how to file gstr-9 and gstr-9c applicability and provision in gst

For GST, GSTR-9 (Annual Return) and GSTR-9C (Reconciliation Statement) have different applicability.

Applicability

Aggregate Turnover in FYGSTR-9GSTR-9CUp to ₹2 croreGenerally Not mandatory for FY 2024-25, subject to exemption notified for that yearNot applicableMore than ₹2 crore up to ₹5 croreMandatoryNot applicableMore than ₹5 croreMandatoryMandatory – self-certified

For GSTR-9C, the threshold is aggregate turnover exceeding ₹5 crore in the financial year. Since 1 August 2021, the reconciliation statement is self-certified, rather than requiring certification by a CA/CMA.

Important point – ₹5 crore is aggregate turnover

The ₹5 crore limit is not calculated GSTIN-wise. Aggregate turnover is considered on an all-India PAN basis, including taxable supplies, exempt supplies, exports and inter-State supplies, subject to the statutory exclusions.

For example:

• GSTIN 1 turnover = ₹3.50 crore
• GSTIN 2 turnover = ₹2.00 crore
• Same PAN
• Aggregate turnover = ₹5.50 crore

Therefore, GSTR-9 and GSTR-9C applicability would be determined with reference to the aggregate turnover, not merely the turnover of one GSTIN.

Also, inward supplies on which GST is payable under RCM are excluded from aggregate turnover.

Due date

Normally, GSTR-9 and applicable GSTR-9C are furnished by 31 December following the end of the financial year. CBIC has also clarified that where GSTR-9C is applicable, it forms part of the annual-return compliance along with GSTR-9.

Example – FY 2025-26:
Due date ordinarily = 31 December 2026.