GSTR-9C Part I: Basic Details, and What Must Be Verified

GSTR 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.

Four fields, three of them auto-populated. It looks like the least interesting part of the form — until a legal name in the GST registration turns out not to match the certificate of incorporation, at which point the answer is an amendment under the Companies Act, not a note in the reconciliation.

Part I captures Sl. No. 1 Financial Year, Sl. No. 2 GSTIN, Sl. No. 3A Legal Name and 3B Trade Name — both auto-populated — and Sl. No. 4: "Are you liable to audit under any Act?" The Guide's caution: "the distinction between a trade name and a legal name must be clearly understood and borne out in Sl. No. 3A and 3B of Part-A and should not be used interchangeably."

Legal name against trade name

"The word 'trade' is used in Sl. No. 3B… may not be limited to occupation or business. It could be a connotation. The word 'trade' ought to be understood in its ordinary sense, without any reference to 'business'."

The Guide's two examples:

"trade name is used by trade and industry to identify their businesses symbolizing their reputation. Caution must be exercised in listing the trade name and legal name."

Where there is no trade name, "Sl. No. 3B of Part-A would not be applicable. Therefore, NOT APPLICABLE may be stated… which could be verified from the auto populated data."

How to verify each

"The legal name and trade name ought to be verified with the certificate of registration issued by the tax department in FORM GST REG-06."

And against the source document for the entity:

• a company — the certificate of incorporation under the Companies Act, 2013;
• a partnership firm — "the certificate issued by the registrar of firms";
• any other case — "the NAME mentioned in the PAN can be considered."

Two situations the Guide flags:

• "Legal name in the documents under other statute does not match the legal name on the registration certificate";
• "Trade name is not disclosed on the registration certificate."

And what to do about the first:

"Any discrepancy in the 'Trade Name' and 'Legal Name' may necessitate an amendment under the appropriate law. E.g., the name of the company in the certificate of incorporation is 'XYZ Advertising Private Limited' whereas in the certificate of registration under GST it could be 'XYZ Advertising Limited' — which would require an amendment bearing in mind the correct name, which is the certificate of incorporation in this case."

The direction of correction is stated. The incorporation certificate is authoritative; the GST registration follows it. A mismatch is fixed by amending REG-06, not by reporting the GST version.

Note that a name discrepancy is not merely cosmetic. Registration particulars flow into every tax invoice under rule 46, into e-invoicing and e-way bills, and into refund sanction orders — so an unamended mismatch propagates.

Sl. No. 4: liable to audit under any Act

"It is possible that an entity could be subjected to audit under several statutes."

The Guide's three illustrations:

• "a proprietary concern could be subject to audit under the Income-tax Act, 1961";
• "a private limited company could be subject to the statutory audit under the Companies Act, 2013 as well as under the Income-tax Act";
• "a society registered under the Societies Registration Act may be subject to audit under that Act as well as under the Income-tax Act."

"This fact must be specified in Sl. No. 4."

It is the only field in Part I calling for a judgment, and it is a plural answer — the question is which statutes, not whether one applies.

And it has a practical consequence for the rest of the form. Where the entity is audited under the Companies Act, the audited financial statements required for Table 5A exist and must be annexed. Where the only audit is under the Income-tax Act, the "audited financial statements" reference is read, per the instructions, as including "reference to books of accounts in case of persons/entities having presence over multiple States." Table 5A →

Financial year and GSTIN

Financial year — "1st day of April… 31st day of March" under the General Clauses Act, the GST laws not defining it. FY 2017-18 was nine months under GST, from 1 July 2017.

GSTIN — "a State-wise PAN based 15-digit GSTIN", and "The importance of verification of the GSTIN is paramount", since the statement is filed separately for each.

These four fields are common to GSTR-9, GSTR-9A and GSTR-9C — "the write-up would equally apply to these Sl. Nos."

Key takeaways

• Part I has four fields; only Sl. No. 4 requires a judgment.
• Legal name and trade name are not interchangeable — Indigo is a trade name, InterGlobe Aviation Limited is the legal name.
• Verify both against FORM GST REG-06, and the legal name against the certificate of incorporation, registrar of firms certificate, or the name on the PAN.
• Where there is no trade name, state NOT APPLICABLE.
• A mismatch between the incorporation certificate and REG-06 requires an amendment, with the incorporation certificate governing.
• Sl. No. 4 may have more than one answer — the Companies Act, the Income-tax Act, the Societies Registration Act, or others.
• Financial year follows the General Clauses Act; FY 2017-18 covered nine months of GST.
• The GSTIN is State-wise and PAN-based, and the statement is filed per GSTIN.

Read next

• GSTR-9C: Applicability, the ₹5 Crore Line, and Self-Certification
• 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 Form GSTR-9C and its instructions, rule 80 of the CGST Rules, 2017, FORM GST REG-06, the Companies Act, 2013, the Income-tax Act, 1961 and the General Clauses Act, 1897, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).