Form Gstr-9C: CA Pratik Sudhir Shah, 9819122318

FORM GSTR-
9C
CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

LEGAL
PROVISIONS
S. 35(5) S. 44(2) R. 80(3)
  Every Registered Person who is 
Every registered person whose Every registered person
turnover during a financial required to get his accounts audited in whose aggregate turnover
year accordance with provisions of Sec 35(5) during a financial year
shall
 exceeds the prescribed limit  exceeds Rs. 2 crore
 furnish, electronically,
 shall get his accounts audited by a  shall get his accounts
 the annual return under S. 44(1)
chartered accountant or a cost audited as specified under
accountant and  along with a copy of the audited S. 35(5) and
 shall submit- annual accounts and  he shall furnish a copy of
 a copy of the audited annual
 a reconciliation statement, reconciling audited annual accounts
accounts, and
the value of supplies declared in the
 the reconciliation statement return furnished for the financial year  a reconciliation
under S. 44(2) and with the audited annual financial statement,
statement, and
 such other documents in such  duly certified, in FORM
form and manner as may be  such other particulars as may be GSTR-9C
prescribed. prescribed
FAQ ON APPLICABILITY OF GSTR 9C
Q1. Mr A is supplier of Taxable Goods. During the period 1st July 17 to 31st March 18, Mr A had turnover
of Rs 5 Crores + GST. Whether Mr A is liable to GST Audit ?
Ans: Yes GST Audit is Applicable as Aggregate Annual Turnover us exceeding Rs 2 Crores.
Q2. Mr A is supplier of Taxable and Exempt Goods. During the period 1st July 17 to 31st March 18, Mr A
sold Taxable Goods of Rs 1.5 Cr + GST and Exempt Goods of Rs 60 Lakhs.
Ans: Yes, as per Section 35(5) read with rule 80(3), GST Audit is applicable if your Aggregate Annual
Turnover in a Financial Year exceeds Rs 2 Crores. Aggregate Annual Turnover includes both Taxable and
Exempt Supplies.
Q3. Mr A is supplier of Taxable Goods. During the period 1st July 17 to 31st March 18, Mr A sold goods of
Rs 1.5 Crores + GST. During the period 1st April 17 to 30th June 17, Mr A sold goods of Rs 75 Lakhs.
Whether Mr A is liable for GST Audit ?
Ans: Yes, as per Section 35(5) read with rule 80(3), GST Audit is applicable if your Aggregate Annual
Turnover in a Financial Year exceeds Rs 2 Crores. Financial Year is not defined under GST Law hence as
per General Clauses, Financial Year is period of April to March.
FAQ ON APPLICABILITY OF GSTR 9C
Q4. Mr A has GST Registration in state of Maharashtra and Delhi. In Maharashtra his turnover
was 1.25 Crore and in Delhi his turnover was 1.5 Crore. Whether Mr A is liable for GST Audit in
Maharashtra or Delhi or Both?
Ans: Yes, Section 35(5) read with Rule 80(3) does not use “Turnover in a State”. It states GST
Audit shall be applicable when Aggregate Annual Turnover exceeds Rs 2 Crores. Hence PAN
Indian Turnover should be calculated to determine whether GST Audit is applicable or not.
Q5. Mr A has taxable turnover of Rs 2.5 Crores for the period 1st July 17 to 31st March 18.
However he has not taken registration till date. Whether Mr A is required to file GSTR 9C ?
Ans: Section 35(5) read with Rule 80(3) says “Every Registered Person”. In this case Mr A is not
registered under GST in FY 2017-18 hence GST Audit is not applicable. As per my opinion GST
Audit should be made applicable in this case as Mr A is actually liable to Audit. He should also
be subjected to Penalty under Section 73 or 74 as case may be

FORM GSTR-9C

FORM GSTR-9C
Part-II: Reconciliation of turnover declared in audited Annual Financial Statement

with turnover declared in Annual Return (FORMGSTR-9)
TABLE NO. DESCRIPTION
5 Reconciliation of Gross Turnover

FORM GSTR-9C

Turnover (including exports) as per audited financial statements for the State/ UT
5A (For multi-GSTIN units under same PAN the turnover shall be derived from the
audited Annual Financial Statement)
INSTRUCTIONS (AsAppended below FORM GSTR-9C)

