GST audit and GSTR-9C after the 2021 change

Until 2021, businesses with turnover above ₹2 crore needed their GST reconciliation certified by a Chartered Accountant or Cost Accountant. From 1 August 2021, Section 35(5) of the CGST Act was removed. GSTR-9C is now a reconciliation statement that the taxpayer self-certifies.

GSTR-9C applies where aggregate turnover in the year exceeds ₹5 crore. It reconciles the turnover and tax shown in the audited financial statements with the annual return in GSTR-9. GST authorities can still conduct their own audit under Section 65 and order a special audit under Section 66.

Key points

  • GSTR-9 annual return is optional for turnover up to ₹2 crore
  • GSTR-9C applies above ₹5 crore of aggregate turnover
  • GSTR-9 and GSTR-9C are due by 31 December after the year end
  • Reconcile books, GSTR-1, GSTR-3B and GSTR-2B before filing
  • A departmental audit can still be called for at any time

General information only, not professional advice. Section references are to the Income-tax Act, 1961; corresponding provisions of the Income-tax Act, 2025 apply from 1 April 2026. Thresholds and dates may change by notification.

CA Rahul R. Mohite
CA Rahul Rajendra MohiteACA, M.Com · ICAI Membership No. 622387 · Founder, Rahul R. Mohite & Co., PuneFirm profile and key facts