Annual GST compliance requires taxpayers to close their books, reconcile tax ledgers, and file their annual returns. While Form GSTR-9 is the annual return, Form GSTR-9C acts as a reconciliation bridge between the audited annual financial statements and the figures declared in the GST returns. Many business owners and accounts teams wonder who needs to file GSTR 9C and whether an external CA certification is still mandatory.
The 5 crore threshold under Rule 80(3)
The legal requirement to submit Form GSTR-9C is governed by Rule 80(3) of the CGST Rules. Under this provision, 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 in Form GSTR-9.
If your aggregate turnover across the entire financial year is up to 5 crore rupees, filing Form GSTR-9C is optional. You are only required to file Form GSTR-9 if your turnover exceeds 2 crore rupees.
Common mistake: Calculating the 5 crore threshold per GSTIN rather than on a PAN-India basis. Aggregate turnover includes all taxable supplies, exempt supplies, exports, and inter-state supplies of persons having the same PAN across all states in India. If the combined PAN turnover exceeds 5 crore rupees, every GSTIN registered under that PAN must file Form GSTR-9C.
Self-certification replaces CA audit
In earlier financial years, Form GSTR-9C had to be certified by a practicing Chartered Accountant or Cost Accountant. Under the amended provisions of the CGST Act and Rule 80(3), that requirement was replaced with self-certification by the taxpayer.
Taxpayers prepare the reconciliation statement directly and digitally sign it on the GST portal using a Digital Signature Certificate (DSC) or Electronic Verification Code (EVC). While external CA certification is no longer legally mandated, the taxpayer remains personally responsible for any discrepancies, unpaid tax liabilities, or wrongful Input Tax Credit (ITC) reported in the form.
For a detailed breakdown of tables and reconciling figures, see our guide on GSTR-9C reconciliation statement.
Persons exempted from filing Form GSTR-9 and GSTR-9C
Under Rule 80(1) of the CGST Rules, specific classes of registered persons are completely excluded from the requirement to file Form GSTR-9 and Form GSTR-9C, regardless of their annual turnover:
- Input Service Distributors (ISD)
- Tax deductors under Section 51 (TDS)
- Tax collectors under Section 52 (TCS)
- Casual taxable persons
- Non-resident taxable persons
- Departments of the Central Government or State Governments, or local authorities whose books of account are subject to audit by the Comptroller and Auditor-General of India (CAG)
Worked example: checking the 5 crore AATO threshold
Consider a business operating under a single PAN with two branch registrations: one in Maharashtra and one in Gujarat. The accounts team evaluates whether Form GSTR-9C is mandatory for the financial year.
| Registration (GSTIN) | Taxable supplies | Exempt supplies | Total GSTIN turnover | GSTR-9C filing requirement |
|---|---|---|---|---|
| Maharashtra Branch | ₹3,20,00,000 | ₹40,00,000 | ₹3,60,00,000 | Mandatory (PAN turnover > ₹5 crore) |
| Gujarat Branch | ₹1,80,00,000 | ₹20,00,000 | ₹2,00,00,000 | Mandatory (PAN turnover > ₹5 crore) |
| Total PAN-India AATO | ₹5,00,00,000 | ₹60,00,000 | ₹5,60,00,000 | Both GSTINs must file GSTR-9C |
Calculation check:
Maharashtra (₹3,60,00,000) + Gujarat (₹2,00,00,000) = ₹5,60,00,000
Because the aggregate turnover of ₹5,60,00,000 exceeds the 5 crore rupees threshold (₹5,00,00,000), both the Maharashtra and Gujarat branches must file Form GSTR-9C, even though neither branch individually crossed 5 crore rupees on its own.
Key reconciliation areas in Form GSTR-9C
Form GSTR-9C is divided into two primary parts:
- Part A (Reconciliation Statement): Reconciles the turnover, taxable turnover, tax paid, and Input Tax Credit declared in audited annual financial statements with the numbers reported in Form GSTR-9. Official guidance on filing is detailed in the GSTN combined FAQ on Form GSTR-9 and GSTR-9C.
- Part B (Self-Certification): The declaration digitally verified by the taxpayer certifying that the reconciliation statement reflects true and correct particulars from the books of account.
A critical table in the annual return is Table 8 of Form GSTR-9, which compares the ITC available in Form GSTR-2B against the credit availed in monthly returns. Reconciling inward supplies between books of accounts and GSTR-2B avoids unexplained differences during GSTR-9 and GSTR-9C preparation.
Frequently asked questions
Who needs to file GSTR-9C?
Every registered taxpayer whose aggregate turnover exceeds 5 crore rupees in a financial year must file a self-certified reconciliation statement in Form GSTR-9C along with the annual return Form GSTR-9.
Does a Chartered Accountant need to certify Form GSTR-9C?
No. Under Rule 80(3) of the CGST Rules, the requirement of audit and certification by a Chartered Accountant or Cost Accountant was substituted with self-certification by the taxpayer.
Is aggregate turnover calculated per GSTIN or PAN-India?
Aggregate turnover is calculated on an all-India basis for the same Permanent Account Number (PAN). If the total PAN-level turnover exceeds 5 crore rupees, every registered GSTIN under that PAN must furnish Form GSTR-9C.
Check your own GSTR-2B
Reconcile your purchase register against monthly GSTR-2B files instantly before filing your annual return. 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 CGST Rule 80, GSTN Combined FAQ on GSTR-9 and GSTR-9C.