GSTR-9 is the GST annual return. GSTR-9C is a separate, self-certified reconciliation statement that accompanies GSTR-9 when a registered person’s aggregate turnover for the financial year exceeds ₹5 crore. GSTR-9C does not replace GSTR-9.
Whether you must file either form depends on your taxpayer category, any exemption notified for the particular financial year, and (for GSTR-9C) turnover calculated across your entire PAN in India. The ordinary deadline for both forms is 31 December after the end of the financial year, although the government can extend it.
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GSTR-9 and GSTR-9C at a glance
The two forms serve different purposes. Rule 80 of the Central Goods and Services Tax (CGST) Rules provides the annual-return framework, while the reconciliation requirement is linked to the turnover threshold in the same rule. The current rule text is available from the Central Board of Indirect Taxes and Customs (CBIC).
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| Question | GSTR-9 | GSTR-9C |
|---|---|---|
| What is it? | The annual return for a registered person within the form’s scope. | A reconciliation statement matching the annual return with the annual financial statements. |
| When does the turnover threshold matter? | A financial-year notification may exempt certain taxpayers; the commonly quoted threshold must not be treated as a universal exemption. | Required when aggregate turnover during the financial year exceeds ₹5 crore. |
| Does it replace the other form? | No. Where GSTR-9C applies, it accompanies GSTR-9. | No. It is an additional statement, not a substitute for GSTR-9. |
| Certification | No special auditor certification is stated in the cited rule for filing GSTR-9. | Currently self-certified by the registered person. |
| Ordinary due date | 31 December following the end of the financial year, subject to extensions. | 31 December following the end of the financial year, subject to extensions. |
The practical decision is therefore two-stage: first determine whether the registered person is required to file GSTR-9, then test whether PAN-wide aggregate turnover exceeds ₹5 crore for the additional GSTR-9C obligation.
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Who must file GSTR-9?
GSTR-9 is the annual return prescribed for registered persons covered by section 44 of the CGST Act and rule 80. The obligation is not determined solely by whether a business made taxable sales in one GST registration. You must also consider the taxpayer categories that the rule expressly excludes and any exemption notified for the relevant financial year.
Taxpayer categories excluded by rule 80
Rule 80 excludes the following categories from the GSTR-9 requirement:
- An Input Service Distributor.
- A person paying tax under section 51, which covers tax deducted at source under the GST framework.
- A person paying tax under section 52, which covers tax collected at source by specified e-commerce operators.
- A casual taxable person.
- A non-resident taxable person.
These exclusions come from the rule itself; they should not be expanded to other categories without checking the applicable legal text. The CBIC version of rule 80 is the appropriate starting point for the wording in force at the time you assess the return.
Year-specific exemptions can change the result
Section 44 allows the government to notify exemptions from the annual-return requirement for specified classes of registered persons or for a specified financial year. Consequently, a turnover figure often discussed in general guidance is not a permanent, all-years exemption rule. Before filing or deciding not to file, identify the financial year and read the notification issued for that year.
This distinction matters because the GSTR-9 exemption question and the GSTR-9C threshold are separate tests. A notification that removes or limits GSTR-9 filing for a class of taxpayers does not, by itself, rewrite the ₹5 crore test for GSTR-9C. Conversely, being below ₹5 crore does not automatically exempt a taxpayer from GSTR-9 if the taxpayer remains within its scope and no applicable exemption applies.
Who must file GSTR-9C?
GSTR-9C is required when a registered person’s aggregate turnover exceeds ₹5 crore during the financial year. The statement reconciles the supplies and other figures reported in the annual return with the corresponding annual financial statements. It must be furnished with GSTR-9, so it is an additional compliance document rather than an alternative annual return. The requirement and current threshold are set out in the amended rule text published by CBIC and discussed in CBIC Circular 246/03/2025-GST.
What “aggregate turnover” means for the ₹5 crore test
Aggregate turnover is not the turnover of one GSTIN viewed in isolation. It is computed on a PAN basis for the whole of India. The statutory concept generally brings together:
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- Exempt supplies.
- Exports.
- Inter-State supplies of persons having the same PAN.
It excludes specified taxes charged under the GST laws and inward supplies on which tax is payable under reverse charge, along with other exclusions in the statutory definition. The CBIC Sectoral FAQs explain the PAN-wide, all-India approach. Apply the legal definition to every relevant registration and business activity before deciding that the threshold has not been crossed.
