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Reconciliation Statement & Certification GSTR- 9C

Updated: Dec 5, 2019

Instructions: –

  1. Terms used:

(a) GSTIN: Goods and Services Tax Identification Number

  1. The details for the period between July 2017 to March 2018 are to be provided in this

statement for the financial year 2017-18. The reconciliation statement is to be filed for

every GSTIN separately.

  1. The reference to current financial year in this statement is the financial year for which the

reconciliation statement is being filed for.

  1. Part II consists of reconciliation of the annual turnover declared in the audited Annual

Financial Statement with the turnover as declared in the Annual Return furnished in

FORM GSTR-9 for this GSTIN. The instructions to fill this part are as follows :-

Table No. Instructions

  1. 5A The turnover as per the audited Annual Financial Statement shall be declared

here. There may be cases where multiple GSTINs (State-wise) registrations

exist on the same PAN. This is common for persons / entities with presence

over multiple States. Such persons / entities, will have to internally derive

their GSTIN wise turnover and declare the same here. This shall include

export turnover (if any). It may be noted that reference to audited Annual

Financial Statement includes reference to books of accounts in case of persons

/ entities having presence over multiple States.

  1. 5B Unbilled revenue which was recorded in the books of accounts on the basis of

accrual system of accounting in the last financial year and was carried forward

to the current financial year shall be declared here. In other words, when GST

is payable during the financial year on such revenue (which was recognized

earlier), the value of such revenue shall be declared here.

(For example, if rupees Ten Crores of unbilled revenue existed for the

financial year 2016-17, and during the current financial year, GST was paid on

rupees Four Crores of such revenue, then value of rupees Four Crores rupees

shall be declared here)

  1. 5C Value of all advances for which GST has been paid but the same has not been

recognized as revenue in the audited Annual Financial Statement shall be

declared here.

  1. 5D Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017

shall be declared here. Any deemed supply which is already part of the

turnover in the audited Annual Financial Statement is not required to be

included here.

  1. 5E Aggregate value of credit notes which were issued after 31st of March for any

supply accounted in the current financial year but such credit notes were

reflected in the annual return (GSTR-9)shall be declared here.

  1. 5F Trade discounts which are accounted for in the audited Annual Financial

Statement but on which GST was leviable(being not permissible) shall be

declared here.

  1. 5G Turnover included in the audited Annual Financial Statement for April 2017 to

June 2017 shall be declared here.

  1. 5H Unbilled revenue which was recorded in the books of accounts on the basis of

accrual system of accounting during the current financial year but GST was

not payable on such revenue in the same financial year shall be declared here.

  1. 5I Value of all advances for which GST has not been paid but the same has been

recognized as revenue in the audited Annual Financial Statement shall be

declared here.

  1. 5J Aggregate value of credit notes which have been accounted for in the audited

Annual Financial Statement but were not admissible under Section 34 of the

CGST Act shall be declared here.

  1. 5K Aggregate value of all goods supplied by SEZs to DTA units for which the

DTA units have filed bill of entry shall be declared here.

  1. 5L There may be cases where registered persons might have opted out of the

composition scheme during the current financial year. Their turnover as per

the audited Annual Financial Statement would include turnover both as

composition taxpayer as well as normal taxpayer. Therefore, the turnover for

which GST was paid under the composition scheme shall be declared here.

  1. 5M There may be cases where the taxable value and the invoice value differ due to

valuation principles under section 15 of the CGST Act, 2017 and rules

thereunder. Therefore, any difference between the turnover reported in the

Annual Return (GSTR 9) and turnover reported in the audited Annual

Financial Statement due to difference in valuation of supplies shall be declared

here.

  1. 5N Any difference between the turnover reported in the Annual Return (GSTR9)

and turnover reported in the audited Annual Financial Statement due to

foreign exchange fluctuations shall be declared here.

  1. 5O Any difference between the turnover reported in the Annual Return (GSTR9)

and turnover reported in the audited Annual Financial Statement due to

reasons not listed above shall be declared here.

  1. 5Q Annual turnover as declared in the Annual Return (GSTR 9) shall be declared

here. This turnover may be derived from Sr. No. 5N, 10 and 11 of Annual

Return (GSTR 9).

  1. 6 Reasons for non-reconciliation between the annual turnover declared in the

audited Annual Financial Statement and turnover as declared in the Annual

Return (GSTR 9) shall be specified here.

  1. 7 The table provides for reconciliation of taxable turnover from the audited

annual turnover after adjustments with the taxable turnover declared in annual

return (GSTR-9).

  1. 7A Annual turnover as derived in Table 5P above would be auto-populated here.

  2. 7B Value of exempted, nil rated, non-GST and no-supply turnover shall be

declared here. This shall be reported net of credit notes, debit notes and

amendments if any.

