GSTR 9C – A CLAUSE WISE ANALYSIS OF THE FORM

I. ABOUT
 It is 20 months since the biggest and boldest tax reform, GST was born.
 As in the case of any new born, GST too has undergone various changes and has attained major
milestones making the journey very hectic and overwhelming to the new parents (Tax payers &
professionals).
 GST audit and annual return is the last milestone marking the completion of its journey for F.Y.
2017-18.
 This being the first ever GST audit since GST was born, it is important we understand and analyze every
clause to be reported in the form GSTR 9C.
II. DISCLAIMER & CREDITS
 This article is based on Form GSTR 9C prescribed vide Notification No. 74/2018 dated 31-Dec-2018.
(Hopefully the format does not change at least by the time this article is published!)
 Information & interpretations have been gathered from ICAI publications & materials used by faculties
during the Certificate course on GST by ICAI.
III. APPLICABILITY
 Every registered person
 whose aggregate turnover (Taxable + Exempt + Exports + Interstate at PAN level)
 during a financial year (in the absence of clarification from Govt. and as provided in FAQ by ICAI, safe
to consider turnover of the whole FY including first quarter of F.Y. 2017-18 to reckon the limit)
 exceeds the prescribed limit of Rs. 2 crore (PAN based > Rs.2 crore, multiple GSTIN, all GSTIN’s to
get accounts audited)
shall get his accounts audited by a Chartered Accountant or a Cost Accountant.
IV. DUE DATE
 On or before 31st December following end of such financial year. The same has been extended now up to
30th June 2019 for F.Y. 2017-18 (vide Order No.03/ 2018–Central Tax dated 31st December, 2018).
V. MANNER OF FILING
 Form GSTR – 9C to be filed with Form GSTR – 9 electronically along with
1. Copy of the Audited Accounts
2. A reconciliation statement reconciling the value of supplies declared in the return with the audited
financial statements (Part-A of GSTR 9C)
3. Auditor certification (Part-B of GSTR 9C)
VI. PENAL PROVISIONS
 Late fee – Rs.200 per day upto 0.50% of turnover in the State or Union Territory
VII. CONTENTS OF FORM GSTR 9C WITH CLAUSE WISE ANALYSIS
 GSTR - 9C has two parts - Part A is the reconciliation statement along with certification by the assessee
and Part B is the Certification by the auditor.
 Analysis of each clause, wherever pertinent have been given in blue for easy identification.
Part – A – Reconciliation Statement

Pt. I Basic Details Remarks

1 Financial Year  2017-2018
2 GSTIN  State wise PAN based 15-digit number
3A Legal Name <Auto Populated>
3B Trade Name (if any) <Auto Populated>
4 Are you liable to audit under any Act?  Eg. Audit under Income Tax Act, 1961;
Companies Act, 2013, Societies Registration Act
etc.
Pt. II Reconciliation of turnover declared in audited Annual Financial Statement with turnover
declared in Annual Return (GSTR9)
5 Reconciliation of Gross Turnover
A Turnover (including exports) as per Will include:
audited financial statements for the State  Only “Revenue from operations” as per FS to be
/ UT (For multi-GSTIN units under disclosed.
same PAN the turnover shall be derived  Turnover for the period April 17 to March 18 to
from the audited Annual Financial be disclosed (including Pre GST turnover). Same
Statement) is later deducted in Clause 5(G) below.
 In case of multiple GSTIN, turnover to be derived
for each GSTIN from audited FS.
Will NOT include:
 Other Income (eg. Sale of FA etc.) on which GST
may be levied can be reflected in Clause 5(O).
Hence not to be included here.
 Inward supplies on which GST charged under
RCM not to be included. Only turnover as per FS!
 Supply to SEZ/ Export from SEZ will not be
included for regular GSTIN. It will be included in
the turnover of SEZ GSTIN, since SEZ will have
separate GSTIN
B Unbilled revenue at the (+)  Unbilled revenue recognized in the books of
beginning of Financial Year accounts before 1-July-2017, but invoice issued
under GST law on which GST is payable is to be
added here.
