GSTR-9C Part V: Additional Liability and DRC-03

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.

Everything the reconciliation has found arrives here. Part V takes Table 11 from the turnover side and Table 16 from the credit side — and adds three rows that nothing else in the form produces.

"Part V consists of the additional liability to be discharged by the taxpayer due to non-reconciliation of turnover or non-reconciliation of input tax credit. Any refund which has been erroneously taken and shall be paid back to the Government shall also be declared in this table. Lastly, any other outstanding demand which is to be settled by the taxpayer shall be declared in this Table." And: "taxpayers shall be given an option to pay any additional liability declared in this form, through FORM DRC-03. Taxpayers shall select 'Reconciliation Statement' in the drop down… such liability shall be paid through electronic cash ledger only."

What the table contains

Rate-wise rows — 5%, 6%, 12%, 18%, 28%, 40%, 3%, 0.25%, 0.10%, Others, and supplies on which the e-commerce operator pays under section 9(5) — the 6% row inserted by Notification No. 38/2023-CT dated 04.08.2023 and Others by Notification No. 30/2021-CT dated 30.07.2021.

Then six further rows:

• Input Tax Credit
• Interest
• Late Fee
• Penalty
• Any other amount paid for supplies not included in Annual Return (FORM GSTR-9)
• Erroneous refund to be paid back
• Outstanding demands to be settled
• Other (pl. specify)

The last three exist nowhere else in the statement. Nothing in Tables 5 to 16 computes an erroneous refund or an outstanding demand — they are brought in here because Part V is the point at which the taxpayer settles up.

Where the numbers come from

"Any additional tax liability that may arise due to non-reconciliation between the turnovers or the tax payable on such turnovers would be reported in Table 11. Further, any additional tax liability arising due to non-reconciliation of the input tax credit are to be disclosed in Table 16. The amount reported in these two Tables would be summarized and reported in Part V."

And separately: "Additional tax liability may arise on account of any other amount paid for supplies not included in the annual return, erroneous refund to be paid back, outstanding demands to be settled, etc."

The three situations, and the judgment each requires

The Guide sets out where a turnover-side liability comes from, and each case turns on the taxpayer deciding which document was wrong.

Situation 1 — GSTR-1 matches the financials but GSTR-3B differs. "even though Table 6 and 8 may not reflect any differences… Table 10 would reflect a difference of the amount of tax to be paid and tax actually paid. Therefore, any tax payable occurring due to this would automatically form part of Table 11 and thereby additional liability… The registered person would do so only after taking a judgement call that the amounts reported in FORM GSTR-1 and the audited financial statements were correct and that the reporting in FORM GSTR-3B was incorrect."

Situation 2 — GSTR-3B matches the financials but GSTR-1 differs. "the differences would most clearly be evident from Tables 6 and 8… This difference would be reported as part of Table 10… Therefore, this should form part of the additional amount of tax payable. The registered person would do so only after taking a judgement call that the amounts reported in FORM GSTR-3B were incorrect as compared to that reported in FORM GSTR-1 was correct. Of course, if the reverse is true, then even though there is a difference between the two, the additional liability in Part V would not contain the said amount."

Situation 3 — GSTR-1 and GSTR-3B agree but neither matches the financials. "Such differences would figure in all the Tables 6, 8 and 10 as such turnover, if lower than the audited financials, will result in short payment of tax (if differences thereof are not explained)… Therefore, this should form part of additional amount of tax payable."

The recurring phrase is "judgement call". Part V is not arithmetic — it records a conclusion about which of three records is right, and the reasons tables are where that conclusion is justified.

Two structural requirements

Forward and reverse charge are computed separately. The reconciliation covers "Total turnover and taxable turnover; Output tax liability; Liability under reverse charge", each "required to be disclosed and reconciled separately between FORM GSTR-3B and the audited financial statements in Table 9. Any additional amount that is liable to be paid… would be disclosed together in Table 11 and in Part V."

And everything is rate-wise. "Any additional tax liability that occurs either under forward charge or reverse charge needs to be shown on rate-wise basis. In fact, the tax payable in Table 9 which is the source of the reconciliation also demands that tax payable be disclosed on a rate-wise basis. This rate-wise breakup… would be shown in Table 11 and in Part V."

The credit side

"The non-reconciliation difference in can occur due to:"

• "Non-reconciliation of the credits which are booked in one financial year and claimed in the subsequent financial year with regard to the audited financial statements and the annual return (Table 13)";
• "Non-reconciliation of the credits between the head-wise " — Table 15. Tables 15 and 16 →

Paying it

Three constraints, all stated in the instructions:

• payment is through DRC-03;
• the taxpayer must select "Reconciliation Statement" in the drop-down;
• "such liability shall be paid through electronic cash ledger only."

The cash-only rule is the one with commercial consequence. A taxpayer with a large credit balance still pays this liability in cash — and, where the liability arises from wrongly availed credit, that is exactly the point: the credit that was taken is being replaced with money.

And the selection in DRC-03 is not cosmetic. It identifies the payment as arising from the reconciliation statement rather than from a voluntary payment or a notice, which is how it is later matched to the filed GSTR-9C.

Key takeaways

• Part V summarises Table 11 (turnover side) and Table 16 (credit side).
• It also carries three rows nothing else produces — supplies not included in the annual return, erroneous refund to be paid back, and outstanding demands to be settled.
• Rate rows include 6% (Notification No. 38/2023-CT), Others (Notification No. 30/2021-CT) and the section 9(5) e-commerce row.
• Three situations produce a turnover-side liability, and each requires a judgment call about which record is correct.
• Where GSTR-3B is the correct record and GSTR-1 is wrong, no additional liability arises despite the difference.
• Forward charge and reverse charge are reconciled separately, and everything is reported rate-wise.
• Payment is through DRC-03, selecting "Reconciliation Statement", and from the electronic cash ledger only.
• Credit cannot be used to discharge Part V, even where the liability arose from excess credit.

Read next

• GSTR-9C Tables 15 and 16: Unreconciled ITC and Tax Payable
• GSTR-9C Tables 10 and 11: Unreconciled Tax and What Is Payable
• GSTR-9C: Applicability, the ₹5 Crore Line, and Self-Certification

Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9C and its instructions, Notifications No. 30/2021 and 38/2023-Central Tax and Form GST DRC-03, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).