1. The turnover asper the audited Annual Financial Statement shal be declared
here.
2. There may be caseswhere multiple GSTINs(State-wise) registrations exist on the
same PAN. This is common for persons/ entities with presence over multiple
States.
3. Suchpersons/ entities will have to internally derive their GSTINwise turnover
and declare the same here.
4. This shal include export turnover (if any).
5. It may be noted that reference to audited Annual Financial Statement
includes CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318
reference to books of accounts in case of persons/ entities having presence

over multiple States.
FORM GSTR-9C
5B Unbilled revenue at the beginning of Financial Year (+)

1. Unbilled revenue which was recorded in the books of accounts on the basisof accrual
system of accounting in the last FYand was carried forward to the current FY.
2. In other words, when GST is payable during the financial year on such revenue (which was
recognized earlier), the value of suchrevenue shal be declaredhere.
For example, if Rs. 10 crore of unbilled revenue existed for the financial year 2016-17, and during the
current financial year, GST was paid on Rs. 4 crore of such revenue, then value of Rs. 4 crore shal be
declared here
S.31(2) an invoice for supply of services may be issued within 30

days.
FORM GSTR-9C
5H Unbilled revenue at the end of Financial Year (-)

Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of
accounting during the current FY but GST was not payable on such revenue in the same FY shal be
declared here.

FAQ on Unbilled
Revenue
Case Study 1: Unbilled Revenue
Mr A had provided consultancy services to Mr B of Rs 1,00,000. Services got completed on 25 th
March 2018 however invoice for the same was raised on 5th April 2018 (within 30 days of
completion of service). Mr A have booked revenue in P n L Account in FY 2017-18 as he was
following Mercantile System.
Ans: Mr A must have booked income in Profit and Loss A/c as per IND AS in FY 2017-18. However he
must have booked Income in GST Returns in FY 2018-19 as Invoice is raised in April 2018 as per Sec
31. Hence GST Turnover is lower than profit and loss t/o which calls for reconciliation. on.
Case Study 2: Unbilled Revenue

Mr A is providing services of construction to Mr B. Contract Value is Rs 10,00,000. As per agreement
invoice shall be raised by Mr A and payment shall be made by Mr B only after completion of
Construction. As on 31st March 2017, 60% of construction was completed hence Mr A booked
revenue in P n L Account of Rs 6,00,000 (10L * 60%) as per proportionate completion method (AS 7).
Construction got completed on 15th July 2017 hence Mr A raised an invoice of 10,00,000 + GST in
July 2017.
Ans: Mr A must have booked Income of Rs 6 Lakhs in Profit and Loss A/c as per “Proportionate
Completion Method” in FY 2016-17. However Entire Invoice of Rs 10 Lakhs + GST was raised in FY
2017-18. Hence GST Turnover isClAoPwatrekirSutdhrhiaSnhaph, rpoatrfhks2i ati 7n04d@glomaissco.lt/om, 98w19h12i2c3h18calls for
reconciliation..
FORM GSTR-9C

5C Unadjusted advances at the end of the Financial Year (+)

Value of all advances for which GST has been paid but the same has not been recognized
asrevenue in the audited Annual Financial Statement shal be declared here.

FORM GSTR-9C

5I Unadjusted Advances at the beginning of the Financial Year (-)

Value of all advances for which GSThas not been paid but the same has been recognized
asrevenue in the audited Annual Financial Statement shal be declared here.
AsGSTR-9Cis being filed for the first time for the FY2017-18, there is no
room for unadjusted advances at the beginning of FY17-18.

FAQ on Unadjusted
Advances
Case Study : Unadjusted Advances
Mr A received advances on services on 28th March 2018 of Rs 5,00,000 + GST.
Services got completed on 5th April 2018 and invoice was raised on same date.
Ans: Mr A must have booked Amount of Rs 5,00,000 in Balance Sheet under
Advances. It is not part of Profit and Loss A/c in FY 2017-18. However as per Time
of Supply of Services under GST Law, GST Liability is attracted as soon as Advances
is received. Hence it is forming part of Turnover under GST in FY 2017-18. Hence
GST Turnover is higher than profit and loss t/o which calls for reconciliation.
Case Study : Unadjusted Advances