  1. 7C Value of zero rated supplies (including supplies to SEZs) on which tax is not

paid shall be declared here. This shall be reported net of credit notes, debit

notes and amendments if any.

  1. 7D Value of reverse charge supplies on which tax is to be paid by the recipient

shall be declared here. This shall be reported net of credit notes, debit notes

and amendments if any.

  1. 7E The taxable turnover is derived as the difference between the annual turnover

after adjustments declared in Table 7A above and the sum of all supplies

(exempted, non-GST, reverse charge etc.) declared in Table 7B, 7C and 7D

above.

  1. 7F Taxable turnover as declared in Table 4N of the Annual Return (GSTR9) shall

be declared here.

  1. 8 Reasons for non-reconciliation between adjusted annual taxable turnover as

derived from Table 7E above and the taxable turnover declared in Table 7F

shall be specified here.

  1. Part III consists of reconciliation of the tax payable as per declaration in the reconciliation

statement and the actual tax paid as declared in Annual Return (GSTR9). The instructions

to fill this part are as follows :-

Table No. Instructions

  1. 9 The table provides for reconciliation of tax paid as per reconciliation statement

and amount of tax paid as declared in Annual Return (GSTR 9). Under the

head labelled ―RC‖, supplies where tax was paid on reverse charge basis by

the recipient (i.e. the person for whom reconciliation statement has been

prepared ) shall be declared.

  1. 9P The total amount to be paid as per liability declared in Table 9A to 9O is auto

populated here.

  1. 9Q The amount payable as declared in Table 9 of the Annual Return (GSTR9)

shall be declared here. It should also contain any differential tax paid on Table

10 or 11 of the Annual Return (GSTR9).

10 Reasons for non-reconciliation between payable / liability declared in Table

  1. 9P above and the amount payable in Table 9Q shall be specified here.

11 Any amount which is payable due to reasons specified under Table 6, 8 and 10

above shall be declared here.

  1. Part IV consists of reconciliation of Input Tax Credit (ITC). The instructions to fill Part

IV are as under:-

Table No. Instructions

  1. 12A ITC availed (after reversals) as per the audited Annual Financial Statement

shall be declared here. There may be cases where multiple GSTINs (Statewise)

registrations exist on the same PAN. This is common for persons /

entities with presence over multiple States. Such persons / entities, will have

to internally derive their ITC for each individual GSTIN and declare the same

here. It may be noted that reference to audited Annual Financial Statement

includes reference to books of accounts in case of persons / entities having

presence over multiple States.

  1. 12B Any ITC which was booked in the audited Annual Financial Statement of

earlier financial year(s)but availed in the ITC ledger in the financial yearfor

which the reconciliation statement is being filed for shall be declared here.

This shall include transitional credit which was booked in earlier years but

availed duringFinancial Year 2017-18.

  1. 12C Any ITC which has been booked in the audited Annual Financial Statement of

the current financial year but the same has not been credited to the ITC ledger

for the said financial year shall be declared here.

  1. 12D ITC availed as per audited Annual Financial Statement or books of accounts

as derived from values declared in Table 12A, 12B and 12C above will be

auto-populated here.

  1. 12E Net ITC available for utilization as declared in Table 7J of Annual Return

(GSTR9) shall be declared here.

  1. 13 Reasons for non-reconciliation of ITC as per audited Annual Financial

Statement or books of account (Table 12D) and the net ITC (Table12E)

availed in the Annual Return (GSTR9) shall be specified here.

  1. 14 This table is for reconciliation of ITC declared in the Annual Return (GSTR9)

against the expenses booked in the audited Annual Financial Statement or

books of account. The various sub-heads specified under this table are general

expenses in the audited Annual Financial Statement or books of account on

which ITC may or may not be available. Further, this is only an indicative list

of heads under which expenses are generally booked. Taxpayers may add or

delete any of these heads but all heads of expenses on which GST has been

paid / was payable are to be declared here.

  1. 14R Total ITC declared in Table 14A to 14Q above shall be auto populated here.

  2. 14S Net ITC availed as declared in the Annual Return (GSTR9) shall be declared

here. Table 7J of the Annual Return (GSTR9) may be used for filing this

Table.

  1. 15 Reasons for non-reconciliation between ITC availed on the various expenses

declared in Table 14R and ITC declared in Table 14S shall be specified here.

16 Any amount which is payable due to reasons specified in Table 13 and 15

above shall be declared here.

  1. Part V consists of the auditor’s recommendation on the additional liability to be

discharged by the taxpayer due to non-reconciliation of turnover or non-reconciliation of

input tax credit. The auditor shall also recommend if there is any other amount to be paid

for supplies not included in the Annual Return. Any refund which has been erroneously

taken and shall be paid back to the Government shall also be declared in this table. Lastly,

any other outstanding demands which is recommended to be settled by the auditor shall

be declared in this Table.

