Except for a few, all registered taxpayers under the Goods and Services Tax (GST) system have to submit the GSTR-9 annual return. It summarizes the information submitted in the quarterly or monthly returns throughout the financial year, e.g., GSTR-1, GSTR-3B, and more. Submission of GSTR-9 helps in transparency, reconciles the tax liability, and facilitates correct reporting to the tax authorities.

The form GSTR-9 contains outward and inward supplies, input tax credit (ITC) utilized, tax paid, and refund or demand during the financial year in question. The deadline for submitting GSTR-9 is usually December 31 of the year after the applicable financial year, unless the government announces an extension. Prior to filing, it is essential to ensure that all GST returns for the year are accurately filed and reconciled to avoid mistakes and potential penalties

Some taxpayers, including composition dealers, Input Service Distributors (ISD), and those required to pay TDS/TCS under GST, are relieved from filing GSTR-9. The legal team must check the disclosures provided in GSTR-9 for accuracy and completeness, confirm conformity with applicable provisions, and reduce the risk of audit questions or tax authority legal notices.

What is GSTR 9?

GSTR-9 is an input tax credit declaration that every registered person under the Goods and Services Tax (GST) regime is required to file on an annual basis, giving a summarizedview of every GST return filed on a monthly or quarterly basis within a fiscal year. It contains information regarding outward and inward supplies, input tax credit availed, tax paid, and adjustments. Filing of GSTR-9 provides financial reconciliation through correct accounting and maintaining GST law compliance.

All regular taxpayers registered under GST with total annual turnover above the specified amount are required to submit GSTR-9. But some categories like composition taxpayers, Input Service Distributors (ISD), non-resident taxable individuals, and TDS/TCS deductors are exempted.

Along with GSTR-9, those taxpayers who have turnover in excess of ₹5 crore also have to file GSTR-9C, a reconciliation statement that is certified by a chartered accountant or cost accountant. Both GSTR-9 and 9C are the major compliance reports that assist in detecting mismatches, errors, or gaps in reporting during the financial year.

GSTR 9 Applicability

Knowledge of GSTR 9 applicability is crucial for GST compliance.GSTR-9 is a yearly return that must be filed by regular taxpayers who are registered under the Goods and Services Tax (GST) system. It serves as a summary of the data already reported throughout the financial year in monthly or quarterly filings, such as GSTR-1 and GSTR-3B. This includes details related to outward and inward supplies, input tax credit (ITC), and tax payments.

In determining the applicability of GSTR 9, it should be realized that this return should be furnished by all registered taxpayers whose registration was valid at any time during the financial year, even if there were no transactions. Some entities are exempt from furnishing GSTR-9. These comprise composition scheme taxpayers, casual taxable persons, non-resident taxable persons, Input Service Distributors (ISDs), and persons who were registered only for TDS/TCS under GST. For taxpayers with total turnover in excess of ₹5 crore, GSTR-9C, a reconciliation statement duly signed by a chartered accountant or cost accountant, should be submitted along with GSTR-9.

Exclusions from Form GSTR 9 Filing 

While GSTR-9 is a compulsory annual return for regular GST-registered taxpayers in general, the Goods and Services Tax law provides for certain exemptions from submission of Form GSTR-9 to make compliance simpler and prevent unnecessary filings by some classes of taxpayers.

The following taxpayers are exempt from the submission of GSTR-9:

GSTR-9 filing is not necessary for taxpayers who are registered under the composition scheme. Instead, they were previously required to submit GSTR-9A, which has been suspended starting from the financial year 2019–20 onward.

Casual Taxable Persons: Those who make occasional taxable supplies and are not habitual taxpayers are exempt from filing GSTR-9.

Non-Resident Taxable Persons: Foreign taxpayers providing taxable supplies in India without a place of business are also exempt.

Input Service Distributors (ISD): Parties to whom input tax credit is distributed need not file this return.

Taxpayers registered only for TDS/TCS under GST: Those registered for deduction or collection of tax at source are exempt from filing GSTR-9.

Types of GST Annual Returns

Under the Goods and Services Tax (GST) regime, different types of annual returns are provided based on the character of the taxpayer's registration and turnover. It is important for legal teams to know the types of GST annual returns as accurate compliance and timely filing are dependent on it.

1. GSTR-9: This standard yearly return must be filed by all regular taxpayers who are enrolled under GST. It provides a summary of outward and inward supply during the financial year, input tax credit (ITC), tax paid, and adjustments through aggregation of details from monthly or quarterly forms (GSTR-1 and GSTR-3B).
2. GSTR-9C: For taxpayers with an overall turnover of more than ₹5 crore, 
3. The annual return filed in GSTR-9 with the audited financial accounts is reconciled in GSTR-9C. It is required to be certified by a chartered accountant or a cost accountant.
4. GSTR-9A was specifically created for taxpayers registered under the composition scheme. It has since been put on hold for financial years 2019–20 and later, and composition taxpayers are no longer compelled to submit it.
5. GSTR-9B: It was advocated for e-commerce operators but has neither been notified nor done so.