Mr A received advances on services on 20th February 2017 of Rs 2,00,000 + Service
Tax. Services got completed on 5th July 2017 and invoice was raised on 5th July
2017.
Ans: Mr A must have booked Amount of Rs 2,00,000 in Balance Sheet under
Advances. It is not part of Profit and Loss A/c in FY 2016-17. However Mr A has paid
Service Tax in FY 2016-17 as Service Tax is applicable on Advances Received on
Services. In this case, Mr A has raised an Invoice on 05th July 2017 hence it is
required to raise an Invoice of Rs 2 Lakh + GST and take credit in Tran 1 of Service
Tax already paid in FY 2016-17.
FORM GSTR-9C
Advances not to be considered-

(a) Against goods (after 15-Nov-2017) (13-Oct-2017 for GTObelow
1.5crore)
(b) Against exempted services
(c) Deposits and securities received
(d) LoansandAdvances
Revenue Recognition-
AS-9: Revenue from sale of goods is recognized at the time of transfer of
risks and rewards & revenue from services is recognised asthe service is
performed

FORM GSTR-9C
5D Deemed Supply under Schedule I (+)

Aggregate value of deemed supplies under Schedule I of the CGST Act, 2017 shal be declared here.
Any deemed supply which is already part of the turnover in the audited Annual Financial
Statement is not required to be included here.
Schedule-I transactions may be verified through chal ans and e-way

bil s
CASE STUDIES FOR GSTR 9C
Case Study : Deemed Supply under Schedule I
Mr A had two branches, 1st branch in Maharashtra and 2nd in Delhi. He transferred goods worth Rs
2,00,000 + GST from Maharashtra to Delhi. Such transfer was shown as Branch Transfer and not
considered as Sales in P n L Account.
Ans:
Branch transfer outside the state are subjected to GST. Hence such branch transfer shall form part of
GST Turnover. However there is no such provision in Accounting standard and hence Profit and Loss A/c
shall not include Rs 2 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for
reconciliation.
Case Study : Deemed Supply under Schedule I

Mr A bought Air Condition in July 2017 for 1,28,000 (1 lakh + 28% GST). Mr A had taken set off of Rs
28,000. Later Mr A took Air Condition at home without any consideration. Mr A knew concept of
Deemed Supply hence considered transfer of AC as Supply (Net Value = Rs 1 Lakh) and paid GST of Rs
28,000.
Ans:
As per Schedule I of CGST Act, Permanent Transfer or disposal of business assets on which ITC is availed
shall be subjected to GST. Hence AC permanently transfer shall be considered as T/O in GST Act.
However there is no such provision in Accounting standard and hence Profit and Loss A/c shall not
include Rs 1 lakhs as T/O. HenceCA PGatrSkiTSudThuri rShnaoh,vpreatrkshi is270h4@iggmaheco.lir mth, 9a81n912p23r1o8fit and loss t/o which calls
for
FORM GSTR-9C 27
Para 1 of Schedule-I: Permanent transfer or disposal of busines as ets where ITC

has be n availed on such as ets, e.g. stock transfers, assets donated, de-
commissioning of plants, impairment of assets, assets taken by owners
Para 3 of Schedule-I: Transaction between principal and his agent, e.g. in GST
gross amount is shown in the hands of the agent whereas in financials only
commission is shown
Para 4 of Schedule-I: Import of services from a related person, e.g. foreign

branch supplying manpower to HO in Delhi; sharing of cloud services

FORM GSTR-9C

Credit Notes issued after the end of the financial year but reflected in the annual
5E
return (+)

Aggregate value of credit notes which were issued after 31st of March for any supply accounted
in the current financial year but such credit notes were reflected in the annual return (FORM
GSTR-9) shal be declared here.
1.CNissued during FY2018-19 may not be given effect to during FY2017-18.

