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