GSTR-9C Tables 5B and 5H: Unbilled Revenue

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Two accounting standards and one GST provision guarantee this adjustment will exist every year. AS-9 and Ind AS-115 recognise revenue when performance occurs; section 31 read with rule 47 allows the invoice up to thirty days later. Any service performed in late March falls into the gap.

Table 5B adds "Unbilled revenue at the beginning of Financial Year" — "Unbilled revenue which was recorded in the books of accounts on the basis of accrual system of accounting in the last financial year and was carried forward to the current financial year… when GST is payable during the financial year on such revenue (which was recognized earlier)." Table 5H deducts the mirror figure at the year end. For FY 2017-18 through 2022-23, filling 5B was optional, with adjustments permitted in Table 5O instead.

Why the difference exists

"unbilled revenue is the revenue recognized in the books of accounts before the issue of an invoice at the end of a particular period. AS-9 'Revenue Recognition' / IND-AS-115 'Revenue from Contracts with Customers' provides for recognition of revenue on full completion/partial completion of the services though the due date for issuing invoice as per the contract would be on a later date."

The GST side. Under section 13, time of supply of services is generally "the date of issue of invoice by the supplier, if the invoice is issued within the legally prescribed period under section 31… or the date of receipt of payment, whichever is earlier"; the date of provision of service if the invoice is not issued in time; and failing both, "the date on which the recipient shows the receipt of service in his books."

And section 31 read with rule 47 sets that period: "an invoice for supply of services needs to be issued before or after the provision of service but not later than thirty days from the date of provision of service. From the above it is clear that, if the supplier does not receive money in advance, he gets 30 days' time from the date of provision of service to raise invoice and collect tax."

Hence: "there would be a timing difference in the recognition of revenue in the books of accounts and the GST provisions. Because of this, Table No. 5B is necessary."

The four illustrations

The Guide's examples, all turning on a billing cycle that crosses 31 March:

• Rental contract billed on the 20th of every month — "unbilled revenue would be recognized in the books of accounts as on 31st March to the extent of 11 days of services provided in March."
• Maintenance contract billed on the 5th of the subsequent month — "unbilled revenue would be recognized… as on 31st March."
• Construction services — "The cost incurred as on 31st March towards construction services for which billing would be done on reaching the milestone in September of the next financial year."
• Cost-plus companies — "if any cost is excluded from billing cycle during the financial year and is identified at the time of audit, it would be booked as unbilled revenue and invoice would be raised in the month in which it is identified i.e., September or October."

And the reporting rule: "value will be reported in Table 5B only for the transactions for which invoice is raised during April to March " — that is, opening unbilled revenue actually invoiced and taxed during the year, not the whole opening balance.

The Guide's worked instruction, from the form itself: "if ₹10 Crore of unbilled revenue existed for the financial year 2016-17, and during the current financial year, GST was paid on ₹4 Crore of such revenue, then value of ₹4 Crore shall be declared here."

Six crore stays out, to be reported in a later year when invoiced.

How the two rows work together

5B (+) brings in last year's unbilled revenue now taxed — it was income last year in the accounts but turnover this year in GST.

5H (−) takes out this year's unbilled revenue not yet taxed — it is income this year in the accounts but will be turnover next year in GST.

The two are structurally symmetrical, and this year's 5H becomes next year's 5B. A break in that chain across two consecutive statements is a reliable indicator that something was missed.

Note also which side of the equation each sits on. Table 5A starts from accounting turnover, so an adjustment that moves an item into the GST year is an addition, and one that moves it out is a deduction.

Verification

Source. "For information of unbilled revenue at the beginning of a financial year, reference may be made to previous year's audited financial statements." For multi-registration entities, "a separate statement is to be obtained for each GSTIN reconciling the total with the amount disclosed in the financials."

Three control checks:

• "Must be vouched/checked with notes to accounts in the Balance Sheet (PY and CY)";
• "Notes to FORM GSTR-9C may be drafted for this Table as to the manner of its quantification from the books and records and correlated with returns filed in FORM GSTR-3B";
• "Adequate attention of the reader must be drawn to 'Notes on Accounts' and 'Significant Accounting Policies' in cases of entities that need to adhere to statutory audit provisions."

The middle one is the practically important instruction. Because 5B and 5H are optional in several years and are pure timing items, a note explaining how the figure was derived is what makes the adjustment defensible.

Key takeaways

• Unbilled revenue is revenue recognised under AS-9 / Ind AS-115 before an invoice is issued.
• The gap arises because section 31 and rule 47 allow thirty days from provision of service to invoice.
• 5B adds last year's unbilled revenue on which GST was paid this year; 5H deducts this year's unbilled revenue.
• Only the portion actually invoiced and taxed in the year goes into 5B — not the whole opening balance.
• This year's 5H should equal next year's 5B — a useful year-on-year check.
• Typical cases: mid-month rental billing, next-month maintenance billing, milestone construction billing, and cost-plus costs identified at audit.
• 5B was optional for FY 2017-18 to 2022-23, with adjustments permitted in Table 5O.
• Verify against the prior year's notes to accounts, and draft a note explaining the derivation.

Read next

• GSTR-9C Tables 5C and 5I: Unadjusted Advances
• GSTR-9C Table 5A: Turnover From the Audited Financial Statements
• GSTR-9C Table 5O: The Residual Adjustment Row

Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9C and its instructions, sections 13 and 31 of the CGST Act, 2017, rule 47 of the CGST Rules, 2017 and AS-9 and Ind AS-115, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).