 Eg. Rental/ Maintenance contract, billing on 10th
of subsequent month.
C Unadjusted advances at the end (+) Will include:
of the Financial Year  Advance received for services for which supply

Will NOT include:
D Deemed Supply under Schedule I (+)
E Credit Notes issued after the end (-)
of the financial year but reflected
in the annual return
F Trade Discounts accounted for in (+)
the audited Annual Financial
Statement but are not permissible
under GST
G Turnover from April 2017 to (-)
June 2017
H Unbilled revenue at the end of (-)
Financial Year
I Unadjusted Advances at the (-)
beginning of the Financial Year
J Credit notes accounted for in the (+)
audited Annual Financial
Statement but are not permissible
under GST
K Adjustments on account of (-)
supply of goods by SEZ units to
DTA Units
not made as at 31-March-2018
 Advance received for goods received before
15-Nov-2017 for which supply not made as at
31-March-2018
 Advance received for Exempt services
 Advance received for goods received after
15-Nov-2017
 Advance received and invoices raised upto
31-March-2018 (adjusted advances)
 Financial advances which are not adjustable
against any services
 Sch. I of CSGT Act deals with transactions
deemed as supply even if made without
consideration
 These transactions will NOT be part of books.
Hence, we as auditors have to exercise due
diligence in identifying such transactions
 Credit notes pertaining to supply made during
F.Y. 2017-18, issued after 31-March-2018 but
reflected in GSTR – 9. (Very rare)
 We are expected to verify GST returns for April
to September 2018 to identify such cases
 Pertains to trade discount GIVEN
 Post supply discount is to be added here (not
eligible as deduction under GST), if ANY of the
following are NOT satisfied:
- Mentioned in agreement at or before time of
supply
- Discount linked to relevant invoices
- ITC attributable to the discount has been
reversed
 As mentioned earlier in Clause 5(A), Pre GST
turnover to be deducted
 Similar to Clause 5(B), pertains to revenue
recognized in the books of accounts on or before
31-March-2018, but invoice issued after
31-March-2018.
 Advances on which GST was not liable as on
1-July-2017, but was recognized as revenue.
 Applicable only to assessees engaged in supply of
services, since the erstwhile service tax was liable
on advance received.
 Similar to clause 5(F) above.
 Applicable only when BOE filed by DTA for
supply by SEZ.
 To be reported by SEZ unit
L Turnover for the period under (-)
composition scheme
M Adjustments in turnover under (+/-)
section 15 and rules thereunder
N Adjustments in turnover due to (+/-)
foreign exchange fluctuations
O Adjustments in turnover due to (+/-)
reasons not listed above
P Annual turnover after
adjustments as above
Q Turnover as declared in Annual
Return (GSTR 9)
R Un-Reconciled turnover (Q - P)
6 Reasons for Un-reconciled difference in Annual Gross Turnover
A Reason 1
B Reason 2
C Reason 3
7 Reconciliation of Taxable Turnover
A Annual turnover after
adjustments (from 5P above)
B Value of Exempted, Nil Rated,
Non-GST supplies, No-Supply
turnover
C Zero rated supplies without
payment of tax
 If composition scheme was opted out for part of
the period during July 2017 to March 2018,
turnover may include both as composition &
normal.
 Composition turnover to be excluded here since
they are required to file GSTR 9A
 Applicable in following cases, where transaction
value is NOT Taxable value for GST
- Non-monetary consideration
- Related persons
- Interstate branches
- Agent transactions
 For the purpose of exports / imports, taxable value
under GST is arrived at on the basis of CBEC
Exchange Rates. The difference between values
as per CBEC rates and that adopted in AFS must
be reported here
 Transactions not considered as turnover but
constitute income for the purpose of GST
 Eg. Sale of capital goods
 Reimbursements Sales promotion / advertisement
 Reimbursement of out of pocket expenses
 Notice pay recovery
 Return of pre-GST inward supplies etc.
