GSTR-9C Tables 10 and 11: Unreconciled Tax and What Is Payable

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.

Table 11 is where Part III becomes money. It carries only what is payable — and the Guide is explicit that there is no negative row. A taxpayer with a ₹7 shortfall on one reason and a ₹14 excess on another declares and pays the ₹7.

Table 10 requires "Reasons for non-reconciliation between payable/liability declared in Table 9P above and the amount payable in Table 9Q", in free text with amounts. Table 11 carries "Additional amount payable but not paid (due to reasons specified under Tables 6, 8 and 10 above)", rate-wise, with rows for interest, late fee, penalty and others — and headed "To be paid through Cash".

The three scenarios behind a Table 10 difference

(A) GSTR-3B shows less or more tax paid. "GSTR-1 matches with the audited financials with regard to the tax payable. GSTR-3B shows the tax paid differently from the books."

"In this situation, even though Tables 6 and 8 may not show any differences, Table 10 would show a difference… So, any tax payable occurring due to this would automatically form part of Table 11."

And the sentence that defines Table 11's design: "In case any excess tax has been paid, there will be no reporting in Table 11. There is also no provision of negative reporting in Table 11."

(B) GSTR-1 and GSTR-3B match each other but not the financials. "Such differences would be depicted in Tables 6, 8 and 10. If the turnover is lesser than what it is in the audited financials, they could indicate a short payment of tax if differences thereof are not explained."

(C) Taxable turnover matches everywhere but the tax does not. "The value of taxable supply in GSTR-3B matches with that in GSTR-1. Tax payable as self-assessed in GSTR-3B is different from what is shown in GSTR-1."

"The possible reason… can be because of the difference in the classification of supply" — HSN disputes, GST rate disputes, inter-State against intra-State, place of supply, and taxable against exempt or nil-rated.

And the governing principle: "the amount of tax in Table 9P shall be calculated on the basis of turnover reported and shall be treated as correct. Any deviation from the same shall be disclosed in Table 10."

Not every difference is a liability

"in the case of amounts reported in Table 6, reasons for non-reconciliation may be due to difference in timing or due to a permanent difference in turnover as per the books of accounts and the GST returns. However, every non-reconciliation might not lead to a situation where there is a requirement to pay GST on the said difference."

Four examples the Guide gives where no tax follows:

• "Difference in turnover where the time of supply is postponed but revenue is recognized in books ";
• "Difference in the value of export turnover reported in the books on the invoice value shown in the shipping bill whereas GSTR-1 uses the invoice prepared in INR at the rate on the date of preparation";
• "Difference in turnover of services due to tax paid on advances and shown in GSTR-1 but not required to be disclosed as turnover in the audited financial statements";
• "Difference in turnover due to disclosure of profit/loss on sale of fixed assets in the audited financial statements and disclosure of wholesale proceeds in GST returns."

"In the given cases, no reporting is required to be done in Table 11."

The other differences do carry tax, and "shall principally cover such cases where there is difference in taxable turnover in GST returns and the adjusted total turnover. These… shall actually be a part of Table 8 again."

How the tables filter

The Guide describes a funnel:

• Table 6 — reasons for the gross turnover difference (5R). Some are permanent or timing differences with no tax.
• Table 8 — reasons for the taxable turnover difference (7G). "out of such non-reconciliation filtered out and reported in Table 8…"
• Table 10 — "a further filter of non-reconciliation… regarding tax liability which should have been paid on un-reconciled turnover reported in Table 8, but the same was not paid as declared in FORM GSTR-9."
• Table 11 — "Since Table 11 requires the disclosure of additional tax liability payable and not paid on non-reconciliations, it is evident that such details shall be reported in Table 10 also."

Each stage narrows the population. A difference must survive all three filters to become a payment.

The worked illustration, and why gross beats net

The Guide's example has four reasons on one reconciliation:

Gross additional tax to be paid: ₹7 (CGST 2.5, SGST 2.5, IGST 2). Gross excess already paid: ₹14. Net: −₹7.

And the conclusion: "though the total amount of non-reconciliation is in the negative, there are instances where for a unique reason the tax liability is either payable or has been paid in excess. It is suggested that under Table 11, the reasons due to which the tax liability should have been additionally paid but was not paid should be disclosed rate-wise."

"Legally, in the given case, the registered person is required to pay additional tax of ₹7… Further, he is entitled to claim refund of ₹7 additionally paid in case the same has not been subsequently adjusted in FORM GSTR-3B filed upto 30th November of the next financial year."

Two separate transactions, not one. The shortfall is paid in cash; the excess is claimed as a refund. They do not offset because they arise from different supplies at different rates in different heads.

Interest, penalty and late fee

"The method suggested for calculating interest, late fees and penalty shall be employed to find the gross amounts, and the difference of amounts not reported in FORM GSTR-9 shall be required to be disclosed."

And an item to look for outside the returns: "Checking needs to be done to see if there is any amount which should not have been reported in the monthly GST returns (like penalty under section 129 for movement of goods without compliance of rule 138) but accounted for in the books and relating to GST should also be reported."

Section 129 detention penalties never pass through GSTR-3B but sit in the profit and loss account — so "The respective accounts of expenses in the profit and loss account needs to be referred."

Key takeaways

• Table 10 explains the 9P against 9Q difference; Table 11 carries only what is payable and unpaid.
• Table 11 has no negative row — "there is also no provision of negative reporting".
• Excess tax paid is claimed as a refund, not netted in Table 11, and only if not already adjusted by 30 November.
• Three scenarios: GSTR-3B differs from books; GSTR-1 and GSTR-3B agree but differ from books; turnover agrees but tax differs on classification.
• Table 9P is treated as correct; deviations go to Table 10.
• Four named differences carry no tax — developer-landlord time of supply, export exchange rates, service advances, and net asset-sale disclosure.
• Differences filter through Tables 6 → 8 → 10 → 11, narrowing at each stage.
• Report rate-wise and reason-wise, gross — a net-negative reconciliation can still carry a payable.
• Section 129 penalties are in the books but never in the returns, and must be picked up.

Read next

• GSTR-9C Part V: Additional Liability and DRC-03
• GSTR-9C Table 9: Rate-Wise Liability and Amount Payable
• GSTR-9C Table 5R and Table 6: Unreconciled Turnover

Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9C and its instructions, sections 50 and 129 of the CGST Act, 2017, rule 138 of the CGST Rules, 2017 and Notification No. 04/2018-Central Tax (Rate) dated 25 January 2018, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).