  1. Towards, the end of the reconciliation statement taxpayers shall be given an option to pay

their taxes as recommended by the auditor.

PART – B- CERTIFICATION

  1. Certification in cases where the reconciliation statement (FORM GSTR-9C)

is drawn up by the person who had conducted the audit:

* I/we have examined the—

(a) balance sheet as on ………

(b) the *profit and loss account/income and expenditure account for the period beginning

from ………..…to ending on ……., and

(c) the cash flow statement for the period beginning from ……..…to ending on ………, —

attached herewith, of M/s …………… (Name), …………………….………… (Address),

..…………………(GSTIN).

  1. Based on our audit I/we report that the said registered person—

*has maintained the books of accounts, records and documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

*has not maintained the following accounts/records/documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

1.

2.

3.

  1. (a) *I/we report the following observations/ comments / discrepancies / inconsistencies; if

any:

…………………………………….

…………………………………….

  1. (b) *I/we further report that, –

(A) *I/we have obtained all the information and explanations which, to the best of *my/our

knowledge and belief, were necessary for the purpose of the audit/ information and

explanations which, to the best of *my/our knowledge and belief, were necessary for the

purpose of the audit were not provided/partially provided to us.

(B) In *my/our opinion, proper books of account *have/have not been kept by the registered

person so far as appears from*my/ our examination of the books.

(C) I/we certify that the balance sheet, the *profit and loss/income and expenditure account

and the cash flow Statement are *in agreement/not in agreement with the books of account

maintained at the Principal place of business at ……………………and **

……………………additional place of business within the State.

  1. The documents required to be furnished under section 35 (5) of the CGST Act and

Reconciliation Statement required to be furnished under section 44(2) of the CGST Act is

annexed herewith in Form No. GSTR-9C.

  1. In *my/our opinion and to the best of *my/our information and according to explanations

given to *me/us, the particulars given in the said Form No.GSTR-9C are true and correct

subject to following observations/qualifications, if any:

(a) ……………………………………………………………………………………

(b) ……………………………………………………………………………………

(c) ……………………………………………………………………………………

………………………………………

………………………………………

**(Signature and stamp/Seal of the Auditor)

Place: ……………

Name of the signatory …………………

Membership No………………

Date: ……………

Full address ………………………

  1. 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:

*I/we report that the audit of the books of accounts and the financial statements of M/s.

………………..…………………. (Name and address of the assessee with GSTIN) was

conducted by M/s. …………………………………………..………. (full name and address

of auditor along with status), bearing membership number in pursuance of the provisions of

the …………………………….Act, and *I/we annex hereto a copy of their audit report dated

……………………………. along with a copy of each of :-

(a) balance sheet as on ………

(b) the *profit and loss account/income and expenditure account for the period beginning

from ………..…to ending on …….,

(c) the cash flow statement for the period beginning from ……..…to ending on ………, and

(d) documents declared by the said Act to be part of, or annexed to, the *profit and loss

account/income and expenditure account and balance sheet.

  1. I/we report that the said registered person—

*has maintained the books of accounts, records and documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder

*has not maintained the following accounts/records/documents as required by the

IGST/CGST/<<>>GST Act, 2017 and the rules/notifications made/issued thereunder:

1.

2.

3.

  1. The documents required to be furnished under section 35 (5) of the CGST Act and

Reconciliation Statement required to be furnished under section 44(2) of the CGST Act is

annexed herewith in Form No.GSTR-9C.

  1. In *my/our opinion and to the best of *my/our information and according to examination

of books of account including other relevant documents and explanations given to *me/us,

the particulars given in the said Form No.9C are true and correct subject to the following

observations/qualifications, if any:

(a) …………………………….…………………………….………………………

(b) …………………………….…………………………….………………………

(c) …………………………….…………………………….………………………

………………………………………

**(Signature and stamp/Seal of the Auditor)

Place: ……………

Name of the signatory …………………

Membership No………………

Date: ……………

Full address ………………………‖.

[F. No. 349/58/2017-GST (Pt.)]

(Gunjan Kumar Verma)

Under Secretary to the Government of India

Note:- The principal rules were published in the Gazette of India, Extraordinary, Part II,

Section 3, Sub-section (i) vide notification No. 3/2017-Central Tax, dated the 19th June,

2017, published vide number G.S.R 610 (E), dated the 19th June, 2017 and last amended

vide notification No. 48/2018-Central Tax, dated the 10th September, 2018, published vide

number G.S.R 859 (E), dated the 10th September, 2018.

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