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GSTR-9 / 9C Applicability Checker.

Annual return season, answered in one screen: the ₹2 crore GSTR-9 exemption (now permanent), the ₹5 crore self-certified GSTR-9C threshold, the 31 December due date, and the Section 47 late-fee slabs.

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Your profile for the financial year

Registration type

Aggregate turnover for the FY (all-India, PAN level — taxable + exempt + exports)

Where this fits

For auditors, 9C is where the year reconciles — or doesn't.

The GSTR-9C tables force books-to-returns reconciliation: turnover, tax paid, ITC. CORAA runs those reconciliations from your trial balance and returns data all year, so December is a review, not an archaeology dig.

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How GSTR-9 / 9C applicability is determined

Section 44(1) of the CGST Act requires every registered person to file an annual return (GSTR-9) for each financial year — except Input Service Distributors, TDS deductors under Section 51, TCS collectors under Section 52, casual taxable persons and non-resident taxable persons. Composition taxpayers are also outside GSTR-9: they file the annual GSTR-4 (the old GSTR-9A was discontinued from FY 2019-20).

The ₹2 crore exemption: registered persons with aggregate turnover up to ₹2 crore in the FY are exempt from filing GSTR-9. This relief ran year-by-year from FY 2017-18, and Notification 15/2025-Central Tax (17 September 2025) made it permanent for FY 2024-25 onwards. Filing remains optional — some taxpayers file voluntarily to formally close the year's position.

GSTR-9C — the reconciliation statement between the audited financial statements and the annual return — applies where aggregate turnover exceeds ₹5 crore (Rule 80(3), CGST Rules). Since FY 2020-21 it is SELF-CERTIFIED by the taxpayer: the Finance Act 2021 amended Sections 35(5) and 44 to drop the CA/CMA certification requirement, operationalised by Notifications 29/2021 and 30/2021-Central Tax. Both GSTR-9 and 9C are due by 31 December following the financial year, filed GSTIN-wise even though the thresholds are tested PAN-wise.

Late filing attracts a fee under Section 47, restructured by Notification 07/2023-Central Tax for FY 2022-23 onwards: ₹50/day (turnover up to ₹5 crore, capped at 0.04% of State turnover), ₹100/day (₹5–20 crore, same cap), ₹200/day (above ₹20 crore, capped at 0.5%) — all figures CGST + SGST combined.

Worked example — ₹6 crore trader

A regular taxpayer in Maharashtra closes FY 2025-26 with aggregate turnover of ₹6.4 crore across two GSTINs on the same PAN (₹4.1 crore in Maharashtra, ₹2.3 crore in Gujarat).

Inputs

Registration typeRegular taxpayer

Aggregate turnover (PAN)₹6.4 crore

GSTINs2 (Maharashtra + Gujarat)

Output

GSTR-9Mandatory — for EACH GSTIN separately

GSTR-9CRequired (self-certified) — turnover > ₹5 Cr, again per GSTIN

Due date31 December 2026

Late-fee slab if missed₹100/day, capped at 0.04% of turnover in each State

The ₹5 crore GSTR-9C test uses PAN-level aggregate turnover — ₹6.4 crore — even though neither individual GSTIN crosses ₹5 crore. Both registrations must file GSTR-9 and a self-certified GSTR-9C. This PAN-versus-GSTIN mismatch is the most commonly missed point in annual return season.

Common mistakes

Testing the ₹2 Cr / ₹5 Cr limits GSTIN-wise

Both thresholds use AGGREGATE turnover — all-India, PAN-level, including exempt supplies and exports (Section 2(6)). A company with three ₹1.9 crore registrations has ₹5.7 crore aggregate turnover: GSTR-9 and GSTR-9C are due for every GSTIN, even though no single state crosses the line.

Thinking GSTR-9C still needs a CA certification

Not since FY 2020-21. The Finance Act 2021 scrapped the GST audit under Section 35(5); GSTR-9C is now a self-certified reconciliation statement filed by the taxpayer (Notifications 29/2021 and 30/2021-Central Tax). Budgeting for a separate "GST audit" — or skipping 9C because "no auditor was appointed" — are both wrong.

