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GSTR-9C: the reconciliation statement for FY 2025-26

For larger taxpayers the annual return has two parts: GSTR-9, the summary of the year’s GST, and GSTR-9C, which reconciles it to the audited financial statements. The second is where unexplained differences surface, so it is worth starting before December.

Reviewed by Vijay Dhawan, Managing Partner, LexVerge LLP, on · Published

Quick answer

GSTR-9C is filed by every registered person whose aggregate turnover for the year exceeds ₹5 crore, together with GSTR-9. Since FY 2020-21 it is self-certified by the taxpayer; a chartered accountant’s certification is no longer required. For FY 2025-26 it is due by 31 December 2026. There is no separate late fee for GSTR-9C: under CBIC Circular 246/03/2025, the GSTR-9 late fee keeps running until the complete annual return, including GSTR-9C, is filed.

GSTR-9 and GSTR-9C side by side

GSTR-9GSTR-9C
What it isAnnual return: outward supplies, ITC and tax for the yearReconciliation of GSTR-9 with the audited financial statements
Who filesMandatory above ₹2 crore turnover; optional below by yearly notificationAggregate turnover above ₹5 crore
CertificationSigned by the taxpayerSelf-certified by the taxpayer since FY 2020-21
Due date for FY 2025-2631 December 202631 December 2026, filed after GSTR-9
Late feePer day, capped by turnoverNone separately; GSTR-9’s fee runs until 9C is filed too

What GSTR-9C reconciles

GSTR-9C takes the figures in the audited financial statements and walks them to the figures in GSTR-9, explaining every difference:

  • Turnover: from the audited accounts to the turnover declared in the annual return, adjusting for unbilled revenue, credit notes, deemed supplies and items outside GST.
  • Taxable value and tax paid: rate by rate, so a short payment is identified.
  • Input tax credit: from the credit booked in the accounts to the credit claimed in the returns.
  • Additional liability: any tax found short is declared and paid through DRC-03.

The work is in the reconciliation, not the form: GSTR-1, GSTR-3B, GSTR-2B and the books must already agree, or the differences must be explained. Our GSTR-9 due date guide covers the late-fee caps and a timeline from October.

How to prepare, in order

  1. Close the books and get the statutory audit signed; 9C reconciles to audited figures.
  2. Reconcile GSTR-1 and GSTR-3B with the books month by month, and GSTR-2B with the purchase register.
  3. File GSTR-9, using the reconciliation to fill each table.
  4. Prepare GSTR-9C from the audited accounts, pay any extra tax through DRC-03 and file it with the authorised signatory’s DSC.

Frequently asked questions

Who has to file GSTR-9C?

Every registered person whose aggregate turnover in the financial year exceeds ₹5 crore, along with GSTR-9.

What is the due date for GSTR-9C for FY 2025-26?

31 December 2026, the same date as GSTR-9.

Does GSTR-9C need certification by a CA?

No. Since FY 2020-21 GSTR-9C is self-certified by the taxpayer. Many businesses still have a CA prepare it because it reconciles to the audited accounts.

Is there a late fee for GSTR-9C?

Not separately. CBIC Circular 246/03/2025 clarifies that the late fee for the annual return runs until the complete return, GSTR-9 and GSTR-9C where required, is filed.

What if GSTR-9C shows tax short paid?

Declare the additional liability in GSTR-9C and pay it, with interest, through Form DRC-03.

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Year-end reconciliation and GSTR-9 filed by a CA.

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Reviewed by Vijay DhawanManaging Partner, LexVerge LLP · reviewed on · How we write and check our guides

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