What this covers
The annual return and, where it applies, the reconciliation statement — consolidating the year's returns, reconciling them to the audited accounts, and disclosing the differences properly rather than filing a summary that does not tie to the books.
Statutory basis
Section 44 of the CGST Act, 2017 read with Rule 80 of the CGST Rules, 2017. The annual return is Form GSTR-9. Where turnover exceeds the prescribed limit, a self-certified reconciliation statement in Form GSTR-9C is required with it — since it became self-certified, the responsibility for the reconciliation sits with the taxpayer rather than with a certifying auditor, which has raised rather than lowered the standard of working papers needed.
Who it applies to
Every registered person, with exceptions including a person paying tax under the composition scheme, who files a different annual return, and casual and non-resident taxable persons. Filing is optional below the turnover threshold prescribed for GSTR-9, and the reconciliation statement in GSTR-9C applies only above its own, higher threshold. The thresholds are notified and have changed, so we confirm them for the year rather than working from the previous year's position.
What we do
- 1Consolidate the year's outward supplies from the monthly and quarterly returns, and reconcile the total to the turnover in the audited accounts.
- 2Explain each difference by reason — timing, credit notes, non-GST income, supplies reported in the wrong period — rather than leaving a residual.
- 3Reconcile input tax credit claimed to the auto-populated statement and to the purchase ledger, and identify what was reversed and re-claimed during the year.
- 4Reconcile tax paid across cash and credit ledgers to the returns and to the accounts.
- 5Quantify anything that should have been paid and was not, and pay it with interest before filing, which is materially cheaper than being assessed for it.
- 6Complete the annual return, and the reconciliation statement where it applies, with working papers that stand behind every reported difference.
- 7File, and give you a note on the differences found and what to change in the coming year.
What you receive
- Turnover reconciliation
- Returns to books, with each difference explained and evidenced.
- Credit reconciliation
- Credit claimed, reversed and available, tied to the statement and the ledger.
- Additional liability working
- What is payable with interest, and why.
- Returns filed
- GSTR-9, and GSTR-9C where applicable, filed with the working papers retained.
- Improvement note
- The recurring causes of difference, and the process fix for each.
Documents and information required
All returns filed for the year · audited financial statements with the turnover schedule · trial balance mapped to GST heads · purchase and sales registers · credit and debit notes issued and received · e-way bill data where relevant · auto-populated credit statements for each month · records of reversals · previous year's annual return and reconciliation.
Key dates
The annual return for a financial year is ordinarily due on 31 December following the year end, and it has been extended by notification in several years. It matters more than its own due date suggests: the time limit for claiming input tax credit for the year is tied to it, so an annual return filed at the last moment leaves no room to act on what the reconciliation finds.