2. GSTR-9captures this detail from Table 11 [Supplies/ tax reduced through
amendments (-)(net of credit notes)]
3.If 5A is net turnover (on accrual basis) then it may be added to match with the
gross turnover of GSRT-9.
FORM GSTR-9C

Trade Discounts accounted for in the audited Annual Financial Statement
5F
butare not permissible under GST (+)

Trade discounts which are accounted for in the audited Annual Financial Statement but on
which GSTwas leviable (being not permissible) shal be declared here.
Types of discounts-
(a) Special discount: On any extraordinary purchase made by customers
(b) Bonus Discounts: On negotiations made after sales
(c) Incentives: Given on achieving targets and making sales without reducing
sales price
(d) Remission: General fall in prices
(e) Compensation: Significant
CA Pratik correction of
Sudhir Shah, pratiksh2704@gmail.com, prices
9819122318
Case Study : Trade Discounts accounted for in the audited Annual
Financial Statement but are not permissible under GST
Mr A is supplier of Goods. During the year Mr B had purchased more
than 100 quantity from Mr A, hence Mr A decided to give him discount
of Rs 5,000. Mr B issued credit note (Financial credit note without
reducing GST) of Rs 5,000 and reduced it from Sales of FY 2017-18.
Ans:
• Mr A have reduced Sales in Profit and Loss Account to extent of Rs
5,000 (Discount).
• However such discount shall not have any impact in GST Turnover as
Mr A has not reduced GST on discount as discount was not agreed
before or during the supply and Credit Note is Financial Credit Note.
• Hence GST Turnover is lower than profit and loss t/o which calls for
reconciliation..

FORM GSTR-9C

5G Turnover from April 2017 to June 2017 (-)

Turnover included in the audited Annual Financial Statement for April 2017 to June2017
shal be declared here.

FORM GSTR-9C

Credit notes accounted for in the audited Annual Financial Statementbut are not
5J
permissible under GST (-)

Aggregate value of credit notes which have been accounted for in the audited Annual
Financial Statement but were not admissible under Section 34 of the CGSTAct shal be
declared here.
It may include credit notes which were issued otherwise than S. 34 read with R.
53 i.e. financial credit notes, e.g. cashdiscount offered for early payment by
debtors
FORM GSTR-9C
FAQ for Point 5J - Credit notes accounted for in the audited Annual Financial Statementbut are not permissible
under GST (-)
Q 1-
What is the effect of Credit notes issued in relation to exempt supplies, zero-rated supplies and non-GST outward
supplies?
Supply of exempt, zero-rated and non-GST outward supply of goods and / or services are not liable to GST. In such a
scenario, the credit notes issued for claiming reduction in the taxable value shall be recorded in the audited annual
financial statements. Such credit notes should be declared against Pt. II Sl. No. 5J of Form GSTR 9C
Q2-
What are the implications upon issuance of financial credit notes?
Financial credit notes would not adjust the amount of GST involved in the original tax invoice issued at the time of
supply of goods and / or services. Accordingly, the transaction value of supply of goods and / or services shall stand
reduced although tax paid thereon remains the same. This may result in higher amount of GST being paid considering
the adjusted value of original supply. Since, the value of financial credit notes is to be reduced from the financial
statements and not the GST Annual retuCArnPrsa,ktiitSuisdhrrieSqhauhi,rpear dktitsh2o 7b0e4@agdmjauoc.lts
i emd, 98in19512J23o1f8Form GSTR 9C.
FORM GSTR-9C

5K Adjustments on account of supply of goods by SEZ units to DTA Units (-)

Aggregate value of all goodssupplied by SEZsto DTAunits for which the DTAunits have filed
bill of entry shal be declared here.
Supplies by SEZs to DTA units for which DTA units have filed bill of entry, such transaction
does not form part of GST turnover as that is not reported by SEZ unit in its GST returns.
[Refer Rule 58 of SEZRules, 2006]

FORM GSTR-9C

5L Turnover for the period under composition scheme(-)

1. There may be caseswhere registered persons might have opted out of the composition
scheme during the current financial year.
2. Their turnover asper the audited Annual Financial Statement would include turnover
both as composition taxpayer aswell asnormaltaxpayer.
3. Therefore, the turnover for which GSTwas paid under the composition scheme shal be
declared here.
This amount can be taken from clause 6C of GSTR-9A, which is the sum total of table 6
[Tax on outward supplies] and 7 [Amnd. to outward supplies] of GSTR-4. Besides this
exempted suppliesof traders are to be extracted from the booksof accounts
FORM GSTR-9C
5M Adjustments in turnover under section 15 and rules there under (+ / -)