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For example, a company with registrations in Maharashtra, Karnataka and Delhi cannot compare ₹5 crore with only the Maharashtra GSTIN. It must aggregate the relevant turnover of all three registrations under the same PAN. Exempt education services, zero-rated exports and inter-State supplies remain relevant to the aggregate-turnover calculation even when no output tax was charged on a particular invoice. Conversely, inward supplies on which the recipient pays tax under reverse charge are not added as outward turnover for this test.
Self-certification replaced the earlier audit-linked model
The current rule requires a self-certified reconciliation statement. The older framework used a ₹2 crore threshold linked to an audit and a duly certified reconciliation statement. The change took effect from 1 August 2021. Therefore, current filing guidance should not describe certification by a chartered accountant or cost accountant as a legal prerequisite for GSTR-9C. A professional may still help prepare or review reconciliations, but that practical choice is different from a statutory certification requirement. The historical wording can be compared in the original CGST Rules.
Self-certification does not mean that the reconciliation can be completed casually. The registered person signs off on the statement and remains accountable for the figures, explanations and tax consequences shown. Keep the financial statements, trial balance extracts, GST ledgers, return workings and approval evidence that support the figures submitted.
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Use the following sequence for each financial year. Keep the financial year visible on your working papers because exemptions, portal behavior and extensions can change.
- Identify every GST registration linked to the PAN. Include registrations in different Indian states and Union territories when assembling the turnover picture.
- Check whether the taxpayer is in an excluded category. Confirm whether the entity is an Input Service Distributor, a section 51 deductor, a section 52 collector, a casual taxable person or a non-resident taxable person.
- Read the financial-year-specific section 44 notification. Do not rely on an old article or a threshold remembered from another year. Determine whether the notification exempts your class of registered person from GSTR-9.
- Calculate aggregate turnover on the PAN basis. Combine the supplies covered by the statutory definition across India, including taxable, exempt, export and relevant inter-State supplies, and remove the stated exclusions.
- Test the ₹5 crore line. If aggregate turnover exceeds ₹5 crore, plan for GSTR-9C in addition to GSTR-9. If it does not, GSTR-9C is not triggered by that threshold alone.
- Confirm the filing status of the year’s periodic returns. For FY 2024-25, GSTN stated that the annual-return forms become enabled after all due GSTR-1 and GSTR-3B returns for that year have been filed.
- Check the current due-date notification. Start with the ordinary 31 December rule, then verify whether the government extended the date for the financial year or for a particular class of taxpayers.
How the decision works in common cases
A normal registered company that is not in an excluded category generally starts with GSTR-9, subject to the year’s section 44 notification. If its PAN-wide aggregate turnover is above ₹5 crore, it adds GSTR-9C. A company below ₹5 crore may still have to file GSTR-9, because the ₹5 crore figure is the trigger for the additional reconciliation statement, not a universal annual-return exemption.
If one PAN has several GSTINs, assess the annual-return obligation for each registration according to its status and the applicable rules, while using the combined PAN-wide figure for the GSTR-9C threshold. An Input Service Distributor’s exclusion does not automatically remove the obligation of a separate regular registration held by the same PAN.
Deadlines and portal prerequisites
Ordinary statutory deadline
Under rule 80, GSTR-9 and any applicable GSTR-9C are ordinarily due by 31 December following the end of the financial year. For FY 2024-25, that ordinary date was 31 December 2025. An extension, if issued, supersedes the ordinary date for the covered taxpayers and period, so check the latest notification before treating a return as late or on time. Rule 80 and its deadline structure appear in the CBIC rules compilation.
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The ordinary date is calculated after the financial year closes: a year ending 31 March 2025 points to 31 December 2025. Do not carry a date from one financial year into the next without checking the notification applicable to that year. Extensions may be limited to specified forms, taxpayers or periods.
FY 2024-25 enablement condition
GSTN’s FY 2024-25 GSTR-9/9C FAQ says the forms are enabled after all due GSTR-1 and GSTR-3B returns for that year have been filed. The same FAQ describes auto-population from filed statements and returns, with GSTR-2B used for relevant tables. These workflow details carry the FY 2024-25 label; portal rules and table behavior can change for later years.
If the annual-return tile is unavailable, first check for an unfiled GSTR-1 or GSTR-3B in the relevant period rather than assuming that the business is exempt. The portal’s auto-populated figures are a starting point, not a substitute for comparing the return data with the books.
