GSTR-9C: Applicability, the ₹5 Crore Line, and Self-Certification

5 Crore Line explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

GSTR-9C used to have two parts: a reconciliation statement and a certificate signed by a chartered accountant or cost accountant. From FY 2020-21 the certificate was removed entirely. What is left is a statement the taxpayer certifies himself — and files only if turnover crosses ₹5 crore.

"FORM GSTR-9C is the relevant form prescribed in terms of rule 80(3). Upto FY 2019-2020, it had two parts: Part-A is the 'Reconciliation Statement' and Part-B is the 'Certificate'. However, from FY 2020-21 onwards, Part-B has been omitted. Now, it has only Part-A." Rule 80(3) requires it where "aggregate turnover during a financial year exceeds five crore rupees", filed "along with the annual return… on or before the thirty-first day of December following the end of such financial year."

The threshold, year by year

Contrast the GSTR-9 position, where "No threshold limit prescribed under CGST Act and CGST Rules. Option/Exemption to small taxpayers has been provided vide various notifications" — GSTR-9 has an exemption below ₹2 crore; GSTR-9C has a threshold above ₹5 crore. The distinction matters because a threshold is built into the rule while an exemption depends on a notification.

Between ₹2 crore and ₹5 crore, GSTR-9 is due and GSTR-9C is not.

The seven differences from GSTR-9

The Guide's own comparison is the clearest statement of what the two documents are:

The first row is the substantive difference. GSTR-9 reports; GSTR-9C asserts something that can be tested. That is why it carries reasons columns, and why the reconciliation is expected to survive scrutiny.

And the same categories are excluded from both — "Casual Taxable Person, Non-Resident Taxable Person, Input Service Distributor, Unique Identification Number Holders, Online Information and Database Access Retrieval Service , Composition Dealers, persons required to deduct tax under section 51 and persons required to collect tax under section 52."

The filing sequence, and the anomaly in it

The instructions are explicit: "It is mandatory to file all your FORM GSTR-1, FORM GSTR-3B and FORM GSTR-9 for the current financial year before filing Reconciliation Statement in Form GSTR-9C. The reconciliation statement is to be filed for every GSTIN separately."

But the Guide records a real difficulty with that sequence:

"A plain reading of the relevant provisions indicates that the said Annual Return in FORM GSTR-9 and the Reconciliation Statement in FORM GSTR-9C must be filed together. However, if one has to peruse FORM GSTR-9C there are certain tables which state that 'turnover as declared in annual return' indicating thereby that FORM GSTR-9C is dependent on FORM GSTR-9. This anomaly can be addressed only on the basis of the finalized annual return initialled by the registered person."

The practical consequence is that GSTR-9C must be prepared before GSTR-9 is filed, but cannot be filed until it is. The reconciliation drives figures into GSTR-9 — particularly Table 9's tax payable, which per Sl. No. 9Q flows from GSTR-9 Tables 9, 10 and 11 — so the two are worked together and only then filed in sequence.

And filing GSTR-9 first has its own cost. The section 16(4) and section 37/39 correction windows close on 30 November or the date of filing the annual return, whichever is earlier — so a return filed to unlock GSTR-9C also forecloses further corrections. GSTR-9 and the specified date →

The first year, and what "financial year" means

"The expression financial year has not been defined under the GST laws. However, in terms of the General Clauses Act, 'financial year' shall mean the year commencing on the 1st day of April and closing on the 31st day of March."

FY 2017-18 was a nine-month year. "the GST laws came into operation on the 1st day of July, 2017… for the financial year 2017-18, the GST Laws was applicable only for nine months commencing from July, 2017 to March, 2018." The form nonetheless records it as "2017-18".

This still matters for reopened years and for any comparison against income-tax turnover for that period, which covers twelve months.

What the statement is built on

Five documents, per the Guide's list for Table 5A:

• audited financial statements for the FY, to derive total turnover;
• registration-wise trial balance, to furnish GSTR-9C for each registrant;
• communication with the persons responsible for other States' reconciliation statements, to ensure holistic reconciliation;
• GSTR-9 with supporting GSTR-3B and GSTR-1;
• Income Tax Returns, "to ensure that the turnover details are reconciled with the turnover as per GST."

The third item is the one most often skipped. A multi-State entity filing several GSTR-9Cs must ensure the sum of the State turnovers equals the consolidated audited figure — which requires the preparers to talk to each other before any of them files.

Key takeaways

• Rule 80(3) requires GSTR-9C where aggregate turnover exceeds ₹5 crore, filed with the annual return by 31 December.
• The threshold was ₹2 crore for FY 2017-18 and ₹5 crore from FY 2018-19, confirmed for FY 2020-21 onwards by Notification No. 30/2021-CT.
• Part B, the certificate, was omitted from FY 2020-21 — the statement is now self-certified.
• Between ₹2 crore and ₹5 crore, GSTR-9 is due and GSTR-9C is not.
• GSTR-9 is a report; GSTR-9C is a statement whose veracity can be enquired into — and financials must be annexed.
• The same categories are excluded from both forms, including OIDAR since Notification No. 30/2019-CT.
• GSTR-1, GSTR-3B and GSTR-9 must all be filed first, and the statement is filed GSTIN by GSTIN.
• The forms are mutually dependent, resolved only "on the basis of the finalized annual return initialled by the registered person".
• FY 2017-18 was a nine-month year under GST although labelled 2017-18.

Read next

• GSTR-9C Part I: Basic Details, and What Must Be Verified
• GSTR-9C Table 5A: Turnover From the Audited Financial Statements
• GSTR-9: Who Must File, and Who Is Exempt

Disclaimer: Positions stated as on 5 September 2026, based on section 44 of the CGST Act, 2017, rule 80 of the CGST Rules, 2017, Notifications No. 30/2019 and 30/2021-Central Tax and the General Clauses Act, 1897, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).