GSTR-9C applicability and turnover limit
GSTR-9C, the GST reconciliation statement, becomes applicable once a taxpayer's aggregate turnover in a financial year crosses ₹5 crore. Since FY 2020-21, it has been self-certified by the taxpayer, replacing the earlier requirement of certification by a practicing chartered accountant or cost accountant.
The ₹5 crore threshold
Once a taxpayer's aggregate turnover for a financial year exceeds ₹5 crore, filing GSTR-9C becomes mandatory in addition to GSTR-9. Aggregate turnover for this purpose is computed on an all-India, PAN-wide basis — it isn't limited to a single GSTIN if a business holds multiple registrations under the same PAN across states.
Self-certification since FY 2020-21
GSTR-9C was originally required to be certified by a practicing chartered accountant or cost accountant before submission. That requirement has been removed, and GSTR-9C has been self-certified by the taxpayer since FY 2020-21 — the business itself signs off on the reconciliation rather than obtaining a separate CA/CMA certificate. That said, the underlying reconciliation exercise — matching GSTR-9 figures against audited books, explaining variances, and identifying tax or ITC gaps — hasn't gotten any simpler, which is why many businesses still choose to have a CA prepare or review it even though a formal certificate is no longer mandatory.
Shunya's CA team handles GSTR-9 and GSTR-9C filing end to end — reconciliation, ITC review, and portal filing. Fully online.
Talk to a CA →What crossing the threshold triggers
Once GSTR-9C applies, the taxpayer needs audited financial statements for the year (or, where a statutory audit under another law doesn't apply, financials prepared and reviewed with the same rigour) to complete the reconciliation. Part A of the form reconciles turnover, tax paid, and input tax credit between the audited books and the annual return; Part B carries the self-certification.
What happens if turnover fluctuates near the threshold
GSTR-9C applicability is assessed year by year based on that specific financial year's aggregate turnover — crossing ₹5 crore in one year and falling back below it in a later year changes the requirement accordingly. Businesses hovering near the threshold should track turnover through the year rather than waiting until year-end to find out whether GSTR-9C applies.
Consequences of missing GSTR-9C when it applies
If GSTR-9C is applicable and not filed, the annual return filing for that year is treated as incomplete, and the taxpayer remains exposed to the applicable late fee and to department scrutiny for non-compliance. Because GSTR-9C is filed alongside GSTR-9 rather than as a fully independent return, it's worth building the reconciliation into your year-end closing process well before the due date rather than treating it as an afterthought.
Do I need a CA to certify my GSTR-9C?
No, not for a formal certificate — GSTR-9C has been self-certified by the taxpayer since FY 2020-21, and the earlier requirement for a chartered accountant's or cost accountant's certification has been removed. Many businesses still engage a CA to prepare or review the reconciliation given its complexity, but that engagement is now a business choice rather than a statutory requirement.
This article is for general information only. For your specific situation, consult a practicing CA.
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