GSTR 9A Filing: Participants in the Composition Scheme 

GSTR-9A served as the annual return for taxpayers who opted for the GST Composition Scheme, where tax is paid at a fixed rate on total turnover, and input tax credit is not permitted. GSTR-9A summarized details of quarterly returns (GSTR-4) submitted in the financial year, such as outward supplies, tax paid, and amendments made.

Still, it should be noted by the leg

al team that GSTR-9A filing has been suspended from financial year 2019–20 onwards. The requirement for filing of GSTR-9A was waived by the government to reduce the compliance burden on small businesses operating under the Composition Scheme.

Now, composition taxpayers need to file GSTR-4 only annually, as well as quarterly payment of tax through CMP-08. Even though GSTR-9A has been suspended, there is no excuse for businesses not to keep proper records of transactions and payment of taxes so they are ready if their books are audited or scrutinized.

In the case of GSTR-9 filing, it is important not to mistake it for GSTR-9A. While GSTR-9 is for regular taxpayers, composition dealers have to adhere to the returns applicable under their scheme.

GSTR 9C: Reconciliation Statement Submission 

Taxpayers enrolled under the Goods and Services Tax (GST) regime whose aggregate revenue is more than ₹5 crore in a financial year need to furnish the GSTR-9C reconciliation statement. This statement is submitted along with GSTR-9 and plays a crucial role in matching the details reported in the annual return with the figures from the taxpayer’s audited financial statements.

To ensure that the books of accounts agree with the GST returns, GSTR-9C must be certified by a cost accountant or chartered accountant. It includes detailed reconciliation of turnover, tax paid, input tax credit, and any discrepancies encountered. In case of discrepancies, justifications have to be provided, and additional tax, if any, has to be paid.

The GSTR-9C: Reconciliation Statement Submission is of particular importance to the legal team. It displays the organization's tax accuracy and financial honesty. Legal practitioners have to ensure that all support documents are accurate, audit trails are followed, and all reconciliations are well justified.

Delays in filing GSTR-9C or errors in reporting can lead to penalties, audits, or legal action. Thus, legal supervision is crucial to achieve complete compliance and avoid potential regulatory issues.

What is the turnover limit on GSTR 9? 

It is important to understand the threshold of turnover for filing GSTR-9 to comply under the Goods and Services Tax (GST) regime. GSTR-9 is an annual return to be furnished by regular taxpayers enrolled under GST, consolidating the transactions disclosed during the financial year in returns such as GSTR-1 and GSTR-3B.

The current GST legislation mandate that taxpayers file GSTR-9 if their total yearly turnover exceeds ₹2 crore. For taxpayers with a turnover less than ₹2 crore, the filing of GSTR-9 is optional but still advisable for reconciliation and record purposes.

Also, there is an additional turnover threshold applicable for GSTR-9C, the reconciliation statement. Taxpayers with a turnover of over ₹5 crore per annum are mandated to file both GSTR-9 and GSTR-9C, which is to be certified by a chartered accountant or cost accountant.

How Can The Legal Team Help with Filing GSTR-9 Forms?

The legal team has an important role to play in ensuring compliant and accurate filing of GSTR-9, the annual return covering all GST transactions for a year. While the technical details of data entry and reconciliation lie with the finance or tax department, the legal team has the role of overseeing to reduce legal risk and ensure compliance with GST laws.

Reviewing the accuracy and completeness of disclosures furnished in GSTR-9 is one of the most important tasks of the legal team. It involves cross-validation of turnover, input tax credit (ITC), payment of tax, and adjustments reported during the year. Legal experts also ensure that exemptions, amendments, or transitional provisions are applied and interpreted properly.

Furthermore, the legal department assists in evaluating the applicability of returns, e.g., if GSTR-9C (reconciliation statement) is to be filed or not depending on the turnover of the organization. In case of disputes, audits, or notices from GST authorities, legal professionals play a key role in preparing responses, handling litigation risks, and keeping supportive documents on record.

Through close collaboration with the tax and finance functions, the legal function enhances the organization's GST compliance structure and avoids penalties, interest, or reputational losses due to erroneous or late GSTR-9 submissions.

With The Legal Team as your ally, your organization is sure to meet the deadlines for filing GSTR-9 with a reliable partner having domain expertise in GST compliance and legal nuances. Your annual return is accurately prepared and filed in time with the assurance of the legal team, avoiding chances of fines or legal issues.

Ready to make your GSTR-9 filing process a breeze? Leave everything in the capable hands of the legal team and get expert help every step of the way, along with a compliance guarantee. Begin today and experience a stress-free way to meet your GST obligations.

Cut the hassles of GSTR-9 filing. Contact the legal team today and secure your business's compliance with confidence.