GSTR-9C Table 7: Reconciliation of Taxable Turnover

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.

Part II ends by narrowing adjusted turnover to taxable turnover. Four deductions do that — and the least obvious rule in the table is that 7C must include zero-rated supplies that were never declared in any return, because Table 5P already contains them.

Table 7A carries forward "Annual turnover after adjustments (from 5P above)", auto-populated. 7B deducts "Value of Exempted, Nil Rated, Non-GST supplies, No-Supply Turnover"; 7C deducts "Zero rated supplies without payment of tax"; 7D deducts "Supplies on which tax is to be paid by the recipient on reverse charge basis". 7E is the resulting taxable turnover, 7F the taxable turnover as per the annual return, and 7G the unreconciled difference. All three deductions are "reported net of credit notes, debit notes and amendments, if any."

Table 7B: four classes in one row

"Table 7B essentially comprises the following 4 classes/types of supplies —"

And the reason all four sit together: "The definition of exempt supply under section 2(47) covers three out of four terms used in Table 7B and is also a part of disclosures in GSTR-1, GSTR-3B and GSTR-9. Further, common instruction to Tables 5D, 5E and 5F of FORM GSTR-9 specifically includes the value of 'no supply'. Therefore, the turnover disclosed as 'no supply' would appear only in FORM GSTR-9 and FORM GSTR-9C."

The obligation is to break it out: "the registered person needs to disclose data relating to each sub-group within the definition of 'exempt supply', whether or not they were reported in FORM GSTR-1 and FORM GSTR-3B."

Where the figures come from: "generally… from the credit side of the profit and loss account. In case of a barter transaction, the sale of fixed assets at loss etc. would not appear in the profit and loss account. Therefore, that information shall be obtained from the fixed assets schedule or the stock register. The value of no-supply can be taken as reported in the books."

The Guide's hospital illustration: consultation fees ₹2,50,00,000 (exempt); diagnostic services ₹40,00,000 (exempt); excess petrol sold to a related party ₹10,000 (non-taxable); land sold ₹5,00,00,000 (no supply).

Three control checks: cross-link to GSTR-9 Tables 5D, 5E and 5F; draft notes to GSTR-9C on how the figure was quantified; and "To be cross checked with exempted turnover computation for the purpose of section 17(2)" — the rule 42 base. Rule 42 reversal →

Table 7C: the rule that catches people out

"Table 7C… requires disclosure of value of zero-rated supplies without the payment of tax which forms part of the 'Annual turnover after adjustments' from Table 5P. This should also consist of the value of zero-rated supplies which have not been declared in the monthly return/annual return erroneously for the reason that the adjusted turnover at Table 5P contains even such zero-rated supplies. Therefore, such value… should be deducted from the adjusted annual turnover so as to claim exemption. In short, the zero-rated supplies as recorded in the audited annual financial statements should be declared against Table 7C."

This is the opposite of the Table 5O rule. An undeclared taxable supply must not be adjusted away; an undeclared zero-rated supply must be deducted here — because it is in 5P, carries no tax, and would otherwise inflate taxable turnover.

Four exclusions from 7C:

• Zero-rated supplies with payment of tax — "Such exports would form part of the taxable turnover to be arrived at Table 7F";
• Supplies where tax was remitted under rule 96A — "If the tax is remitted in terms of rule 96A, the relevant zero-rated supplies should not be declared against Table 7C since the tax on such supplies have been remitted";
• Merchanting trade — "supplies effected under merchanting trade would not qualify as an export under the GST law. Accordingly, such supplies may not be declared under the reconciliation statement";
• Deemed exports — "shall not be declared against Table 7C since such supplies would not qualify as zero-rated supplies."

And one item that goes to 5O instead: "Goods exported in pre-GST regime, but recognised as revenue in GST regime in the audited annual financial statements… should be declared against Table 5O."

Export timing: FOB against CIF

The Guide addresses when export revenue belongs to a year at all:

"In case of FOB contract the revenue is recognized on the date of actual shipment or filing of bill of lading as the risk of title and ownership is transferred… when the goods are boarded on the conveyance. In the case of CIF contract, the revenue is recognized on the date of receipt of delivery by the foreign buyer."

"Revenue cannot be recognized based on the invoice date and hence, such revenue may be classified as un-earned revenue till the actual shipment", with entries Foreign buyer Dr / Unearned revenue Cr on invoicing, and Unearned Revenue Dr / Sales Cr on recognition.

The year-end consequence: "where the tax invoice is issued prior to 31st March… and shipping bill/delivery of goods takes place after 31st March… If the exports are recognised as revenue for the financial year, such value should be declared against Table 7C. However, if the exports are recorded as un-earned revenue in the annual audited financial statement as on 31st March, this would not form part of the revenue at Table 5A."

The LUT position, and realisation

Late LUT does not defeat the claim. "attention is drawn to Circular No. 125/44/2019-GST dated 18.11.2019 wherein it is clarified that substantial benefits of zero-rated supplies should not be denied if it is established that the goods or services have been exported."

But rule 96A imposes a deadline — tax with interest within fifteen days after three months for goods not exported, or after one year for services not realised in convertible foreign exchange.

And rule 96B claws refunds back. Where sale proceeds are not realised within the FEMA period, the refund of unutilised ITC or IGST paid must be repaid "to the extent of non-realisation… along with applicable interest within thirty days of the expiry of the said period", failing which it is recovered under section 73 or 74 with interest under section 50.

Documents to verify include export invoices and packing lists, shipping bill and bill of lading, refund applications, ICEGATE verification on a sample basis, the LUT in RFD-11, and foreign inward remittance — noting that "with substitution of sub-section (3) of section 16 of IGST Act with effect from 01.10.2023, foreign remittance certificate is required for export of goods also." For SEZ supplies, the invoice must carry the SEZ officer's endorsement.

Key takeaways

• 7A carries 5P forward; 7B, 7C and 7D deduct to reach taxable turnover at 7E, compared with the return at 7F, leaving 7G.
• All three deductions are net of credit notes, debit notes and amendments.
• 7B has four classes — nil rated, exempted, non-taxable (section 2(78)) and no supply (Schedule III) — each to be identified separately.
• "No supply" turnover appears only in GSTR-9 and GSTR-9C, nowhere else.
• 7B should tie to the exempt turnover used for section 17(2) and rule 42.
• 7C must include zero-rated supplies never declared in the returns, because 5P already contains them.
• 7C excludes exports with payment of tax, supplies where rule 96A tax was remitted, merchanting trade, and deemed exports.
• FOB revenue is recognised on shipment, CIF on delivery — year-end unearned revenue never reaches 5A at all.
• Circular No. 125/44/2019 preserves zero-rating despite a late LUT; rule 96B claws refunds back on non-realisation, and since 01.10.2023 a remittance certificate is needed for goods too.

Read next

• GSTR-9C Table 9: Rate-Wise Liability and Amount Payable
• GSTR-9C Table 5R and Table 6: Unreconciled Turnover
• GSTR-9 Table 5: Supplies on Which Tax Is Not Payable

Disclaimer: Positions stated as on 5 September 2026, based on Form GSTR-9C and its instructions, sections 2(47), 2(78), 2(98), 9 and 17(2) of the CGST Act, 2017, section 16 of the IGST Act, 2017, rules 96A and 96B of the CGST Rules, 2017, Notification No. 11/2017-Central Tax (Rate) and Circular No. 125/44/2019-GST, as reproduced in the ICAI Technical Guide on GST Reconciliation Statement (Form GSTR-9C).