GST Annual Return (GSTR-9)
Comprehensive annual GST return filing with reconciliation and audit support.
Who this is for
- Annual reconciliation
- GSTR-9 & GSTR-9C
- Audit support
- Complete compliance
The process
What we actually do
- 1
We reconcile the returns against the books first
Turnover per GSTR-1, turnover per GSTR-3B and turnover per the financial statements all have to be tied together, with each difference explained — a credit note, an exempt supply, a timing difference at the year end. The differences are normal; unexplained differences are not.
- 2
We reconcile input credit against GSTR-2B for the whole year
Credit claimed in 3B against credit available in 2B, month by month, with the excess identified and either supported or reversed. Doing this at the annual return rather than monthly is how businesses discover in December that a supplier never filed in April.
- 3
We check what the section 16(4) deadline has already closed
Credit for a financial year cannot be claimed after 30 November following it. Anything still unclaimed at that point is lost permanently, and the annual return is where it becomes visible.
- 4
We prepare GSTR-9C where it applies
Above ₹5 crore turnover the reconciliation statement is self-certified and filed with the annual return. It reconciles the audited turnover and the tax paid, and every unreconciled item has to carry a reason.
- 5
We pay any shortfall through DRC-03
Additional liability identified in the reconciliation is paid through Form DRC-03. Voluntary payment at this stage costs interest; the same liability found in an audit costs interest and penalty.
Who this is for
- Every registered business with turnover above ₹2 crore, for whom GSTR-9 is mandatory
- Businesses above ₹5 crore turnover, who must also file the GSTR-9C reconciliation
- Anyone whose GST turnover and income tax turnover do not currently agree
- Businesses that claimed input credit during the year that is not fully supported by GSTR-2B
- Composition dealers, who file GSTR-9A or GSTR-4 depending on the year
How long it takes
Two to four weeks where the monthly returns were reconciled as the year went. Where they were not, the work is a full-year reconciliation and the timeline depends on how many months disagree — which is why the annual return is the wrong moment to start reconciling.
If you do nothing
The late fee runs and the reconciliation still has to be done eventually — usually at the point a GST audit or a departmental notice asks for it, when the explanations have to be constructed years after the transactions. A business that has never filed an annual return also has no consolidated position to hand a bank or an acquirer.
The law, in figures
Dates, thresholds and sections
| What | Figure | Source |
|---|---|---|
| Due date | 31 December following the financial year | Section 44, CGST Act 2017 |
| GSTR-9 threshold | Mandatory above ₹2 crore aggregate turnover | Notification 10/2022-Central Tax |
| GSTR-9C threshold | Above ₹5 crore aggregate turnover, self-certified | Section 35(5) as amended by Finance Act 2021 |
| Late fee | ₹200 per day, capped at 0.5% of turnover in the state | Section 47(2), CGST Act 2017 |
| Last date to claim credit for the year | 30 November following the financial year | Section 16(4), CGST Act 2017 |
What usually goes wrong
- Treating the annual return as an opportunity to correct the year — it reports, it does not amend
- Reconciling for the first time in December, when the credit deadline of 30 November has already passed
- Leaving the GST turnover and the income tax turnover to disagree, which both departments reconcile automatically
- Filing GSTR-9C without explaining each unreconciled item, which is what the form exists for
- Skipping the annual return below ₹2 crore and then needing it for a loan or a tender
What non-compliance costs
- ₹200 per day late fee, capped at 0.5% of state turnover
- Interest at 18% on any additional liability identified and paid late
- Interest at 24% on input credit wrongly availed and utilised
- Differences between the annual return and the income tax return are a standing audit trigger
These are statutory amounts, not our fees. What we charge depends on your situation and is quoted before any work starts.
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