<Auto Populated>
AT1
 Eg. The conditions relevant for the zero-rated supply has
not been complied by the registered person, can be
construed to be a regular supply.
 Eg. Transaction reported through delivery challan during
the financial year for supply on sale or approval basis
beyond a period of six months shall be deemed to be a
supply under GST.
 Eg. Exemption conditions not fulfilled by the registered
person.
<Auto Populated>
 Exempted supplies – Supplies that are wholly or partially
exempted by way of notification
 Nil rated - Supplies taxable at a ‘NIL’ rate of tax
 Non-taxable - supplies that are not taxable under the Act
(viz. alcoholic liquor for human consumption)
 No-supply – Schedule III activities
 Two types of zero-rated supplies, SEZ and exports
effected by
 - Supply on payment of IGST
- Supply under LUT
 Supplies under LUT without payment of tax to be
reported here – info may be gathered from shipping bills
D Supplies on which tax is to be  Eg. GTA, advocate, Director sitting fees
paid by the recipient on reverse
charge basis
E Taxable turnover as per <Auto Populated>
adjustments above (A-B-C-D)
F Taxable turnover as per liability  As per clause 4M of GSTR 9
declared in Annual Return
(GSTR9)
G Unreconciled taxable turnover AT2
(F-E)
8 Reasons for Un-reconciled difference in taxable turnover
A Reason 1
B Reason 2  Similar to Clause 6 above
C Reason 3
Pt. III Reconciliation of tax paid
9 Reconciliation of rate wise liability and amount payable thereon
Tax payable
Description Taxable Value CGST SGST/ IGST Cess, if
UTGST applicable
1 2 3 4 5 6
A 5%  Payable on outward supply under Forward charge
B 5%(RC)  Payable on inward supply under Reverse charge (RC)
C 12%
D 12%(RC)
E 18%
F 18%(RC)
G 28%
H 28%(RC)
I 3%
J 0.25%
K 0.10%
L Interest
M Late fee
N Penalty
O Others
P Total amount to be paid as per tables above <Auto Populated>
Q Total amount paid as declared in Annual Return
(GSTR 9)
R Unreconciled payment of amount (PT1)
10 Reasons for un-reconciled payment of amount
A Reason 1  Eg. GSTR 3B shows less/more tax paid for various reason
B Reason 2  GSTR 1 and GSTR 3B inter se matching but not with the Audited
Financials
C Reason 3  Taxable turnover as per the books matching in GSTR 1 and GSTR
3B but tax is not matching.
 11 Additional amount payable but not paid (due to reasons specified under Tables
6,8 and 10 above)
To be paid through Cash
Description Value CGST SGST/ IGST Cess, if
UTGST applicable
1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Input Tax credit
Interest
Late fee
Penalty
Others (Pl. specify)
Pt. IV Reconciliation of Input Tax Credit (ITC)
12 Reconciliation of Net Input Tax Credit (ITC)
A ITC availed as per audited Annual Financial  ITC availed on inputs, input services &
Statement for the State/ UT (For multi-GSTIN capital goods
units under same PAN this should be derived
from books of accounts)
B ITC booked in earlier Financial Years claimed in  TRAN ITC claimed has to be reported
current Financial Year under this Clause. Auditor has to verify
the eligibility of TRAN ITC and the filing
of TRAN – 1 & TRAN – 2 forms
C ITC booked in current Financial Year to be  ITC which were for any reason
claimed in subsequent Financial Years (inadvertent or conditions not being
fulfilled) were not taken in returns as
filed from July 2017- March 2018.
D ITC availed as per audited financial statements <Auto Populated>
or books of account
E ITC claimed in Annual Return (GSTR9)
F Un-reconciled ITC ITC1
13 Reasons for un-reconciled difference in ITC
A Reason 1  Eg. ITC of another GSTIN claimed in returns of GSTIN under
audit
B Reason 2  Eg. Duplicate ITC availed
C Reason 3  Eg. ITC of subsequent year where goods / services were received
later but their invoice was received prior was availed.