There may be cases where the taxable value and the invoice value differ due to valuation
principles under section 15 of the CGSTAct, 2017 and rules there under.
Therefore, any difference between the turnover reported in the Annual Return (FORM GSTR-9)
and turnover reported in the audited Annual Financial Statement due to difference in valuation
of suppliesshal be declared here.
(+) he differences arose on account of netting off of certain expenses in financials whereas
T theare shown asturnover in GST
sam CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318
e
Case Study : Adjustments in turnover under section 15 and rules thereunder
Mr A had sold goods for Rs 1 Lakh + 5000 GST to Mr B. Credit period was 30 days. Mr B paid money after
30 days hence Mr A charged Interest of Rs 1000 + GST. Interest was shown in “Other Income” in Profit
and Loss A/c.
Ans:
Mr A has received Interest Income in relation to Supply made of Rs 1 Lakh. Hence GST shall be applicable
on Interest Income of Rs 1,000. Mr Rs 1000 is forming part of GST Turnover. However it is not forming
part of Sales in Profit and Loss A/c as Mr A has booked it in Other Income. Hence GST Turnover is higher
than profit and loss t/o which calls for reconciliation.
Case Study : Adjustments in turnover under section 15 and rules thereunder

Mr A is developer. He gave contract of construction of Rs 1 Cr to Mr B. Contract specified that all
materials, labour, other services shall be responsibility of Contractor. Later Mr A (Developer) had cement
in his godown hence supplied Cement free to Mr B (Contractor). Mr B (Contractor) completed
construction and charged invoice of only Rs 1 Crore + GST. However he booked 80 lakhs as Revenue in P n
L Account.
Ans:
As per GST Law, any expenses incurred by Receiver which ought to be incurred by Supplier of Services
must be included in Value of Supply and GST shall be applicable. In given case, Mr A (Receiver) gave
cement of Rs 20 lakhs to Mr A (Supplier). Such expenses should have been incurred by Supplier as
contract specified entire responsibility is of Supplier. Hence GST shall be applicable on entire Rs 1 crore.
However in Profit and loss account revenue of only Rs 80 lakhs shall be booked. Hence GST Turnover is
higher than profit and loss t/o whCci AhPractaiklSlusdhfoir Srhraeh,cporatnikcshli2i7a0t4i@ognm.ail.com, 9819122318
FORM GSTR-9C
(+) Taxes other than GST paid and recovered from customers whereas the same are taken in
turnover asper valuation underGST
(+) Free of cost supplies made by the contractee which do not reflect in the Financials of the
contractor whereas the same is taken in turnover by the contractor for valuation purposes
under GST
(+) Incidental expenses like commission, packing, handling charges paid by the supplier
before delivery and recovered from the customer and being net off in P&L A/c but shown as
GST turnover in terms of valuation provisions
(+ E-comm. operator compensating vendors participating in mega sales. Such discounts are
) ered through financial credit notes in the form of subsidy being net off with commission
of paid operator
f CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318
to
FORM GSTR-9C

5N Adjustments in turnover due to foreign exchange fluctuations (+/ -)

Any difference between the turnover reported in the Annual Return (GSTR-9) and turnover
reported in the audited Annual Financial Statement due to foreign exchange fluctuations shal be
declared here.
The GST valuation has to be derived by considering the rate of exchange as specified in
Rule 34 i.e. ROE as notified by CBIC for the date of time of supply of goods (S. 14 of
Customs) and ROE asper GAAPfor the date of time of supply of services. In books ROE
isasper AS-11.
Case Study : Adjustments in turnover due to foreign exchange fluctuations
PQR Limited has exported goods to a Company located in USA. The value of goods is $100,000. The
exchange rate (Rs/$) on the date of filing Shipping Bill are
• CBEC Rate: Rs 65
• RBI Rate: Rs 68
•At the time of receipt of money bank has exchanged foreign currency at Rs 70.
Ans:
As per GST Law, Revenue must be booked under GST as per CBEC rate for Goods Exported. Hence
GST Turnover as per GST Law is Rs 65,00,000/
As per Accounting Standards, Revenue must be booked in Profit And Loss Ac as per RBI Rate for
Goods Exported. Hence Turnover as per Profit and Loss Ac is Rs 68,00,000
Hence Reconciliation of Rs 3,00,000 in GSTR 9C.
PQR received money of Rs 70,00,000 (70 * 100000) hence difference of Rs 2,00,000 (Amount
Received of Rs 70 lakhs less Income booked as per RBI Rate of Rs 68 Lakhs) shall be booked as
Income in Profit and Loss Ac as “Foreign Exchange Fluctuation. Such Foreign Exchange Fluctuation is
required as per Accounting Standard only and it shall not have any impact on GST Turnover.
Hence Reconciliation of Rs 2,00,000 in GST 9C.
FORM GSTR-9C
5O Adjustments in turnover due to reasons not listed above (+/-) [Page: 321]

