GSTR-9C Table 5N: Foreign Exchange Fluctuation

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A single export invoice can be valued at three different exchange rates — one for GST, one for the accounts, and one when the money actually arrives. Two of those three differences land in Table 5N.

Table 5N carries "Adjustments in turnover due to foreign exchange fluctuations (+/-)" — "Any difference between the turnover reported in the Annual Return and turnover reported in the audited Annual Financial Statement due to foreign exchange fluctuations shall be declared here." It was optional for FY 2017-18 to FY 2021-22, reportable in Table 5O.

Why three rates exist

For the books — "Forex transactions are accounted… based on AS 11 'Effects of Changes in Foreign Exchange Rates' / Ind AS 21."

For GST — rule 34 requires:

• "The value of taxable goods to be determined on the basis of the exchange rate notified under section 14 of the Customs Act, 1962."
• "The value of taxable services is to be determined on the basis of the applicable rate of exchange determined as per generally accepted accounting principles for the date of time of supply of such services in terms of section 13."

"Since the exchange rates applied to forex amounts for accounting purposes are different from the exchange rates applied for determining the value of taxable goods and services, there could be a difference between the turnover recorded in the books when compared with the turnover declared for the purpose of GST returns."

Note the asymmetry inside rule 34 itself. For goods the rate is externally fixed by a customs notification; for services it is the taxpayer's own GAAP rate at the time of supply — so services generally produce no 5N adjustment, and goods almost always do.

The worked example, both ways

PQR Ltd. exports goods worth $100,000. On the date of filing the shipping bill:

For GST, the exchange rate is ₹65 and exports are ₹65,00,000. For the accounts, it is ₹68 and exports are ₹68,00,000. "The difference in revenue being ₹3,00,000 would have to be reduced from the annual turnover as per the financials to arrive at the revenue as per FORM GSTR-9."

Then the money arrives.

Case (a) — bank rate ₹70. "difference in the amount booked in the accounts and actual amount received being ₹70 − ₹68 = ₹2 × $1,00,000 = ₹2,00,000 would be credited to the Profit and Loss Account as Forex Gain which again needs to be reduced from the Annual turnover as per the financials."

Case (b) — bank rate ₹66. "₹66 − ₹68 = (−) ₹2 × $1,00,000 = (−) ₹2,00,000 would be debited to the Profit and Loss Account as forex loss which again needs to be added in the annual turnover."

So there are two separate adjustments in each case:

The reason the realisation difference appears at all is Table 5A's instruction to include "indirect income in the form of… forex fluctuation". Having been added into the gross figure, it must be taken back out to reach GST turnover. Table 5A →

Source, validation and revision

Source. "Export of goods are stated in Table 6 of FORM GSTR-1 and its amendments are given effect in Table 9 of FORM GSTR-1 and at Table 3.1(b) in FORM GSTR-3B. The forex gain/loss arising due to the difference in the amount booked in accounts and actual amount received forms part of the Profit and Loss Account."

Validation. "The 'Activities in Foreign Currency' are reported as part of the notes of accounts to the financial statements of companies."

Revision. "Foreign exchange fluctuation is purely an accounting concept and does not form part of the GST returns and hence revision of return is not required."

That last point is worth holding. A 5N adjustment never generates additional tax by itself — it explains a difference rather than correcting an error. Unlike Table 5O items, which can carry liability into Table 11, this row is a pure presentation reconciliation.

And the Guide adds a general caution: "FORM GSTR-9C should contain notes disclosing the limitations inherent in this exercise."

Where forex meets other tables

Table 6 recognises the same issue as a reason for non-reconciliation: "Difference in the value of export turnover reported in the books of accounts on the basis of invoice value shown in the shipping bill whereas turnover reported in FORM GSTR-1 on the basis of invoice prepared in INR on the basis of exchange rate applicable on the date of preparation of invoice."

And it is expressly listed as a case needing no tax: among "examples where non-reconciliation is reported in Table 6… but shall not require any additional tax payment." Table 5R and Table 6 →

Key takeaways

• Rule 34 fixes the GST rate: section 14 of the Customs Act for goods, GAAP at the time of supply for services.
• The books follow AS 11 / Ind AS 21, producing a different rate.
• Services rarely generate a 5N adjustment; goods routinely do.
• Two components: the invoicing-date rate difference and the realisation gain or loss.
• A forex gain is deducted; a forex loss is added — because Table 5A included forex fluctuation as indirect income.
• In the Guide's example, the CBIC rate of ₹65 against the RBI rate of ₹68 produced a ₹3,00,000 deduction before any realisation effect.
• No revision of returns is required — the difference is an accounting concept, not an error.
• Source from Table 6 and Table 9 of GSTR-1, Table 3.1(b) of GSTR-3B, and the profit and loss account; validate against the "Activities in Foreign Currency" note.
• The same difference is a listed Table 6 reason that requires no additional tax.

Read next

• GSTR-9C Table 5O: The Residual Adjustment Row
• GSTR-9C Table 5M: Valuation Adjustments Under Section 15
• 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, section 13 of the CGST Act, 2017, rule 34 of the CGST Rules, 2017, section 14 of the Customs Act, 1962, and AS 11 and Ind AS 21, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).