GSTR-9C Explained: Who Files the GST Reconciliation
GSTR-9C is now a self-certified reconciliation for turnover above ₹5 crore under Section 44 — no CA audit needed. Who files it, what it contains, and due dates.
There is a persistent myth that a business above a certain turnover needs a "GST audit by a CA." That requirement was removed years ago. What actually applies now is GSTR-9C — a self-certified reconciliation statement. Here is who files it and what it involves.
What changed: no more mandatory GST audit
Until FY 2019-20, Section 35(5) of the CGST Act required larger taxpayers to get their accounts audited by a CA or CMA, who then certified GSTR-9C. The Finance Act 2021 removed that audit requirement, effective FY 2020-21. Since then, GSTR-9C is a self-certified reconciliation filed by the taxpayer under Section 44 — no CA or CMA certification is legally mandated. Many websites, and some advisors, still describe the old regime. It is outdated.
That said, "self-certified" does not mean "easy." The reconciliation still has to be right, and mistakes flow straight into notices — which is why most businesses still have a professional prepare it.
Who has to file GSTR-9C
| Aggregate turnover (FY) | GSTR-9 | GSTR-9C |
|---|---|---|
| Up to ₹2 crore | Optional | Not required |
| ₹2 crore – ₹5 crore | Mandatory | Not required |
| Above ₹5 crore | Mandatory | Mandatory |
GSTR-9C is filed in addition to GSTR-9, the annual return. So a business between ₹2 crore and ₹5 crore files GSTR-9 but not GSTR-9C; above ₹5 crore files both.
What GSTR-9C actually reconciles
GSTR-9C is a reconciliation between the annual return (GSTR-9) and the audited annual financial statements. It squares:
- Turnover as per the books vs turnover declared in GST returns
- Tax paid vs tax payable
- Input tax credit claimed vs ITC available per the books
Any gaps must be explained — unbilled revenue, timing differences, credit notes, ineligible ITC reversed, and so on. It is where the year's GST story has to hang together against the audited accounts.
The due date
Both GSTR-9 and GSTR-9C are due by 31 December following the end of the financial year. So for FY 2025-26, the deadline is 31 December 2026. Late filing of GSTR-9 attracts a late fee, and an unreconciled or missing GSTR-9C is a red flag in any future scrutiny.
Why it still pays to have it done professionally
Because it is self-certified, the responsibility for accuracy sits squarely on the business. A reconciliation that does not tie out — mismatched turnover, ITC that cannot be traced, unexplained differences — is exactly the kind of thing that triggers an ASMT-10 or a Section 73 / 74 notice a year later. Getting GSTR-9C right is cheaper than answering the notice it prevents.
How CorporateWalla helps
We reconcile your GSTR-9 against the audited financials line by line, explain every difference, and file a clean, defensible GSTR-9C — plus the GSTR-9 annual return — before the December deadline.
All fees and charges are indicative only and do not constitute a binding offer. Government fees are paid at actuals. Final amounts may vary depending on the volume of work and the complexity involved.
Frequently Asked Questions
Q: Is a GST audit by a CA still compulsory?
A: No. The mandatory CA / CMA audit under the old Section 35(5) was removed. GSTR-9C is now a self-certified reconciliation under Section 44.
Q: Who needs to file GSTR-9C?
A: Registered persons with aggregate turnover above ₹5 crore in the financial year, in addition to GSTR-9.
Q: What is the turnover limit for GSTR-9?
A: GSTR-9 (annual return) is mandatory above ₹2 crore and optional at or below ₹2 crore.
Q: When is GSTR-9C due?
A: By 31 December following the end of the financial year.