Any difference between the turnover reported in the Annual Return (FORM GSTR-9) and
turnover reported in the audited Annual Financial Statement due to reasons not listed
above shal be declared here.

Case Study : Adjustments in turnover due to reasons not listed above

Co A recovered Notice Pay from Employees Rs 50,000 + GST. Co A recovered GST on Rs 50,000. Such
income was not shown as Sales or other income in P n L. It was reduced from Salary Expenses.
Ans: As per Section 7 read with Schedule II, Act of Tolerance is also supply under GST. Hence Rs 50,000
is forming part of GST T/O. However in Profit and Loss Ac, Rs 50,000 is not forming part of Sales as it is
reduced from Salary Expenses. Hence GST Turnover is higher than profit and loss t/o which calls for
reconciliation.

Mr A had sent goods to Mr B on sale or approval basis in Aug 2017. Goods were neither approved nor
returned by Mr B within 6 months. Hence Mr A considered same as Supply (5Lakh +5% GST) as goods
are not approved / returned within 6 months.
Ans: As per GST Law, if goods sent on approval are not approved or returned within 6 months than is
shall be deemed as Supply under GST Law and shall be subjected to GST. Hence Rs 5 lakhs shall be
booked as Turnover under GST. However there is no such provision in Accounting standard and hence
Profit and Loss A/c shall not include Rs 5 lakhs as T/O. Hence GST Turnover is higher than profit and loss
t/o which calls for reconciliation.


Mr A sent goods for Job Work to Mr B in Aug 2017. Goods were not returned by Mr B within 1 year.
Hence Mr A considered same as Supply (2Lakh + 5% GST) under GST as goods are not returned within 1
year.
Ans:
As per Section 143 of CGST Act, Inputs sent on Job work must be returned within 1 year. If it is not
received than it shall be considered as Deemed Supply under GST Law. Hence Rs 2 lakhs shall for part of
GST Turnover. However there is no such provision in Accounting standard and hence Profit and Loss A/c
shall not include Rs 2 lakhs as T/O. Hence GST Turnover is higher than profit and loss t/o which calls for
reconciliation.

FORM GSTR-9C
1. ysician sample distributed by the pharmaceutical company to

Phphysician for e
2. fre
Notice pay recovered from employees
3. Gifts given to customers/ vendors/ distributors
4. Stocksissued to discharge CSRobligation
5. Incentives/ Rebate received from supplier and considered assupply
under GST
6. Sales promotion/ advertisement reimbursement received and considered

as supply
7. Out of pocket expenses considered in the value of supply
8. Value on which GSTpaid on sale of Capital Goods
FORM GSTR-9C
9. (-) rofit on sale of Capital goodsdisclosed in audited Annual

P FinancialStatements
10. Losson sale of Capital goodsdisclosed in audited Annual FinancialStatements
11. Inward supply returns considered asOutwardsupply
12. (-) Outward supply returns considered asInwardsupply
13. (-) Income in Profit and Lossaccount recognized based on special
circumstances
14. Value on which GSTis liable to be paid in respect of transactions where
income is recognized based on special circumstances
15. Discounts which are not to be excluded from the value of supply asper S.
15
16. Any other amount
FORM GSTR-9C

5P Annual turnover after adjustments as above

5Q Turnover as declared in Annual Return (FORM GSTR-9)
INSTRUCTIONS(AsAppended below FORM GSTR-9C)