14 Reconciliation of ITC declared in Annual Return (GSTR9) with ITC availed on
expenses as per audited Annual Financial Statement or books of account
Description Value Amount of Total ITC Amount of eligible
ITC availed
1 2 3 4
A Purchases
B Freight/ Carriage
 C Power & Fuel
D Imported goods
(Including received
from SEZs)
E Rent and Insurance
F Goods lost, stolen,
destroyed, written off
or disposed of by way
of gift or free samples
G Royalties
H Employees' Cost
(Salaries, wages,
Bonus etc.)
I Conveyance charges
J Bank Charges
K Entertainment charges
L Stationery Expenses
(including postage
etc.)
M Repair and
Maintenance
N Other Miscellaneous
Expenses
O Capital goods
P Any other expense 1
Q Any other expense 2
R Total amount of eligible ITC availed <Auto Populated>
S ITC claimed in Annual Return (GSTR9)
T Un-reconciled ITC ITC2
15 Reasons for un-reconciled difference in ITC
A Reason 1  Eg. Ineligible ITC availed by the Registered person
B Reason 2  Eg. ITC booked in the books of accounts but not availed including
ineligible ITC not availed (lapsed)
C Reason 3  Eg. In case of a negative amount, such difference can arise on
account of ITC booked in the books of accounts but availed in
return GSTR 3B of the subsequent year.
16 Tax payable on un-reconciled difference in ITC (due to reasons specified in 13
and 15 above)
Description Amount payable
CGST
SGST/ UTGST
IGST
Cess
Interest
Penalty
Pt. V Auditor's recommendation on additional Liability due to non-reconciliation
To be paid through Cash
Description Value CGST SGST/ IGST Cess, if
UTGST applicable
 1 2 3 4 5 6
5%
12%
18%
28%
3%
0.25%
0.10%
Input Tax credit
Interest
Late fee
Penalty
Any other amount paid
for supplies not
included in Annual
Return (GSTR 9)
Erroneous refund to be
paid back
Outstanding demands
to be settled
Other (Pl. specify)
Verification:
I hereby solemnly affirm and declare that the information given herein above is true and correct to the best of
my knowledge and belief and nothing has been concealed there from.
**(Signature and stamp/Seal of the Auditor)
Place:
Name of the signatory:
Membership No:
Date:
Full address:
Verification of registered person:
I hereby solemnly affirm and declare that I am uploading the reconciliation statement in FORM GSTR-9C
prepared and duly signed by the Auditor and nothing has been tampered or altered by me in the statement. I am
also uploading other statements, as applicable, including financial statement, profit and loss account and balance
sheet etc.
Signature
Place:
Date:
Name of Authorized Signatory
Designation/status
 Part – B- Certification
I. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by the person who
had conducted the audit (Kindly refer format for text of Certificate))
II. Certification in cases where the reconciliation statement (FORM GSTR-9C) is drawn up by a person other
than the person who had conducted the audit of the accounts (Kindly refer format for text of Certificate)
A brief summary of the contents of the certificate is as follows:
1. We have examined of the BS, P&L & Cash flow;
2. Registered person has maintained the books of accounts, records and documents as required by the GST
Laws and the rules/notifications made/issued thereunder;
3. Any observations/ comments & report that all information obtained, proper books maintained and FS are
in agreement with the books;
4. The documents required to be furnished under section 35 (5) of the CGST Act/SGST Act and
Reconciliation Statement required to be furnished under section 44(2) of the CGST Act/SGST Act is
annexed herewith in Form No. GSTR-9C;
5. The particulars given in the said Form No. GSTR-9C are true and correct.
VIII. CONCLUSION
 On an analysis of the above Form GSTR 9C, we may conclude that GST audit is not a mere
reconciliation of the books with returns.
 Additionally, it seems to cast a huge responsibility on us auditors.
 Therefore, now is the perfect time to prepare and equip ourselves for the challenge ahead, as it is said
that “All is well, that ends well!”.

The writer T.M.Malavika,.B.Com, F.C.A, DISA, is a partner in NRD Associates, Coimbatore. Article dated
25-Jan-2019.