What information each form brings together
GSTR-9: annual consolidation
GSTR-9 consolidates the year’s GST reporting into an annual return. Preparation should start with the periodic returns and statements already filed, then compare them with the accounting records used to close the financial year. Review the totals for outward supplies, tax payable and tax paid, input-tax-credit claims and reversals, and any amendments or adjustments that affected the year. The objective is to submit a consistent annual picture, not to treat the annual return as a replacement for correcting an inaccurate periodic return.
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GSTR-9C: reconciliation with annual financial statements
GSTR-9C starts from the annual financial statements and reconciles their turnover and tax-related figures to the values reported in GSTR-9. Differences can arise from accounting classifications, timing, exempt or non-GST items, credit notes, amendments, or transactions treated differently in the books and GST returns. The reconciliation should identify the reason for each material difference and connect any resulting tax impact to the relevant return or payment record.
Because the statement is self-certified, the registered person is responsible for the completeness and accuracy of the reconciliation. A tax professional can assist with preparation, but the legal filing obligation remains with the registered person. Retain the signed-off reconciliation, working papers and financial statements with the annual-return records.
What GSTR-9 and GSTR-9C do not do
Neither form is a general correction mechanism for every earlier-period mistake. The annual return summarizes the year’s reporting, while the reconciliation statement explains differences between that summary and the financial statements. If the review identifies additional tax, interest or another periodic-return issue, follow the correction and payment process applicable to that issue rather than assuming that attaching GSTR-9C alone resolves it.
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Worked threshold examples
Example 1: one GST registration below ₹5 crore
A registered person has aggregate turnover of ₹4.80 crore for the year after applying the statutory inclusions and exclusions. The ₹5 crore GSTR-9C threshold is not crossed. The person must still check whether GSTR-9 applies under rule 80 and whether a financial-year notification provides an exemption. Being below ₹5 crore answers only the GSTR-9C threshold question.
Example 2: several registrations under one PAN
A business operates registrations in three states. Their combined aggregate turnover is ₹5.20 crore, even though no individual registration exceeds ₹5 crore. The PAN-wide calculation crosses the GSTR-9C threshold. The business should therefore assess the accompanying reconciliation requirement for the registered persons covered by its annual-return filings instead of testing each GSTIN separately.
Example 3: an excluded taxpayer category
An Input Service Distributor has activity during the year but falls within a category expressly excluded by rule 80. That exclusion must be considered before applying general annual-return guidance. The business should still review any other GST registrations under the PAN independently; one registration’s category does not automatically decide every registration’s obligation.
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Example 4: exempt and export supplies
A PAN has ₹3.9 crore of taxable domestic supplies, ₹70 lakh of exempt supplies and ₹60 lakh of exports. Subject to the statutory exclusions and the precise facts, these categories are relevant to aggregate turnover, producing a figure above ₹5 crore even though taxable domestic sales alone are below the line. The business should not omit exempt or export turnover merely because those supplies did not carry ordinary output GST.
Common mistakes and how to prevent them
- Treating GSTR-9C as a replacement: File GSTR-9 first and add GSTR-9C when the aggregate-turnover test requires it.
- Using one GSTIN’s turnover: Recalculate on the PAN-wide, all-India basis and include the statutory categories of supplies.
- Confusing the annual-return exemption with the ₹5 crore trigger: Check the section 44 notification separately from the GSTR-9C threshold.
- Calling current GSTR-9C “CA-certified” by default: The current rule specifies self-certification; the ₹2 crore audit-linked wording is historical.
- Ignoring excluded taxpayer categories: Screen for Input Service Distributor, section 51, section 52, casual and non-resident status before concluding that GSTR-9 is required.
- Relying on an old deadline: Use 31 December as the ordinary rule, then look for a year-specific extension.
- Expecting the forms before periodic returns are complete: For FY 2024-25, GSTN tied enablement to filing all due GSTR-1 and GSTR-3B returns.
- Accepting auto-populated data without reconciliation: Compare portal figures with the books, filed returns and payment records, and document every unexplained difference before submission.
- Leaving out exempt or export turnover: These supplies can form part of aggregate turnover, so segregate them in the turnover schedule.
- Assuming self-certification removes review responsibility: The registered person still owns the accuracy of the submitted reconciliation and should retain support for each material difference.
