Answer

GST

GSTR-9C for multiple GSTINs under one PAN

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  1. Facts

    Yes. Each GSTIN files its own GSTR-9 and GSTR-9C, but the ₹5 crore test uses aggregate turnover of the whole PAN.

  2. Provisions and law

    • Rule 80(3), CGST Rules 2017A taxpayer whose aggregate turnover exceeds ₹5 crore files a self-certified reconciliation statement in GSTR-9C along with GSTR-9.
    • Sec 25(2), CGST Act 2017One registration per PAN per State, with separate registrations allowed for multiple places of business in a State.
  3. Analysis

    Since accounts are usually made for the whole entity, you need State-wise turnover from books, or a working that allocates it. Inter-GSTIN supplies count as turnover of the supplying GSTIN. A GSTIN with small turnover still files 9C if the PAN total exceeds ₹5 crore. Plan the State-wise split early.

  4. Conclusion

    1. Compute PAN-level aggregate turnover.
    2. Prepare State-wise turnover from books.
    3. Include inter-GSTIN supplies for the supplying GSTIN.
    4. File 9C for each GSTIN.

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