Annual turnover as declared in the Annual Return (FORM GSTR-9) shal be declared here. This
turnover may be derived from Sr. No. 5N [Total turnover on which tax is payable and tax is
not payable but does not include inward supplies liable to RCM], 10 [Supplies/ tax declared
through amendments (+)] and 11 [Supplies/ tax reduced through amendments(-)] of Annual
Return (FORM GSTR-9).
FORM GSTR-9C

5R Un-Reconciled turnover (Q - P)
• Taxable, exempted or non-GST outward supplies not declared in annual returns

will form part of auto-computed value in this Table
• FORM GSTR-9C do not specifical y provide to claim the benefit of tax
paid erroneously

FORM GSTR-9C

6 Reasons for Un - Reconciled difference in Annual Gross Turnover[Page: 331]

Reasonsfor non-reconciliation between the annual turnover declared in the audited Annual
Financial Statement and turnover asdeclared in the Annual Return (FORM GSTR-9)shal be
specified here.
FORM GSTR-9C
Reasonsfor reconciliation difference could

be-
Capi al Gain/ Losson sale of FixedAsset recorded in books for turnover purpose compared
t with consideration available in GST
total
Tran action reported in Delivery Chal an for supply on sale or approval basis beyond a
s period of onths shal be deemed to be supply under GST but may not be a
6 msale for revenue
recognition in books

FORM GSTR-9C

FORM GSTR-9C
7 Reconciliation of Taxable Turnover [Page: 334]

The table provides for reconciliation of taxable turnover from the audited annual
turnover after adjustments with the taxable turnover declared in annual return
(FORMGSTR-9).

FORM GSTR-9C

8 Reasons for Un - Reconciled difference in taxable turnover [Page: 347]

Reasonsfor non-reconciliation between adjusted annual taxable turnover asderived from Table
7E above and the taxable turnover declared in Table 7F shal be specified here.

Part IV. Reconciliation of Input Tax
Credit
Reconcile

12A. ITC availed as per audited
financials
Single GSTIN (From 1st July 2017)
 ITC ledger to be taken from financials (both revenue and capitalized items)
 ITC availed to be considered whether it is utilized or not
 ITC reversals and reclaimed to be considered to arrive at ITC availed
 ITC to be collated from net of debits and credits of the ITC ledger
 ITC on reverse charge to be included
 ITC receivable not to be considered
 In case of single ledger for liability and ITC, suitable mechanism for derivation and
assurance in the form of corroborative evidence to be taken
12A. ITC as per audited 34
financials
CGST/SGST/IGST
Sl No. Particulars Debit Credit
1 Opening Balance XXXX
2 Tax payable XXXX
3 Tax payable reversed (credit notes) XXXX
4 ITC Availed XXXX
5 ITC reversed XXXX
6 ITC reclaimed XXXX
7 Tax paid by cash ledger XXXX
8 Closing balance XXXX

12C. ITC booked in current FY to be claimed in
later
Fys (-)
 All credits shown in FY 2017-18 in books but claimed in GSTR 3B of FY 2018-19
 Credit which satisfies the conditions of eligibility in 2018-19 though booked in 2017-
18
 If shown in ITC receivable in books, it is not to be considered as booked
 Only if credit taken in the ITC ledger in books, it is to be considered
 All GSTR 2A transactions on which ITC not taken in 2017-18 not to be reported here

12D (Audited financials) vs 12E (Annual
return)
12D. ITC availed as per audited financial statement or books of account
ITC availed as per audited financial statement or books of account as derived from
values declared in Table 12A, 12B and 12C above will be auto populated here
12E. ITC claimed in Annual

return
Net ITC Available for utilization as declared in Table 7J of Annual return (GSTR 9) shall
be declared here

