover computed?

The test is aggregate turnover, and aggregate turnover is PAN-wide. It adds taxable supplies, exempt supplies, exports, and inter-state supplies of every GSTIN under the same PAN, computed on an all-India basis. It is not the turnover of one branch or one State registration looked at alone.

Because the ₹5 crore line is drawn at PAN level, a company can be over the threshold on its all-India figure even where a single State registration is small. In that case every GSTIN under the PAN that files GSTR-9 also files GSTR-9C.

Does a CA still certify GSTR-9C?

The old GST audit is gone. Since the amendment to section 44 and rule 80, the reconciliation statement is self-certified by the taxpayer. There is no separate certification by a chartered accountant or cost accountant, and no separate audit report to upload with it.

Self-certification does not lower the accuracy expected. The figures still have to tie to the audited accounts, and an unexplained gap between the annual return and those accounts is exactly what the statement is meant to surface.

When is GSTR-9C due?

GSTR-9C is due on 31 December following the financial year, the same date as GSTR-9, under rule 80(3) of the CGST Rules. File the annual return first, then the reconciliation statement.

Does late GSTR-9C carry its own late fee?

No separate fee, but one continuing fee. Circular 246/03/2025-GST dated 30 January 2025 clarifies that where GSTR-9C is required, the annual return under section 44 is not complete until both GSTR-9 and GSTR-9C are furnished. Late fee under section 47(2) therefore runs from 31 December until the date GSTR-9C is filed, and is not levied twice for the two forms.

Was the old GSTR-9C late fee waived?

Yes, for one closed window. Notification 08/2025-Central Tax dated 23 January 2025 waived late fee on delayed GSTR-9C for financial years up to FY 2022-23 in excess of the fee payable up to the GSTR-9 filing date, provided GSTR-9C was furnished on or before 31 March 2025. Late fee already paid is not refundable, and FY 2023-24 onward carries no such relief.

How do I check GSTR-9C applies to me?

1. Read section 44 of the CGST Act for the annual return and the self-certified reconciliation statement.
2. Confirm your PAN-wide aggregate turnover for the financial year against the ₹5 crore line before deciding GSTR-9C applies.
3. Keep Circular 246/03/2025-GST with the working file: it fixes the late-fee period as running to the date the complete annual return is furnished.
4. File GSTR-9 first, then GSTR-9C, before 31 December following the financial year.
5. Watch CBIC updates if the threshold or the form tables change.

Why do GSTR-9C filings go wrong?

• Testing the ₹5 crore line on one State's turnover instead of the PAN-wide figure.
• Filing GSTR-9C before the GSTR-9 annual return for that year.
• Assuming a chartered accountant must still certify it after the shift to self-certification.
• Filing one reconciliation statement for the PAN instead of one per GSTIN.
• Leaving a turnover or ITC gap against the audited accounts unexplained in the statement.

Where are GSTR-9C rule changes published?

GSTR-9C changes are published as CBIC central tax notifications and circulars: the ₹5 crore threshold sits in rule 80(3), the self-certification shift came with the 1 August 2021 amendment to section 44, and the late-fee position came in Circular 246/03/2025-GST. For the annual return itself, read our GSTR-9 due date guide. Complied AI keeps CBIC / GST updatesin one feed so you can open the source behind a change instead of relying on last year's note. When you need the annual-return rule itself, open section 44 next to the update.