Answer

GST

Who has to file GSTR-9C

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  1. Facts

    GSTR-9C is required only where aggregate turnover for the year exceeds ₹5 crore. At ₹4.5 crore you file GSTR-9 (if above ₹2 crore) but not GSTR-9C.

  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 44(1), CGST Act 2017Every registered person (other than notified classes) files an annual return by 31 December after the year; a self-certified reconciliation statement is filed with it where turnover exceeds the notified limit.
    • Notification 15/2025-CTTaxpayers with aggregate turnover up to ₹2 crore are exempt from filing the annual return from FY 2024-25 onwards.
  3. Analysis

    Aggregate turnover is counted on an all-India PAN basis, including exempt, export and inter-State supplies, but excluding taxes. So a business with two GSTINs of ₹3 crore each has ₹6 crore aggregate turnover, and each GSTIN files its own 9C. Check the figure from your books, not only from returns. If you are close to ₹5 crore, compute it carefully before deciding.

  4. Conclusion

    1. Add up turnover of all GSTINs under your PAN for the year.
    2. Exclude GST and cess from the total.
    3. If above ₹5 crore, plan GSTR-9C for each GSTIN.
    4. If between ₹2 crore and ₹5 crore, file only GSTR-9.

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