GST
Late fee when GSTR-9C is filed after GSTR-9
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Facts
Yes. Circular 246/03/2025-GST says the annual return is complete only when GSTR-9C (where required) is also filed. Late fee under Sec 47(2) runs from the due date until 9C is filed, and is charged once, not separately.
Provisions and law
- Circular 246/03/2025-GSTLate fee for an incomplete annual return runs from the due date till both GSTR-9 and GSTR-9C (where required) are filed; there is no separate fee for each.
- Sec 47(2), CGST Act 2017Late fee for a late annual return is ₹100 per day under CGST, capped at a quarter percent of turnover in the State, as reduced by notification.
- Notification 07/2023-CTFrom FY 2022-23, GSTR-9 late fee is ₹50 a day (turnover up to ₹5 crore) or ₹100 a day (₹5 to 20 crore), capped at 0.04 percent of turnover; ₹200 a day capped at 0.5 percent above ₹20 crore (CGST plus SGST).
Analysis
If you filed GSTR-9 on 20 December but GSTR-9C on 20 February, the delay counted is 51 days from 31 December. For turnover of ₹8 crore, the fee is ₹100 a day (CGST plus SGST), about ₹5,100, within the 0.04 percent cap of ₹32,000. If GSTR-9 itself was late too, the fee is computed once on the later date.
Conclusion
- Check the date GSTR-9 and GSTR-9C were filed.
- Count delay from the due date to the 9C filing date.
- Apply the slab rate for your turnover with its cap.
- Pay the late fee in cash when filing.
A Savvy can do this for you
GSTR-9C reconciliation statement
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