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February 8, 2025

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Delayed Submission of Reconciliation Statement in GSTR-9C: No Late Fee or Penalty

Every registered taxpayer in the GST framework with a turnover exceeding five crores is eligible to file GSTR-9C. Filing it might be challenging for many businesses. Despite your best efforts, you could complete it within the deadlines. The CBIC has extended the submission date without late fees or penalties. It is useful for business owners who missed the original deadline. In this blog, we will explore the existing regulations and provisions for filing the annual reconciliation statement. We will explore the rules regarding how you can perform the delayed submission without incurring any late fee or penalty.

Understanding The Annual Return And Filing Requirements

A registered taxpayer with an annual turnover of two crores should file GSTR-9. The persons exempted from filing GSTR-9 are as follows.

1. Input Service Distributors

2. Casual Taxable persons

3. Non-Resident Taxable persons

4. Person liable to deduct TCS/TDS

December 31st of the following year is the last date to file GSTR-9.

GSTR-9C And Its Importance

You must file the annual reconciliation statement if your annual turnover exceeds 5 crores. The following documents you should attach with it are

1. Balance Sheet of the enterprise

2. Profit/Loss Statement (OR) Income/Expenditure Statement to ensure authenticity and accuracy.

It helps to find the difference between the sales and taxes shown in GST reports and those reflected in audited financial reports. The taxpayer can explain the difference with a reason. Also, It helps the authorities verify whether the GST returns that the taxpayer filed with self-certification are accurate and compliant.

Contents and Formats of GSTR-9C

The two main parts of GSTR-9C are as follows:

1. Part - A Reconciliation Statement

2. Verification/Self-Certification

Part-A Reconciliation Statement

The five parts of the Reconciliation Statement are as follows:

1. Part - I Basic Details include the financial year, GSTIN, Legal Name, and Trade Name.

2. Part - II Reconciliation of turnover declared in GSTR-9 with the turnover declared in the audited annual financial statement.

3. Part - III Reconciliation of the tax paid

4. Part - IV Reconciliation of the Input Tax Credit

5. Part - V Additional Liability due to non- reconciliation

Verification/Self-Certification

You should verify and self-certify the filled form

Procedure To Submit GSTR-9C

GSTR-9C should be filed with the annual return and audited accounts copy. The requirements of a taxpayer are listed below.

1. The taxpayer should have a valid GST Registration

2. The Login Credentials should be active.

3. The taxpayer must have filed GSTR-9.

4. The aggregate Turnover of the business should have exceeded 5 crores.

Step-by-step process to file using Offline Utility

You can create a JSON file with the offline utility. After creating a JSON file, you can upload it to the GST portal. The process includes the following steps.

1. Download GSTR-9 from the financial year and GSTR-9C tables derived from GSTR-9 by logging in to the GST portal.

2. To download the offline utility from the GST portal, select “Offline Tools” in the downloads tab and “GSTR-9C Offline Tool”. To download the form, Click here.

3. Fill the tables with relevant data and generate a PDF for review. Once you have verified, create a JSON file from it.

4. Select the “Annual Returns” from the “Returns” tab by logging into the portal.

5. If there are errors, make the changes, recreate the JSON file, and reupload it.

6. After uploading the JSON, add PDF files of balance sheets and Profit/Loss statements with a minimum of 2 files per section and not exceeding 5 MB.

7. To confirm the upload, click “Save” after uploading each document. After successful completion, you will see the message as “Processed”.

8. After all documents have been uploaded, the “Proceed to File” button becomes active.

9. Click the “Preview Draft GST-9C (Preview)” button to check the draft.

10. Click “Proceed to File” after verifying the documents. Check the verification details and to complete the process, click “File GSTR-9C”

11. To find the returns, go to the “Services” tab. To view the status, select “Returns” from the drop-down and choose “View Filed Returns”.

12. If there are errors while uploading JSON, you can rectify them by downloading the error file. You can re-upload it again.

GSTR-9 and GSTR-9C Late Fee

The late fee for GSTR-9 is Rs. 200 per day. Sometimes, It can be a maximum of 0.5% of the total business turnover in the state. If a taxpayer files GSTR-9 but not GSTR-9C, the penalty would be Rs. 25,000.

GSTR-9C Late Fee Waiving Conditions

As per recent notifications, the conditions under which the GSTR-9C late fee is waived are as follows:

1. On-time filing of GSTR-9

2. GSTR-9 Late fee is paid because of delayed submission

3. Handling Show Cause Notices issued by the Department, which is canceled as per the new notification

GSTR-9C Extended Deadline

31st March 2025 is the last date to file GSTR-9C from 2017-18 to 2022-23. Filing it by the deadline can prevent the GST notice and enjoy the benefit of the waiver.

Consequences of Late GSTR-9C Filing

The GST department will take severe action if you fail to file it within the deadline. During scrutinies, they may take action if they find differences in outward tax, tax liabilities, or input tax credit claims for purchase under the Reverse Charge Mechanism.

Issuance of Notices

The GST Department issues a show cause notice if the taxpayer does not file on time. The showcase is issued under Section 73 for non fraudulent discrepancies or Section 74 for fraudulent activities.

Penalties

According to CGST Act Section 125, the general penalty that the GST department can impose on the taxpayer is Rs.25000. Other penalties include State GST Penalties and Late fees. The GST department can carry out increased scrutiny, audits, and assessments.

Conclusion

According to Notification no. 8/2025 from CBIC, late fees exceeding the rate specified under Section 47(2) for the financial years up to 2022-23 are waived if the taxpayers file GSTR-9C on or before the 31st March 2025. It helps to avoid penalties, show cause notice, and further scrutiny.