13. Reasons for unreconciled
 ITC statutory auditors have not reconciled with returns/ECL and return
Particularly relevant
filers did not have a look at the books
 Whether credit is actually eligible or not is not to be checked in this table
ITC as per books > ITC as per return (less crucial for Department)
 Recognition of accrued expenses with GST before time of supply
 Recognition of ITC at the time of receipt of advances
 Rightful eligible credits not availed in returns though in books and GSTR 2A for any
reason (disputed, genuine, mistake etc.)
 Breakup of ineligible ITC shown in books
 ITC reversal or refund application claim not passed/incorrectly passed in books
 Receipt of excess credit fromCAISD as per books
Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318
13. Reasons for unreconciled
ITC
ITC as per books < ITC as per return (more crucial for Department)
 Breakup of GST not shown in the expenses/capital goods
 ITC of another GSTIN claimed in returns
 ITC claimed based on GSTR 2A without actual incurring the expenses
 ITC incorrectly reported at a higher figure in returns
 ITC reclaimed or refund rejection claim not passed/incorrectly passed in books
 Duplicate ITC availed in returns
 ITC availed after the closure of books of accounts wherein no ITC was shown
 ITC claimed in return even though depreciation claimed on ITC in books
Non reconciliation may be on account of incorrect filling up of Form GSTR 9
Amount of total ITC vs Eligible ITC
Availed
AMOUNT OF TOTALITC ELIGIBLE ITC AVAILED
All ITCs that should ideally appear in Form GSTR 2A Only those credits on which ITC is eligible
Invoice may not be present Invoice has to be present
Goods or services may not have been received during Goods or services should have been received during
the relevant period the relevant period
Returns may not have been furnished by recipient Returns should have been furnished by recipient
Supplier may not have been paid during the relevant Supplier should have been paid during the
period and 180 days may have expired relevant period if 180 days has expired from date
of invoice
Depreciation on the tax part may have been claimed Depreciation should not have been claimed on tax
Total credit for business/non business to be taken Credit attributable to business purpose only
ITC attributable to taxable/exempt supplies allowed ITC attributable to only taxable supplies allowed
ITC blocked under Section 17(5) to be taken ITC should not have been blocked under 17(5)
GSTIN of the recipient should be mentioned GSTIN of the recipient should be mentioned
Ineligible ITC incorrectly availed to appear Ineligible ITC availed incorrectly not to be taken
14R (Audited financials) vs 14S
(Annual
14R. Total amount of eligible ITC return)
availed
Total ITC declared in Table 14A to 14Q above shall be auto populatedhere
14S. ITC claimed in Annual return (GSTR

9)
Net ITC availed as declared in the Annual Return (GSTR9) shall be declared here.
Table 7J of the Annual Return (GSTR9) may be used for filing this Table.

15. Unreconciled
ITC
 All the differences as stated for Table 13
 Incorrectly higher ITC availed in returns even though:
o Not in possession of proper tax invoice (e.g. GSTIN not mentioned)
o Non-receipt of goods or services or both
o Depreciation claimed on tax component
o Credit attributable to non business purposes / exempt supplies
o Payment not made to supplier within 180 days
o ITC blocked u/s 17(5)

16. Tax payable on unreconciled difference in
ITC

PRATIK SUDHIR SHAH
CHARTERED ACCOUNTANT
9819122318
Email:
pratiksh2704@gmail.com

Form Gstr-9C: CA Pratik Sudhir Shah, 9819122318

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FORM GSTR-

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

Part-II: Reconciliation of turnover declared in audited Annual Financial Statement

TABLE NO. DESCRIPTION

5 Reconciliation of Gross Turnover

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

reference to books of accounts in case of persons/ entities having presence

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

S.31(2) an invoice for supply of services may be issued within 30

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

Case Study 2: Unbilled Revenue

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

Case Study : Unadjusted Advances

Advances not to be considered-

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

Schedule-I transactions may be verified through chal ans and e-way

Case Study : Deemed Supply under Schedule I

Para 1 of Schedule-I: Permanent transfer or disposal of busines as ets where ITC

Para 4 of Schedule-I: Import of services from a related person, e.g. foreign

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

1.CNissued during FY2018-19 may not be given effect to during FY2017-18.

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

Case Study : Adjustments in turnover under section 15 and rules thereunder

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

TABLE NO. DESCRIPTION

INSTRUCTIONS (AsAppended below FORM GSTR-9C)

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

Case Study : Adjustments in turnover due to reasons not listed above

Case Study : Adjustments in turnover due to reasons not listed above

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

Case Study : Adjustments in turnover due to reasons not listed above

CA Pratik Sudhir Shah, pratiksh2704@gmail.com, 9819122318

1. ysician sample distributed by the pharmaceutical company to

6. Sales promotion/ advertisement reimbursement received and considered

9. (-) rofit on sale of Capital goodsdisclosed in audited Annual