GST Annual Return (GSTR 9,9A,9B & 9C) For FY 2023-24

Introduction:

GST annual returns are a key part of India’s GST compliance. Registered taxpayers are required to file these returns to provide a summary of their annual transactions, including supplies, tax payments, and input tax credits (ITC). This Blog explains GSTR 9 and its types, non-filing causes, and challenges faced in annual filings.

What is GSTR 9?

• Form GST 9 is an annual return, filed yearly by the GST-registered taxpayers. It consolidates all the quarterly and monthly returns filed in the relevant year.

• It provides all outward and inward supplies made under different tax heads (CGST, SGST, IGST with cess) during the financial year.

• Essentially, this form helps the GST authorities assess the total tax liability and credits availed by taxpayers.

Types of GSTR 9:

• GSTR 9: GSTR 1 and GSTR 3B filing taxpayers must file this return. Taxpayers with an annual GST turnover exceeding ₹2 crores must file GSTR-9.

• GSTR 9A: Taxpayers registered under the GST composition scheme

• GSTR 9B: This annual return applies to e-commerce operators collecting TCS and filing GSTR-8 monthly

• GSTR 9C: GSTR 9C is an annual reconciliation statement for taxpayers whose aggregate turnover exceeds Rs.5 crores

in a financial year.

Who should file GSTR 9?

Form	Turnover	Applicants
GSTR 9	2 crores	Regular taxpayers
GSTR 9A	NA	Composition dealers
GSTR 9B	NA	E-Commerce operators

Note: "GSTR 9C is exempted for Casual taxable persons, non-resident taxable persons, ISDs, and taxpayers under TDS/TCS provisions."

Consequences of Annual Non-filings:

Non-filings or Belated filings of GST Annual returns attract late fees based on taxpayer’s turnover. The Following late fee attracts from FY 2023-24 onwards,

1) GSTR 9/9A/9B:

Turnover limits	Late fee (per day of delay)	Maximum late fee
Up to 5 crores	₹50	0.04% of turnover instate/UT
5-20 crores	₹100	0.04% of turnover in state/UT
More than 20 crores	₹200	0.50% of turnover in state/UT

2) GSTR 9C: General Penalty of ₹50,000/

Common Reporting Challenge:

1. Outward related:

• Verify every income accounted as per books and reported correctly in the GST returns.

• Non-GST, exempted, and nil-rated supplies must be reported with corresponding ITC reversals, to avoid litigation risks.

• Proper documentation should support the values reported in Table 50 of GSTR-9C to avoid unaccounted differences or reconciliations

2. ITC related:

• Validate ITC values in Table 6 and Table 7 are reported correctly.

• Verify the annual reversals under Rules 42 and 43 are made appropriately.

• ITC values in Table 8 of GSTR-9 should be reported based on reconciliation of GSTR-2B and GSTR-3B, adhering to the latest GSTN advisories.

3. RCM related:

• Confirm that variations between RCM liability paid and RCM ITC

claimed in GSTR 3B are reported correctly.

• Reconcile and pay any liabilities if it is unpaid.

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FAQ

Is it mandatory to file Form GSTR-9?

Ans: Yes, GSTR 9 must be filed by all GST-registered taxpayers with an

annual turnover exceeding 2 crores.

Is the GSTR 9 mandatory for the companies below 2 crores?

Is it possible to file a GSTR-9 with no tax liability?

Can GSTR-9C be filed without GSTR-9?

Can we revise the filed GSTR 9 & 9C?