When closing the financial year, accounts teams must determine whether their GSTINs are legally required to submit an annual return. The statutory baseline under Section 44(1) of the CGST Act mandates an annual return for every registered person on or before 31 December following the end of the financial year. However, statutory exemptions and special category exclusions alter who actually needs to file.
The statutory 2 crore exemption threshold
Under the first proviso to Section 44 of the CGST Act, the Commissioner may, on the recommendations of the GST Council, exempt any class of registered persons from filing the annual return. Exercising this power, the Central Government notified the turnover relief initially through Notification No. 31/2021-Central Tax, exempting registered persons whose aggregate turnover in the financial year is up to two crore rupees.
This threshold applies at the PAN level, not on an individual state GSTIN alone. Section 2(6) of the CGST Act defines aggregate turnover as the aggregate value of all taxable supplies, exempt supplies, exports of goods or services, and inter-state supplies of persons having the same PAN, computed on an all-India basis.
Common mistake: Evaluating the ₹2,00,00,000 threshold state by state. If your business holds GST registrations in Maharashtra and Gujarat, and each reports ₹1,20,00,000 in outward supplies, your PAN aggregate turnover is ₹2,40,00,000. Both GSTINs cross the ₹2,00,00,000 exemption limit and must file Form GSTR-9.
Who is required to file Form GSTR-9
According to GSTN FAQs on Form GSTR-9 (Question 2), Form GSTR-9 is required to be filed by:
- Regular taxpayers: Any person registered as a regular taxpayer with aggregate turnover above ₹2,00,00,000.
- SEZ units and developers: Special Economic Zone units and developers registered as normal taxpayers.
- Taxpayers switching schemes: Businesses that were registered as a regular taxpayer for even a single day during the financial year, including those who opted out of the composition scheme into regular registration.
- Cancelled registrations: Taxpayers whose regular registration was cancelled or surrendered during the financial year, covering the period up to the effective date of cancellation.
For taxpayers with turnover exceeding ₹5,00,000,00, CGST Rules Rule 80(3) further mandates a self-certified reconciliation statement in Form GSTR-9C along with Form GSTR-9. For practical steps on preparing the annual filing, review our walkthrough on GSTR-9 filing step by step.
Who is exempt or excluded from GSTR-9
Not every GST registration files Form GSTR-9. Exclusions fall into statutory exclusions under Section 44 and category-specific returns under Rule 80:
| Registration category | Statutory provision | GSTR-9 requirement |
|---|---|---|
| Regular taxpayer (turnover up to ₹2 crore) | Section 44 first proviso | Exempt (optional filing) |
| Regular taxpayer (turnover above ₹2 crore) | Section 44(1) read with Rule 80(1) | Mandatory filing |
| Composition taxpayer (Section 10) | Rule 80(1) proviso | Form GSTR-4 / GSTR-9A (not GSTR-9) |
| Input Service Distributor (ISD) | Section 44(1) exclusion | Exempt from annual return |
| TDS deductor (Section 51) / TCS collector (Section 52) | Section 44(1) exclusion | Exempt from GSTR-9 (Form GSTR-9B for ECO) |
| Casual taxable person / Non-resident taxpayer | Section 44(1) exclusion | Exempt from annual return |
Composition scheme taxpayers
Under the proviso to Rule 80(1), a person paying tax under Section 10 does not file Form GSTR-9. Composition taxpayers furnish their annual return in Form GSTR-4. If a business was under composition for part of the financial year and switched to regular status, it files Form GSTR-9A for the composition period and Form GSTR-9 for the regular period, provided its PAN aggregate turnover crosses the exemption limit.
QRMP scheme filers
Taxpayers enrolled in the Quarterly Return Monthly Payment (QRMP) scheme file quarterly GSTR-1 and quarterly GSTR-3B with monthly challans. The QRMP facility modifies periodic return cycles, but does not provide an annual return waiver. If a QRMP filer has PAN aggregate turnover above ₹2,00,00,000, filing Form GSTR-9 remains compulsory.
Nil filers
Taxpayers often assume that a business with zero sales or purchases does not need to submit an annual return. Under GST portal rules, if your entity PAN turnover exceeds ₹2,00,00,000 due to other operating units, a dormant branch GSTIN cannot simply be ignored. That inactive GSTIN must file a Nil Form GSTR-9 on the portal.
According to GSTN FAQs on Form GSTR-9 (Question 10), a taxpayer can file a Nil GSTR-9 online if they satisfy all of the following conditions for the financial year:
- No outward supplies made (no taxable, exempt, or nil-rated sales).
- No inward supplies received (no purchases of goods or services).
- No other tax liability to report.
- No input tax credit claimed in GSTR-3B.
- No refund claimed during the year.
- No demand orders received from tax authorities.
- No late fee liability outstanding.
Worked example: multi-unit turnover assessment
Consider an enterprise operating three branches under a single PAN across two states. We evaluate each branch's outward turnover to determine whether GSTR-9 filing is required.
| Registration / Branch | Turnover in books | Filing scheme | GSTR-9 filing status |
|---|---|---|---|
| GSTIN 27AAACR1234A1Z1 (Maharashtra Main) | ₹1,45,00,000 | Regular (Monthly) | Mandatory (PAN > ₹2 crore) |
| GSTIN 27AAACR1234A2Z0 (Maharashtra Warehouse) | ₹0 | Regular (QRMP) | Mandatory (Nil GSTR-9) |
| GSTIN 24AAACR1234A1Z5 (Gujarat Branch) | ₹95,00,000 | Regular (Monthly) | Mandatory (PAN > ₹2 crore) |
| Total PAN aggregate turnover | ₹2,40,00,000 | Consolidated | Threshold exceeded |
Calculation and liability formula:
Total PAN aggregate turnover = ₹1,45,00,000 + ₹0 + ₹95,00,000 = ₹2,40,00,000. Because ₹2,40,00,000 exceeds the statutory exemption limit of ₹2,00,00,000, all three GSTINs must file Form GSTR-9. The warehouse GSTIN with zero turnover must file a Nil GSTR-9 on the portal.
Frequently asked questions
Is GSTR-9 mandatory if aggregate turnover is below 2 crore rupees?
No. Under the first proviso to Section 44 of the CGST Act read with Notification No. 31/2021-Central Tax, regular taxpayers whose aggregate turnover does not exceed two crore rupees in the financial year are exempt from filing Form GSTR-9.
Do QRMP taxpayers need to file GSTR-9?
Yes, if their aggregate turnover exceeds two crore rupees. The Quarterly Return Monthly Payment (QRMP) scheme changes the frequency of monthly statements (IFF and quarterly GSTR-3B), but does not grant an exemption from annual return filing under Section 44.
Must I file a nil GSTR-9 if turnover exceeds 2 crore rupees?
If aggregate turnover across your PAN exceeds two crore rupees, every active GSTIN registered as a regular taxpayer must file Form GSTR-9, even if a particular branch had nil outward supplies, nil purchases, and zero tax liability during the year.
Reconcile annual inward supplies before filing GSTR-9
Before submitting Form GSTR-9, compare your purchase register against auto-populated Table 8A credit figures. Our client-side matching tool identifies missing invoices, duplicate bookings, and rate differences locally in seconds. Your GSTR-2B and purchase register files are read in your browser and never uploaded to any server.
Last checked: 25 October 2026. Sources: CBIC Section 44 CGST Act, GSTN FAQs on Form GSTR-9, CBIC Notification No. 31/2021-Central Tax.