Treating the ₹2 crore exemption as "no exposure"

Skipping GSTR-9 under the exemption does not close the year. Departmental scrutiny, ITC mismatches and DRC-01 notices still reach exempt filers, and the annual return is the last clean chance to disclose and correct the year's figures. Many practitioners file voluntarily for exactly that reason.

Filing GSTR-9 on time but GSTR-9C late

Where 9C is required, the annual-return obligation is complete only when both are furnished. A 9C filed months after the 9 attracts late fee for the gap (CBIC waived this for FY 2017-18 to 2022-23 only via the Notification 08/2025-CT amnesty, for filings by 31 March 2025). Treat 31 December as the deadline for the pair.

Composition dealers hunting for GSTR-9A

GSTR-9A is dead — discontinued from FY 2019-20. Composition taxpayers file the annual GSTR-4 instead. Filing nothing because "9A is not on the portal" is a compliance failure; the GSTR-4 late fee runs ₹50/day (₹500 cap for nil, ₹2,000 cap otherwise).

Frequently asked questions

Is GSTR-9 mandatory for turnover below ₹2 crore?+

No. Registered persons with aggregate turnover up to ₹2 crore are exempt — and from FY 2024-25 onwards the exemption is permanent (Notification 15/2025-Central Tax dated 17 September 2025). Filing stays optional; earlier years had equivalent year-wise exemption notifications.

What is the turnover limit for GSTR-9C?+

GSTR-9C is required where aggregate turnover for the FY exceeds ₹5 crore (Rule 80(3), CGST Rules), tested at PAN level. It is filed along with GSTR-9, self-certified — no CA/CMA certification since FY 2020-21.

What is the due date for GSTR-9 and GSTR-9C?+

31 December following the end of the financial year (Section 44 read with Rule 80). For FY 2025-26 that means 31 December 2026, unless CBIC extends it by notification — extensions have happened in several years, so check for a current-year notification before relying on one.

What is the late fee for GSTR-9?+

For FY 2022-23 onwards (Notification 07/2023-Central Tax): turnover up to ₹5 crore — ₹50/day capped at 0.04% of turnover in the State/UT; ₹5–20 crore — ₹100/day, same cap; above ₹20 crore — ₹200/day capped at 0.5%. All figures are CGST + SGST combined; there is no IGST late fee.

Does GSTR-9C need to be certified by a Chartered Accountant?+

No — not since FY 2020-21. The Finance Act 2021 removed the GST audit requirement under Section 35(5); GSTR-9C is now self-certified by the taxpayer. Many businesses still have a CA prepare or review it, but the statutory signature is the taxpayer's own.

Who is exempt from filing GSTR-9 altogether?+

Input Service Distributors, TDS deductors (Section 51), TCS collectors (Section 52 — they file GSTR-9B), casual taxable persons and non-resident taxable persons (Section 44(1)). Composition taxpayers file the annual GSTR-4 instead of GSTR-9.

Is GSTR-9 filed per GSTIN or per PAN?+

Per GSTIN — every registration files its own GSTR-9 (and 9C where applicable). But the ₹2 crore and ₹5 crore thresholds are tested on PAN-level aggregate turnover, so one large state can drag every small state registration into filing.

Can GSTR-9 be revised after filing?+

No. There is no revision facility for GSTR-9 or GSTR-9C. Errors can only be addressed through disclosures in the next year's return or by paying differential tax via DRC-03 — which is why the pre-filing reconciliation matters more here than for monthly returns.

Authoritative sources

Notification 15/2025-Central Tax (₹2 crore GSTR-9 exemption) + Rule 80 CGST Rules — Notification 15/2025-Central Tax dated 17 September 2025 (GSTR-9 exemption up to ₹2 crore, FY 2024-25 onwards), Section 44 CGST Act read with Rule 80 CGST Rules (GSTR-9C above ₹5 crore, self-certified per Notifications 29/2021 and 30/2021-Central Tax), and Notification 07/2023-Central Tax dated 31 March 2023 (Section 47 late-fee slabs). All at cbic.gov.in.

Always confirm against the latest version of the source. Regulations evolve and amendments are common.

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GST Registration Applicability Checker →E-Invoice Applicability Checker →GST Late Fee Calculator →GSTR-9C reconciliation template →

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Last reviewed: 2026-07-29 · For informational purposes only — not professional advice.