A practical preparation checklist
- Write the financial year and the ordinary 31 December deadline at the top of the compliance calendar.
- List every GSTIN associated with the PAN and identify any registration in an excluded category.
- Collect the year’s filed GSTR-1 and GSTR-3B returns, relevant GSTR-2B data, ledgers and payment challans.
- Compute aggregate turnover using the statutory PAN-wide definition, with a separate schedule for taxable, exempt, export and inter-State supplies.
- Locate the section 44 notification and any extension notification for the year.
- Determine whether GSTR-9 is required and whether turnover exceeding ₹5 crore adds GSTR-9C.
- Compare annual-return figures with the financial statements and investigate differences before self-certifying GSTR-9C.
- Have the person responsible for the GST registration review the final figures and explanations.
- Save the submitted forms, acknowledgements, reconciliations and supporting schedules in the entity’s tax records.
What to verify before filing
Rules and portal functions are updated periodically. For a live filing decision, verify three items against current official material: the section 44 exemption notification for the financial year, any extension of the 31 December deadline, and the GSTN instructions for that year’s form enablement and auto-populated tables. The legal starting points are rule 80, the amended CGST Rules, and the applicable GSTN annual-return FAQ.
Also confirm that the turnover schedule uses the same PAN, includes all Indian registrations and distinguishes outward supplies from inward reverse-charge transactions. Retain a copy of the notification and FAQ used for the decision so the basis for filing or non-filing is clear when the records are reviewed later.
Frequently asked questions
Who must file GSTR-9 and GSTR-9C?
A registered person within GSTR-9’s scope must file the annual return unless an applicable section 44 notification exempts that taxpayer for the relevant financial year. If aggregate turnover for the PAN exceeds ₹5 crore during that year, the person must also furnish GSTR-9C with GSTR-9.
Is GSTR-9C compulsory above ₹5 crore?
Yes, when aggregate turnover exceeds ₹5 crore during the financial year and the registered person is otherwise within the annual-return framework. The amount is measured across the PAN in India, not by selecting only the GSTIN with the highest sales.
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Is GSTR-9C still audited by a CA?
The current rule requires a self-certified reconciliation statement. The earlier ₹2 crore audit-linked, professionally certified model was replaced from 1 August 2021. A chartered accountant or other adviser may assist voluntarily, but that certification is not stated as the current legal filing prerequisite.
What is the due date for GSTR-9?
The ordinary rule 80 due date is 31 December following the end of the financial year. For FY 2024-25, the ordinary date was 31 December 2025. Check for a government extension before relying on the ordinary date.
Does turnover below ₹5 crore mean no GSTR-9 filing?
No. Below ₹5 crore generally means the GSTR-9C threshold is not crossed. You must still determine whether GSTR-9 applies under rule 80 and whether a financial-year notification grants an exemption.
Why are my annual-return forms not enabled on the portal?
For FY 2024-25, GSTN said the forms become enabled after all due GSTR-1 and GSTR-3B returns for that year are filed. Check those periodic returns first, then follow the year-specific GSTN instructions because portal behavior can change.
Frequently Asked Questions
Who must file GSTR-9 and GSTR-9C?
A registered person within GSTR-9’s scope files the annual return unless a financial-year exemption applies. If PAN-wide aggregate turnover exceeds ₹5 crore, GSTR-9C must accompany GSTR-9.
Is GSTR-9C compulsory above ₹5 crore?
Yes, when aggregate turnover exceeds ₹5 crore during the financial year and the registered person is otherwise within the annual-return framework.
Is GSTR-9C still audited by a CA?
Current GSTR-9C is self-certified. The earlier ₹2 crore audit-linked certification model was replaced from 1 August 2021.
What is the due date for GSTR-9?
The ordinary due date is 31 December following the financial year, subject to any government extension.
Does turnover below ₹5 crore exempt GSTR-9?
No. It addresses only the GSTR-9C threshold. Check rule 80 and the exemption notification for the relevant financial year.
The Bottom Line
Bottom line: Start with the GSTR-9 obligation under rule 80, screen out the named excluded categories and check the financial-year section 44 notification. Then calculate aggregate turnover across every GSTIN under the PAN in India. If that figure exceeds ₹5 crore, file the self-certified GSTR-9C with GSTR-9. Use 31 December after year-end as the ordinary deadline, but verify the current notification and GSTN instructions for the year you are filing.
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