GST
GSTR-9 for a business with multiple GSTINs
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Facts
GSTR-9 is filed separately for each GSTIN. The Rs 2 crore exemption is tested on aggregate turnover of the whole PAN. Each State registration has its own late fee cap based on its State turnover.
Provisions and law
- Sec 44, CGST Act 2017Every registered person, other than excluded categories, files an annual return for each financial year
- Notification 15/2025-CTRegistered persons with aggregate turnover up to Rs 2 crore are exempt from filing GSTR-9 from FY 2024-25
- Sec 47(2), CGST Act 2017Late fee for a delayed annual return, as reduced by notification by turnover band
Analysis
If the PAN total is Rs 7 crore, all three GSTINs must file GSTR-9, and GSTR-9C applies to each because aggregate turnover is above Rs 5 crore. Inter-branch supplies between your own GSTINs count in turnover and must match on both sides. Example: Delhi shows Rs 40 lakh stock transfer to Haryana; Haryana must show the same as inward with ITC.
Conclusion
- Confirm PAN-level aggregate turnover
- Prepare a separate reconciliation for each GSTIN
- Match inter-branch supplies and ITC on both sides
- File GSTR-9, and GSTR-9C where required, for each GSTIN
A Savvy can do this for you
GSTR-9 annual return
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