Annual GST reconciliation requires matching audited financial statements against figures filed in monthly returns. While turnover reconciliation takes place in Part II and tax liability reconciliation in Part III, input tax credit expensed or capitalized across balance sheet heads falls under Part IV. Table 15 specifically documents the precise causes for unreconciled variances emerging from Table 14 expense-wise reviews, including capitalized assets, reverse charge liabilities, and vendor payment timing differences.
Statutory requirement for Table 15 reconciliation
Under CGST Rules Rule 80(3), every registered person whose aggregate turnover during a financial year exceeds five crore rupees must furnish a self-certified reconciliation statement in Form GSTR-9C along with the annual return. The framework connects audited ledger balances with return disclosures to verify that credit claims and outward tax liabilities are completely accounted for.
Taxpayers review the overall reconciliation landscape in our overview on the GSTR-9C reconciliation statement. While overall net credit variances are documented in Table 13 as detailed in our guide on GSTR-9C Table 12 unreconciled ITC reasons, Table 15 provides line-level explanations for discrepancies across individual expense categories, fixed asset accounts, and accrued liabilities.
Common mistake: Entering unclassified round lump sums in Table 15 without ledger-backed working sheets. Proper officers issue notices seeking invoice-wise backing when Table 15 explanations lack specific statutory grounds.
Key areas generating Table 15 discrepancies
- Capital goods and asset capitalization: GST paid on machinery, computers, or office equipment capitalized in the balance sheet rather than debited to profit and loss accounts.
- Reverse charge inward supplies: Unregistered RCM liabilities where tax is paid under Section 9(4) or Section 9(3), requiring recipient self-invoices that do not carry an Invoice Reference Number as confirmed in official CBIC e-Invoice Clarifications.
- Prepaid expenses and deferred charges: Invoices received and claimed in monthly returns during the financial year but amortized across subsequent accounting periods in financial accounts.
- Provisions and accrued liabilities: Year-end audit provisions for freight, legal fees, or contract labour where GST invoices are booked only in the subsequent financial year upon receipt.
Worked example: reconciling asset and liability variances
Consider an engineering firm in Pune with an aggregate turnover of ₹18,50,00,000. When comparing audited financial statements against Form GSTR-9, the accounts team identifies an unreconciled credit variance of ₹1,62,000 across other liabilities and capital asset ledgers. The team analyzes the difference across three distinct components:
| Head of Expense or Asset | ITC in Audited Books | ITC in GSTR-9 | Variance (₹) | Table 15 Discrepancy Note |
|---|---|---|---|---|
| Plant & Machinery (Fixed Assets) | ₹9,00,000 | ₹9,00,000 | ₹0 | Fully capitalized and claimed |
| Office Equipment (Capital Goods) | ₹1,80,000 | ₹0 | + ₹1,80,000 | Ineligible credit under Section 17(5)(a) capitalized to asset |
| Audit & Legal Fee Provisions | ₹0 | ₹36,000 | - ₹36,000 | Prior year provision invoice received and claimed in current year |
| Freight on Inward Goods (RCM) | ₹72,000 | ₹54,000 | + ₹18,000 | RCM liability unpaid on unregistered GTA services |
| Net Unreconciled Variance | ₹11,52,000 | ₹9,90,000 | + ₹1,62,000 | Documented in Table 15 and Table 16 |
The gross variance of ₹1,62,000 comprises ₹1,80,000 of blocked credit on company cars capitalized in books, ₹36,000 of prior year timing difference, and ₹18,000 of short-paid reverse charge liability. The net tax payable arising from the unpaid RCM liability is ₹18,000, which must be declared in Table 16.
Interest computation on unpaid liabilities
Under Section 50(1) of the CGST Act, interest on tax not paid within the prescribed period is payable at a rate not exceeding 18 percent per annum. In this example, the unpaid reverse charge tax of ₹18,000 was delayed by 120 days:
Interest = ₹18,000 × (18 / 100) × (120 / 365) = ₹1,065 (rounded to the nearest rupee).
Open the working file GSTR9C_TABLE15_RECON_2025_26.xlsx and cross-verify invoice line items against purchase ledgers before finalizing the submission.
“Every registered person whose aggregate turnover during a financial year exceeds five crore rupees shall furnish a self-certified reconciliation statement as specified under section 44 in FORM GSTR-9C along with the annual return.” Rule 80(3) of the Central Goods and Services Tax Rules, 2017
Discrepancy notes and corrective action checklist
- Identify the nature of variance: Classify each difference into timing differences, permanent non-creditable items, or outright omission of outward or reverse charge tax.
- Prepare ledger cross-references: Maintain a schedule linking balance sheet heads (Capital Work in Progress, Other Current Assets, Accrued Liabilities) to specific invoice lists.
- Verify RCM documentation: Ensure that reverse charge supplies from unregistered persons have corresponding payment vouchers and self-invoices issued under Section 31(3)(f).
- Compute differential tax and interest: Calculate short payment across IGST, CGST, and SGST, and compute interest at 18 percent per annum from the due date of the return to the date of actual payment.
- Discharge liability in cash: File Form DRC-03 on the common portal selecting the cause of payment as Reconciliation Statement (GSTR-9C).
Frequently asked questions
What is the primary role of Table 15 in Form GSTR-9C?
Table 15 records reasons for unreconciled differences between expense-related input tax credit declared in books or audited accounts and credit claimed in Form GSTR-9, covering liabilities, capitalized assets, and timing adjustments.
How does Table 15 differ from Table 13 in Form GSTR-9C?
Table 13 captures reasons for overall net input tax credit variances computed in Table 12, whereas Table 15 explains line-item discrepancies arising from expense heads, asset capitalizations, and liability reconciliations evaluated under Table 14.
What corrective actions are required when Table 15 reveals an underpayment?
Any additional tax liability resulting from unreconciled differences must be reported in Table 16 and discharged voluntarily in cash through Form DRC-03, along with applicable interest under Section 50.
Reconcile annual ITC before completing Form GSTR-9C
Catch missing vendor invoices, rate discrepancies, and timing variances across all 12 months before filing your annual reconciliation. Your GSTR-2B and purchase register files are read in your browser and never uploaded to any server.
Last checked: 22 October 2026. Sources: CBIC CGST Rule 80(3), CBIC e-Invoice Clarifications, CGST Act Section 50.